ML21125A266

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NRC-2021-000142 - Resp 1 - Interim, Agency Records Subject to the Request Are Enclosed
ML21125A266
Person / Time
Issue date: 05/05/2021
From:
NRC/OCIO
To:
Shared Package
ML21125A264 List:
References
FOIA, NRC-2021-000142
Download: ML21125A266 (38)
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Text

6-page attachment From: Kataoic Janine is a draft document To: R4ALLEGATION Resource and is being

Subject:

RIV-2019-010 Letter RFl.docx withheld in its Date: Tuesday, Ma rch 19, 2019 4:14:51 PM entirety under Attachments: RI V-2019-~ r~ FO IA exemption 5 Judith/Jesse:

Here is our stab at the RFI letter for RIV-2019-A-0010. I'd appreciate any comments or insights as you have more familiarity with wording these types of requests .

Thanks Janine Janine F. Katanic, PhD , CHP Chief, Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety US Nuclear Regulatory Commission Region IV office: 817-200-1151 email: Janine.Katan ic@nrc gov

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION rv 1600 EAST LAMAR BOULEVARD ARLINGTON, TEXAS 76011-4511 June 20, 2019 r ll7KCJ

SUBJECT:

RESPONSE TO THE CONCERN YOU RAISED TO THE NRC REGARDING HOLTEC INTERNATIONAL RE: ALLEGATION RIV-2019-A-0010 Dear l(b)(7)(C)

The U.S. Nuclear Regulatory Commission (NRG) has completed its follow up in response to the concern you brought to our attention on February 4 , 2019, regarding Holtec International at the San Onofre Nuclear Generating Station. Your concern was related to the Systematic Approach to Training (SAT) for tasks associated with fuel transfer operations. The enclosure to this letter restates your concern and describes the NRC's review and conclusions with regard to that concern . .

Thank you for informing us of your concern. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. We believe that our actions have been responsive to your concerns.

You should note that final NRG documents may be made available to the public under the Freedom of Information Act subject to redaction of information pursuant to the Freedom of Information Act. Requests under the Freedom of Information Act should be made in accordance with 10 CFR 9.23, Requests for Records. Information is accessible from the NRC's website at http://www.nrc.gov/readinq-rm/foia/foia-request.html#how.

Should you have any additional questions, or if the NRG can be of further assistance, please contact Mr. Jesse M. Rollins, Senior Allegation Coordinator, at the Region IV toll-free number 1-800-952-9677, Option 2, Monday- Friday between 8 a.m. and 4:30 p.m. Central time.

Information in writing may be provided to the address listed in the letterhead.

Sincerely, reg Warnick, Chief Reactor Inspection Branch Division of Nuclear Material Safety

Enclosure:

As stated

RESPONSE TO CONCERN ALLEGATION RIV-2019-A-00 10 To assist in our evaluation of your concerns, the NRC requested information from Southern California Edison Company (SCE) by letter dated March 26, 2019. The licensee provided a response to the NRC's request for information in a letter dated May 1, 2019. The NRC staff used this information, in part, to perform our independent review of the concern.

Based on our independent evaluation of the licensee's investigative efforts, the NRC verified that the licensee's response was independent of the organization investigated, that it was adequate in detail and scope, and the overall conclusions were supported by the attached documentation.

Concern Holtec International (Holtec) personnel at the San Onofre Nuclear Generation Station {SONGS) are not adhering to a Systematic Approach to Training (SAT) process when developing training for the movement and downloading of spent fuel canisters at SONGS. Specifically, Holtec practices inadequate use of Job Task Analysis {JTA).

Licensee Response to Concern From January 22 to August 3, 2018, Holtec International, a dry cask storage vendor performing operations for NRG licensee SCE at its SONGS facility, had implemented an ineffective SAT process. After the August 3, 2018, canister misalignment event, SCE led the effort to revise the Holtec training process based on the appropriate elements of SAT criteria, as defined in 10 CFR 55.4. Therefore, the current training program used by Holtec at SONGS is based on a rigorous job task analysis and is based on the SAT process.

Based on the results of its evaluation, SCE found that the Holtec training program was developed primarily based on the 10 CFR Part 72 requirements for which a SAT based training program is not required. However, fuel transfer operations at SONGS were being performed under its 10 CFR Part 50 license and required a SAT based training program. The evaluation found that the Holtec training program did not include all the appropriate elements of a SAT process prior to August 3, 2018. This was corrected as part of numerous corrective actions stemming from the August 3, 2018, canister misalignment event.

