ML20094L136

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Memorandum: Andrea Kock, San Onofre Nuclear Generating Station Lessons Learned from Canister Misalignment Event
ML20094L136
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 04/03/2020
From: Greg Warnick
NRC Region 4
To: Andrea Kock
Office of Nuclear Material Safety and Safeguards
References
Download: ML20094L136 (4)


Text

April 3, 2020 MEMORANDUM TO: Andrea Kock, Director Division of Fuel Management Nuclear Material Safety and Safeguards THROUGH: Mary Muessle, Director Mary C. Digitally signed by Mary C. Muessle Division of Nuclear Materials Safety Muessle Date: 2020.04.03 11:53:51 -05'00' FROM: Greg Warnick, Chief Gregory G. Digitally signed by Gregory G. Warnick Reactor Inspection Branch Warnick Date: 2020.04.03 12:05:21 -05'00'

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION LESSONS LEARNED FROM CANISTER MISALIGNMENT EVENT This memorandum serves to summarize Region IV staffs lessons learned assessment, which was completed to evaluate and review the effectiveness of agencys oversight at San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) relating to the licensees (Southern California Edison Companys (SCE)) canister misalignment event that took place August 3, 2018. The evaluation was conducted to determine if the Nuclear Regulatory Commission's (NRCs) processes to inspect, evaluate, and communicate the licensees event, performance, and corrective actions were appropriate and if any improvements should be captured into the NRCs ISFSI Program and Regions policies.

In summary, the evaluation determined that:

1) The NRCs ISFSI Inspection Program and the increased oversight implemented in accordance with Inspection Manual Chapter (IMC) 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at ISFSIs and for 10 CFR Part 71 Transportation Packages, was effective in assessing SCEs performance and ensuring appropriate agency focus was placed on the SONGS ISFSI to ensure that performance problems were identified and addressed.
2) Region IV staff identified eight recommendations that would enhance NRC programs and processes to further ensure that performance issues at ISFSIs are identified, assessed, and addressed in a timely, transparent, and thorough manner, with focus on safety.

CONTACT: Greg Warnick RxIB, DNMS 817-200-1249

A. Kock 2 Two of the eight recommendations are significant changes that fell within the scope of the NRCs recent ISFSI Inspection Enhancement Initiative working group and were adopted in full, and therefore, no additional actions are being proposed. The remaining six recommendations are lower level operational improvement items that were not within the scope of the working group and were considered improvement opportunities. Therefore, action items have been created for these to consider to further enhance the ISFSI Oversight Process.

The recommendations incorporated into the ISFSI Inspection Enhancement Initiative include:

Recommendation 1: Consider revising IMC 2690, Table A-2, to require additional oversight when a licensee is performing continuous off-loading campaign after cessation of Part 50 operations. A suggested frequency could be another inspection each quarter during a continuous off-loading campaign. This enhancement would require and provide additional resources for more frequent inspections when licensees are performing extended loading campaigns. Revising IMC-2690 would provide for increased regulatory oversight of licensee operations and create an opportunity to review changes that occur during an extended spent fuel loading campaign.

Recommendation 2: Consider enhancing the guidance in the applicable inspection procedures for: 1) In-depth review of procedures after dry-run changes have been incorporated, 2) systematic approach to training-based program reviews, 3) corrective action program reviews, and 4) design change reviews. These guidance enhancements for the inspection procedures should assist in focusing inspector reviews in these critical areas.

Actions Taken: These recommendations fell within the scope of the ISFSI Inspection Enhancement Initiative working group and were adopted in full.

Other lower level recommendations under review are as follows:

Recommendation 3: Consider more ISFSI inspector training under IMC 1246, B03, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector, to add: 1) 50.59/72.48 training courses, and 2) a systematic approach to training-based training course. Additional training in these subject areas would also assist inspectors in reviewing and assessing the licensees programs and operations.

Recommendation 4: Consider revising NUREG 1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, to include descriptions and examples to cover 10 CFR 72.75 reporting requirements. Guidance and examples for Part 72 notifications would improve a license holders ability to adequately determine if a notification to the NRC is required.

Recommendation 5: Consider revising the NRC Enforcement Policy to include ISFSI specific examples.

Recommendation 6: Consider establishing a policy or process that could dedicate Division of Fuel Management support outside the technical assistance request process.

Recommendation 7: Consider looking at an organizational practice that would dedicate more resources to establish a team taskforce or a dedicated branch for a single site where a significant event has occurred.

A. Kock 3 Recommendation 8: Consider establishing regional guidance to document and capture learned guidance in: 1) setup and conduct of webinars, 2) setup of use of the NRCs public website spotlight page, 3) learned enhancements to capture and address questions from the public, 4) directions for general improved staff engagement with the public, 5) learned enhancements on Congressional briefs, 6) learned enhancements for higher level NRC briefs.

Actions to be Taken: These six recommendations will be discussed for policy, guidance, organizational, and training changes with the relevant offices and regions by the end of Fiscal Year 2020.

A. Kock 4 SONGS LESSONS LEARNED FROM CANISTER MISALIGNMENT EVENT DATED - April 3, 2020 DISTRIBUTION:

SMorris, ORA MShaffer, ORA LHowell, DNMS CRegan, NMSS/DFM APearson, NMSS/DFM/IOB GWarnick, DNMS LBrookhart, DNMS ESimpson, DNMS WCSmith, DNMS JTrapp, RI DPelton, RIII Mark Franke, RII RidsNmss Resource RidsRgn3Dnms Resource SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: GEW Yes No Publicly Available Sensitive OFFICE C:RxIB D:DNMS NAME GWarnick MMuessle SIGNATURE /RA/ Mary C. Digitally signed by Mary C. Muessle DATE 4/2/2020 Muessle 11:55:38 -05'00' Date: 2020.04.03 OFFICIAL RECORD COPY