Currently Holtec is performing work at SONGS based on training programs that have been developed using the appropriate elements of the SAT process.

NRC Response to Concern The NRC initiated a Special Inspection in response to the August 3, 2018, canister misalignment event at SONGS. As a result of the Special Inspection, NRC issued a Notice of Violation to SCE for "Failure to assure that operations of important to safety equipment were limited to trained and certified personnel (10 CFR 72.190)," VIO 07200041 /2018-001 -03. This was one of five violations associated with the Special Inspection.

The Notice of Violation required SCE to submit a written response to the NRC within 30 days.

The response was required to contain the corrective steps taken to ensure full compliance was RIV-2019-A-0010 1 Enclosure

achieved. The licensee submitted their response to the NRC on December 26, 2018 (NRC ADAMS Accession No. ML18362A148). The corrective steps taken by the licensee included revising the training program to: (1) develop and implement a new site-specific training procedure; (2) develop and implement a SAT process; and (3) ensure all positions are described, with the required t raining and qualifications verified prior to performing fuel transfer activities. In addition, all fuel transfer personnel were required to demonstrate compliance with the new training procedure.

During follow-up inspection activities conducted in-office and on-site at SONGS on January 28 to February 1 and February 11-15, 2019, NRC inspectors reviewed the implementation of corrective actions performed by SONGS regarding VIO 07200041/2018-001-03. The inspectors concluded the licensee had performed adequate corrective actions to restore compliance, address extent of condition, and prevent reoccurrence, including implementation of a training program that included the requirements of SAT.

The resolution of the training violation and the conclusion by NRC inspectors that the SAT is being implemented by Holtec and SCE at SONGS will be documented in NRC Inspection Report 050-00206/2018-006, 050-00361 /2018-006, 050-00362/2018-006, 072-00041 /2018-002.

Therefore, based on our review, the NRC validated your concern that Holtec personnel at SONGS failed to adhere to a SAT process when developiing training for the movement and downloading of spent fuel canisters at SONGS. However, the licensee has since performed adequate corrective actions to restore compliance, address extent of condition, and prevent reoccurrence, including implementation of a training program that included the requirements of SAT.

RIV-2019-A-0010 2

From: Crutchley Julie .------,

To: Araguas Christian: Marcano Damaris: Crutchley Juliej{b)(?)(C) !carpenter Robert; l.m!e.....Eatl; ~

Micl:leJ.li: Katanic Janine: Browder Rachel: Bernal*Jayl r $ara: Hawk ns Sarenee: Meighan Sean: Opara Stella:

Cc:  ::~n~:1;: Mauci:l(b)(?)(C)

R4ALLEGAJION Resource I Peduzzi francjs: Moore Scan: Michalak Paul: ford Monjca: Miller John:

Attachment already Subject : Final NMSS/DFSM ARB Summary

  • 2/28/19 provided to requester in Date: Thursday, February 28, 2019 12:30:40 PM NRC-2021-000055, Attachments: Initial ARB Brjefino summary NMSS-2019-04 f inal odt Interim Response #2, pg.

126.

information that may fingerprint an alleger. Please use an er age orm w en *es and dispose copies in a e receptacle. Also, please l1!:lfil this message from your email in box and trash w Allegation NMSS-2019-A-0004, regarding Holtec International, was discussed at an NMSS/DFSM ARB on Thursday, February 28, 2019. The final ARB summary is attached.

Than ks, Julie U.S... RC *

  • Headquarters
  • Alie atlon _,_,_Team ,,,_,w JULIE A. CRUTCHLEY, Assistant Headquarters Allegation Team - Serving NRR, NRO, NSIR, NMSS, and OIP Office of Enforcement Mailstop: OWFN 14A50 Location: OWFN 14A36 Email: Julie.Crutchley@nrc.gov (best way to reach me)

Phone: 301-287-9293 Fax: 301-415-3790 (VoIP}

Visit our Sharepoint Page for forms, FAQs, and helpful links.

  • If this message contains sensitive aflegation material, please delete when no longer needed.

From: Kataoic Janine To: R4ALLEGAUON Resource Cc: Evans Robert

Subject:

RE: ACT: Review Allegation for ARB I RIV-2019-A-0010 (SONGS) **"SENSI I IVEALLEGA I ION MA I ERIAL***

Date: Wednesday, March 06, 2019 1:28:48 PM Attachment was Attachments: 19010 REDACTE.D ALLEGATION FORM 031319 ifk.pdf provided to requester in iroaoeOOJ 000 NRC-2021-000055, Interim Response #2, Jesse/Judith: pg. 95.

Attached is our update of the RIV allegation form. We still want to send an RFI to SCE, just change the due date from the original due date. Rob Evans is the POC for this allegation.

Janine Janine F. Katanic, PhD, CHP Chief, Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety US Nuclear Regulatory Commission Region IV office: 817-200-1151 email: Janine Katanic@nrc gov From: R4ALLEGATION Resou rce Sent: Thursday, February 28, 2019 2:05 PM To: Kata nic, Ja ni ne <Janine.Kata nic@nrc.gov>

Cc: Pruett, Troy <Troy.Pruett@nrc.gov>; Howell, Li nda <Linda. Howell@nrc.gov>

Subject:

ACT: Review Allegation for ARB I RIV-2019-A-0010 (SO NGS) * "'*SENSITIVE

,l\bbEG/\Tlml MATER IAL***

Importance: High Janine, As you know, HQ sent this case back to Region IV for review.

Please update the RIV allegation form with the relevant information from the HQ ARB, and provide a new recommendation. Please return completed form to ACES by Wednesday, March 6th .

V/r Jesse M. Rollins Senior Allegation Coordinator RIV/ORA/ACES 817-200-143 1

From: Warnjck Greg To: R4ALLEGAUON Resource Subject : RE: Action Overd ue I Closure Memo for RIV-2019-A-0010 Date: Wednesday, June 12, 2019 7:38:32 AM Attachments: 190010 Closure Memo and checklist.doc imaae002.ona Here you go. I've been out of the allegation loop for a couple of years, so, please let me know whether the attached meets your needs.

Greg From: R4ALLEGATION Resou rce Sent: Tuesday, June 11, 2019 2:19 PM To: Wa rnick, Greg <Greg.Wa rnick@ nrc.gov>

Subject:

Action Overdue I Closure M emo for RIV-2019-A-00 10

Greg, Just a reminder that we need the closure memo for this allegation.

The 120 date was 6/4 and we need to have the closure letter sent out to the Cl by 7/4.

Thank you .

V/r

("t;.1... ..

\~*~*;)

Jesse M. Rollins Senior Allegation Coordinator RIV/ORA/ACES 817-200-1431

OFFICIAL USE ONLY* SECURITY RELATED INFORMTION U.S. NUCLEAR REGULATORY COMMISSION

- - - WARNING - - -

NSITIVE ALLEGATI N MATERIAL THE ATTACHED D CUMENT CONTAINS MA RIAL WHICH MAY RELATE TO AN OF ICIAL NRC INQUIRY R INVESTIGATION WHICH MAY BE EXEM FROM PUBLIC SCLOSURE PURSUANT TO ONE OR MORE PA TS OF TITLE O, CODE OF PEDERAL R GULATIO S.

EONLY SPECIAL HAN NG REQUIRED WHEN NO LONGER NEE D, DIS OSE OF THE ATTACHED DOCUMENT IN AS SITIVE U LASSIFIED WASTE RECEPTACLE OR BY D STROYING BY NY MEANS THAT CAN PREVENT RECONS RUCTION IN WHOL OR IN PART. SEE MANAGEMENT IRECTIVE 12.5 FOR IN TRUCTIONS ON DELETING S NSITIVE ALLEGATION MA RIAL FROM LECTRONIC STORAGE MEDIA.

ACCESS T INFORMATION CONTAINED HEREIN LIMITED TO STA AS REQUIRED FOR BRIEFING AND RES UTION.

DISCLO URE OF INFORMATION TO UNAUTHORIZED P RSONS IS PROHIBITED.

N FORM 762

-2006)

OFFICIAL USE ONLY SECURITY RELATED INFORMTION RESPONSE TO CONCERN 1 ALLEGATION RIV-2019-A-0010 Approved By: Gregory Warnick, Chief, Reactor Inspection Branch June 10, 2019 Concern 1:

Holtec International (Holtec) practices inadequate job task analysis, in that they are not performing work based on the Systematic Approach to Training (SAT) process at the San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI).

Licensee Response to Concern 1:

The NRC requested information from the licensee regarding this concern by letter dated March 26, 2019.

The NRC staff utilized this information, in part, to perform our independent review of the concern.

From January 22 to August 3, 2018, Holtec International, a dry cask storage vendor performing operations for NRC licensee Southern California Edison Company (SCE) at its SONGS facility, had used an ineffective process to implement the SAT process. After an August 3, 2018, canister downloading incident, SCE led the effort to revise the Holtec training process based on the appropriate elements of SAT criteria, as defined in 10 CFR 55.4. Therefore, the current training program used by Holtec at SONGS is based on a rigorous job task analysis and is based on the SAT process.

Based on the results of its evaluation, SCE determined that the issue provided by NRC was substantiated.

It was determined that the Holtec training program was developed primarily based on the 10 CFR Part 72 requirements for which a SAT based training program is not required. However, fuel transfer operations at SONGS were being performed under its 10 CFR Part 50 license and required a SAT based training program. The evaluation found that the Holtec training program did not include all the appropriate elements of a SAT process prior to August 3, 2018. This was corrected as part of numerous corrective actions stemming from the August 3, 2018, canister misalignment event.

Currently Holtec is performing work at SONGS based on training programs that have been developed using the appropriate elements of the SAT process.

NRC Basis for Closure Concern 1:

NRC initiated a Special Inspection (SI) in response to the August 3, 2018, canister misalignment incident at SONGS. As a result of the SI, NRC issued a Notice of Violation (NOV) to SCE for "Failure to assure that operations of important to safety equipment were limited to trained and certified personnel (10 CFR 72.190)," NOV 07200041/2018-001-03. This was one of five violations associated with the SI.

The NOV required SCE to submit a written statement to the NRC within 30 days. The statement was required to contain the corrective steps taken to ensure full compliance was achieved. SCE submitted the written statement to the NRC on December 26, 2018 (NRC ADAMS Accession No. ML18362A148). The corrective steps taken by the licensee included revising the training program to (1) develop and implement a new site-specific training procedure; (2) develop and implement a systematic approach to training (SAT );

and (3) ensure all positions are described, with the required training and qualifications verified prior to performing fuel transfer activities. In addition, all fuel transfer personnel were required to demonstrate compliance with the new training procedure.

OFFICIAL USE ONLY - SECURITY RELATED INFORMTION During follow-up inspection activities conducted in-office and on-site at SONGS on January 28-February 1 and February 11-15, 2019, NRC inspectors reviewed the implementation of corrective actions performed by SONGS regarding NOV 07200041/2018-001-03. The inspectors concluded the licensee had performed adequate corrective actions to restore compliance , address extent of condition, and prevent reoccurrence, including implementation of a training program that included the requirements of SAT.

The resolution of the training violation and the conclusion by NRC inspectors that the systematic approach to training is being implemented by Holtec and SCE at SONGS will be documented in NRC Inspection Report 050-00206/2018-006, 050-00361/2018-006, 050-00362/2018-006, 072-00041/2018-002.

OFFICIAL USE ONLY - SECURITY RELATED INFORMTION LICENSEE RESPONSE TO AN ALLEGATION REQUEST FOR INFORMATION NRC STAFF REVIEW CHECKLIST The purpose of this checklist is to assist the staff in evaluating the adequacy ofa licensee's response to an allegation Request for Information (RFl), independently verifying aspects of the information provided by the licensee, and to support the development of the proposed basis fo r additional staff actions if it is determined that the licensee's response is inadequate, inaccurate, or otherwise unacceptable.

  • IMPORTANT: Notify the responsible Branch Chief and the AC/SAC of any NEGATIVE result. This checklist is to be filed in the allegation folder if it has a NEGATIVE result; otherwise discard.
  • Note: The term "licensee" in the worksheet refers to any NRC licensee, certificate holder, license or certificate applicant, or vendor that may be the subject of an allegation concern.

Affected Concern(s): Holtcc International practices inadequate job task analysis. in that they are not performing work based on the Systematic Approach to Training (SAT) process at the SONGS ISFSI.

Review Performed By: ~E= ri~c~J~.S

i~m""p'""s=o

n _ _ _ _ _ _ _ _ __ Date: May 24. 2019 A: Determining the Adequacy of the Licensee's Response to an Allegation RFI Note: " Yes" answers normally indicate that the licensee's response to an RFI is adequate, while "No" answers indicate additional action may be necessary.

Evaluator Independence Yes ___:L__ No _ Does the relationship between the individual(s) chosen by the licensee to evaluate the concern(s) and the concem(s) being evaluated allow for appropriate objectivity (e.g., third party or internal evaluator, but not in the same management chain as those involved in concern(s))?

Note: Use best judgment for smaller organizations when clear management chain independence may not be possible.

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Evaluator Competence Yes...:{_ No _ Based on the information provided, is the evaluator competent in related functional area?

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Depth and Scope of Evaluation Yes...:{_ No Are all RFI-related concerns addressed?

Yes_:{_ No Is the evaluation rigor commensurate with the level of concern detai l provided? For example, if appropriate, did evaluation include extent of condition review, root/apparent cause assessment, or generic

OFFICIAL USE ONLY - SECURI IV RELATED INFORMTION considerations?

Yes_.:!._ No Are the conclusions provided by the licensee supported by the evaluation?

Yes_{_ No Are all affected personnel/groups/departments considered in the evaluation? For example, if interviews were conducted, did the licensee describe the basis for the number and cross section of individuals interviewed and is basis adequate? Were the interview questions appropriate?

Yes_ No_ NIA _{_If the NRC asked additional specific questions, are they answered satisfactorily?

Yes No NIA_{_ If the names of specific individuals were referenced in the RFI, did the licensee contact those individuals and/or appropriately consider their involvement in the allegation concern?

Yes _ No _ N/ A_.:!.__ If specific documentation was referenced in the RFJ, did the licensee evaluate that documentation and/or appropriately consider it in the evaluation of the allegation concern?

Yes_ No _ NI A _.:!.__ If the licensee reviewed a sample of related documentation and/or potentially affected structures, systems, and components, did the licensee describe the sample and provide the basis for determining that the sample size was appropriately representative?

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Effectiveness of Corrective Actions Yes....:!_ No_ N/A _ If applicable, were appropriate immediate corrective actions taken by the licensee?

Yes _ No _ N/A_.:!.__ If applicable, were operability and reportability determinations appropriate?

Yes_.:!.__ No_ NI A _ lf applicable, were appropriate corrective actions proposed?

Yes_.:!.__ No _ N/A _ Ifapplicable, were issues entered into the corrective action program?

Yes_.:!.__ No_ N/ A _ If applicable, were the timelines for corrective action appropriate and timely?

OFFICIAL USE ONLY* SECURITY RELATED INFORMTION Comments: The ma jority of the content of this RFI was addressed by a previous NRC inspection finding related to the Holtec International training program as implemented at the San Onofre Nuclear Generating Station site.

NRC Violations (substantiated concerns only)

Yes _:/_ No _ N/A _ lfthe substantiated concern represents a violation, did the licensee appropriately acknowledge and articulate the violation in response to the RFI?

Comments: A 10 CFR 72.190 violation was cited to Southern California Edison {SCE) as a result of a Special Inspection into an August 3, 2018, canister misalignment event at the SONGS site. SCE acknowledged the training violation and discussed their corrective actions in response to the NOV, which included the identification that a SAT based training program was required. The corrective actions related to this violation addressed the concern articulated by this RFI.

B: NRC Independent Review Effort NRC staff evaluating the licensee's RFI response should attempt to independently validate aspects of the information provided by the licensee. Indicate any of the following that apply:

_ Additional questions submitted to the licensee.

~ Performed or coordinated an independent inspection or technical review activity to verify a condition indicated in the response.

~ Reviewed the results ofrecently conducted NRC inspections in the functional area related to the allegation concerns.

~ Verified the ex istence and applicability of technical references noted in the response.

B: NRC Independent Review Effort (Cont.)

~ Verified the existence and applicability of procedures referenced in the response.

Ensured revision number referenced is appropriate.

~ Verified the existence and content of cotTective action program documentation referenced in the response.

Checked calculations noted in the response.

Requested additio nal information from the licensee during the FRI review

....:L.. Other. Describe: NRC acknowledged the licensee's response to the NOV which cited the IO C FR 72. 190 training requirement in a letter dated .January 17, 2019, indicating that NRC would review their implementation of con-ective actions during a future inspection to determine whether full compliance has been restored and whether compliance will be maintained. NRC completed their inspection and review and will be closing out the violation in an upcoming inspection report. IR 050-00206/20 I 8-006, 050-0036 1/2018-006, 050-00362/2018-006. 072-0004I /2018-002.

OFFICIAL USE ONLY* SECURITY RELATED INFORMTION Comments: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

C: CO CLUSION

_.:!.._ Adequate RFI Response _ Inadequate RFI Response Basis: SCE acknowledged that the systematic approach to training (SAT) had not been previous ly successfully implemented at SONGS, but provided proof of their actions to address the training programs shortcomings in response to a previously identified NRC inspection finding.

Comments: It should be noted that having a SAT adherent training program is not a regulatory requirement of the 10 CFR 72 program. However, SCE found that fuel transfer operations at SONGS were being perfom1ed under their IO CFR Part 50 licensee and therefore required a SAT based training program.

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 EAST LAMAR BOULEVARD ARLINGTON , TEXAS 76011-4511 March 26, 2019 Mr. Doug Bauder, Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

REQUEST FOR INFORMATION RE: ALLEGATION RIV-2019-A-0010

Dear Mr. Bauder:

The U.S. Nuclear Regulatory Commission (NRC) recently received information concerning activities at the San Onofre Nuclear Generating Station. We request that Southern California Edison Company evaluate the information described in the enclosure to this letter and submit the results of that evaluation to the Region IV office. If Southern California Edison Company substantiates a concern, please discuss Southern California Edison Company's consideration of appropriate apparent or root causes, generic implications of the substantiated concern, and the appropriateness of corrective actions taken or planned.

If your evaluation identifies any potential compliance issue with regard to NRC regulatory requirements or NRG commitments, please inform us regarding the requirement or commitment that may have been violated, the corrective actions taken or planned, and the corrective action documentation that addresses the issue. We ask that you reference our tracking number (RIV-2019-A-0010) in your written response, and that you make any records of your evaluation available for possible NRC inspection.

The NRG will review your response to determine whether: (a) the individual conducting the investigation was independent of the organization with responsibility for the related functional area, (b) the evaluator has sufficient knowledge and experience to conduct a review in the related functional area, and (c) the evaluation was of sufficient depth and scope. Your response should describe how each of these attributes was satisfied.

If individuals were interviewed as part of your review, you r response should include the basis for determining that the number and cross section of individuals interviewed was appropriate to obtain the information necessary to fully evaluate the concerns, and the interview questions used.

If your evaluation included a sample review of related documentation and/or potentially affected structures, systems, and components, your response should include the basis for determining that the selected sample size was appropriately representative and adequate to obtain the information necessary to fully evaluate the concern.

D. Bauder 2 RIV-2019-A-0010 The NRC will consider these factors in reviewing the adequacy of your evaluation of this issue and in developing our conclusions with regard to the concerns provided in the enclosure.

Within 30 days of the date of this letter, submit in writing the results of that evaluation to Mr. Jesse M. Rollins, Senior Allegation Coordinator, at the address listed in the header of this letter. We request that your response include the details of your evaluation and findings related to the validity of the information provided. We request that your response only be sent to Mr. Rollins at the address listed in the header of this letter. No other copies should be sent to the NRC (i.e., your response should not be docketed or otherwise submitted to the NRC Document Control Desk).

Any information submitted electronically to the NRC should be provided on a CD or DVD as externally provided thumb drives are prohibited from use on NRC computers. The use of any web-based document room must provide only general support documents to avoid the release of allegation information beyond a "need to know;" i.e. procedures, work orders, etc. If you choose to utilize a web-based document room to provide any supporting documents, please specify the web location, any specific access requirements, and folder title of where the documents may be retrieved. In the title, please include Mr. Rollins' name and the date of this letter. Do not use the allegation number.

We also request that your response contain no personal privacy, proprietary, or safeguards information . If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhollding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by Title 10 of the Code of Federal Regulations (CFR) 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21 . If security-related Information is necessary to provide an acceptable response, please mark your entire response "Security-Related Information-Withhold from Public Disclosure Under 10 CFR 2.390."

This letter and its enclosure should be controlled and distribution limited to personnel with a "need to know." The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L.96-511.

D. Bauder 3 RIV-2019-A-0010 Please contact Dr. Janine F. Katanic, Chief, Fuel Cycle and Decommissioning Branch, at 817-200-1151 within 5 days to discuss your evaluation or investigation plan and how it will incorporate the request for information enclosed. Please provide any additional questions you may have at this time concerning this request.

Sincerely, IRA Jesse Rollins Acting for/

G. Michael Vasquez, Team Leader Allegation Coordination and Enforcement Staff Docket Nos. 50-361 ; 50-362; 50-206; 072-00041 License Nos NPF-10; NPF-15; DPR- 13

Enclosure:

As stated

D. Bauder 4 RIV-2019-A-0010 bee w/enclosure Allegation File l(b)(?)(F)

Document:

(b)(?)(F) I ADAMS: 0 No Note: if DRS Always include DRP associated Branch Chief on concurrence OFFICE AC:ACES SAC C:FCDB DD:DNMS TL:ACES NAME JLWeaver JMRollins JFKatanic LLHowell GM Vasquez SIGNATURE /RA/ /RA/ /RA/ /RA/ /JRollins for/

DATE 03/18/19 03/25/19 03/25/19 03/26/19 03/26/19 OFFICIAL RECORD COPY

NOT FOR PUBLIC DISCLOSURE Issue The U.S. Nuclear Regulatory Commission (NRC) has received information that Holtec International (Holtec) practioes inadequate job task analysis, in that they are not performing work based on the Systematic Approach to Training (SAT) process at the San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI).

Background

Title 10 of the Code of Federal Regulations (CFR) 72.44(b)(4) requires, in part, that the licensee shall have an NRG-approved program in effect that covers the training and certification of personnel that meets Subpart I. This is in reference to the requirements in 10 CFR 72.190, which are applicable to general licensees.

Title 10 CFR 50.120(b)(2) requires, in part, that the training program must be derived from a systems approach to training as defined in 10 CFR 55.4, for certain categories of nuclear power plant personnel.

Southern California Edison Company submitted and was granted approval in 2014 of the Holtec UMAX FSAR, Revision 4 . Section 13.2.1 of the UMAX FSAR, Revision 4, states, in part, that training modules are to be developed under the licensee's training program to require a comprehensive, site-specific training, assessment, and qualification (including periodic requalification) program for the operation and maintenance of the HI-STORM UMAX Spent Fuel Storage Cask System and the ISFSI.

In addition to evaluating the issue and providing the response information requested in the cover letter, we ask that your response address or include the following:

  • Explain in detail how the Holtec UMAX training program utilized at SONGS was developed under the licensee's training program.
  • Include a description of whether the Holtec UMAX training program utilized at SONGS implements the requirements under 10 CFR 50.120(b )(2). If so, explain in detail whether the Holtec training program utilized at SONGS addresses the five elements of a SAT program , as defined under 10 CFR 55.4. Furthermore, if the Holtec UMAX trai ning program utilized at SONGS implements the requirements under 10 CFR 50.120(b)(2),

does it apply to all workers involved with spent fuel movement or only certain positions?

If it applies only to certain positions, provide the names/titles of those positions (i.e. Cask Loading Supervisor, VCT Operator).

  • Include in your response, a training matrix for each position (i.e., ancillary, supplemental, or required) under the Holtec training program utilized at SONGS and the respective training modules for each position. Please document in the matrix whether the training modules are required to be implemented under a SAT program.
  • Provide a copy of the procedure by which Holtec performs Job Task Analyses for activities at SONGS. Provide a summary of Job Task Analyses performed by Holtec after August 3, 2018, for activities at SONGS. Does SONGS review and approve Holtec Job Task Analyses, and if so, how is that performed? If SONGS reviews and approves Holtec Job Task Analyses, provide a summary of the results of these reviews.

RIV-2019-A-0010 Enclosure NOT FOR PUBLIC DISCLOSURE

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 EAST LAMAR BOULEVARD ARLINGTON, TEXAS 76011-4511 May 6, 2019 MEMORANDUM TO: Greg Warnick, Chief, Reactor Inspection Branch FROM: Jesse M. Rollins /jlw for/

Senior Allegations Coordinator Allegations Coordination and Enforcement Staff

SUBJECT:

LICENSEE'S RESPONSE REVIEW RE: ALLEGATION RIV-2019-A-0010 The licensee has replied to our March 26, 2019, request for information related to the subject allegation. The March 13, 2019, ARB assigned your branch to review the licensee's response to the Cl's concerns that:

Holtec International practices inadequate job task analysis, in that they are not performing work based on the Systematic Approach to Training (SAT) process at the SONGS ISFSI.

Please review the attachment to ensure that the licensee's response to the concerns is adequate. The scope of your review should be predicated on many factors, such as, but not limited to, the licensee's past performance, the safety significance of the matter, and the level of licensee management possibly involved in the matter. You may want to consider whether: (1 )

the individual conducting the investigation was independent of the organization affected by the concern; (2) the evaluator was competent in the specific functional area; (3) the evaluation was of sufficient depth and scope; (4) the appropriate root causes and generic implications were considered if the allegations were substantiated; and (5) the corrective actions, if necessary, were sufficient.

Please provide a written response concerning the results of your review and/or provide a closure memo by May 27, 2019. Your response should address the concerns as listed in the Allegation Form's concern which has been assigned to your branch. Detailed guidance for providing a closure basis can be found on the ACES' SharePoint site. Please use the most current format as provided in the aforementioned guidance. This allegation is 91 days old as of today.

Please provide a brief/direct answer stating what was done and what was found. As appropriate, include any documented violations and findings; e.g. _ _ _ was identified and documented in Inspection Report ___ dated _ _. Please provide a draft copy of the report sections pertaining to the allegation and include ACES in the inspection report distribution list so that we may obtain a copy of the final report. In addition, please complete the attached RFI evaluation form. If any section response is negative, submit the form to ACES. If you conclude that the licensee's response was not adequate, promptly notify

your branch chief and an allegation coordinator. An electronic copy of the form may be found on the ACES' SharePoint site.

Should you have any questions, please contact me.

Please document your time as follows:

Indirect Charges Direct Inspection Activities A 11014 Support for Allegations (Reactors) ALG - Allegations A34007 Support for Allegations (Materials)

Attachments:

As Stated cc w/attachment:

Allegation File Page 2 of 2

RIV-2019-A-0010 LICENSEE RESPONSE TO AN ALLEGATION REQUEST FOR INFORMATION NRC STAFF REVIEW CHECKLIST The purpose of this checklist is to assist the staff in evaluating the adequacy of a licensee's response to an allegation Request for Information (RFI ), independently verifying aspects of the information provided by the licensee, and to support the development of the proposed basis for additional staff actions if it is determined that the licensee's response is inadequate, inaccurate, or otherwise unacceptable.

  • IMPORTANT: Notify the responsible Branch Chief and the AC/SAC of any NEGATIVE result. This checklist is to be filed in the allegation folder if it has a NEGATIVE result; otherwise discard.
  • Note: The term "licensee" in the worksheet refers to any NRC licensee, certificate holder, license or certificate applicant, or vendor that may be the subject of an allegation concern.

Affected Concern(s): _ _ _ _ __

Review Performed By: _ _ _ _ _ _ _ _ _ _ _ _ _ Date: _ _ _ _ __

A: Determining the Adequacy of the Licensee's Response to an Allegation RFI Note: "Yes" answers normally indicate that the licensee's response to an RFI is adequate, while "No" answers indicate additional action may be necessary.

Evaluator Independence Yes No Does the relationship between the individual(s) chosen by the licensee to evaluate the concern(s) and the concern(s) being evaluated allow for appropriate objectivity (e.g., third party or internal evaluator, but not in the same management chain as those involved in concern(s))?

Note: Use best judgment for smaller organizations when clear management chain independence may not be possible.

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Evaluator Competence Yes_ No _ Based on the information provided, is the evaluator competent in related functional area?

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Page 1 of 4

RIV-2019-A-0010 Depth and Scope of Evaluation Yes No Are all RFl-related concerns addressed?

Yes No Is the evaluation rigor commensurate with the level of concern detail provided? For example, if appropriate, did evaluation include extent of condition review, root/apparent cause assessment, or generic considerations?

Yes No Are the conclusions provided by the licensee supported by the evaluation?

Yes No Are all affected personnel/groups/departments considered in the evaluation? For example, if interviews were conducted, did the licensee describe the basis for the number and cross section of individuals interviewed and is basis adequate? Were the interview questions appropriate?

Yes No N/A If the NRC asked additional specific questions, are they answered satisfactorily?

Yes No N/A If the names of specific individuals were referenced in the RFI, did the licensee contact those individuals and/or appropriately consider their involvement in the allegation concern?

Yes No N/A If specific documentation was referenced in the RFI, did t he licensee evaluate that documentation and/or appropriately consider it in the evaluation of the allegation concern?

Yes No N/A If the licensee reviewed a sample of related documentation and/or potentially affected structures, systems, and components, did the licensee describe the sample and provide the basis for determining that the sample size was appropriately representative?

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Page 2 of 4

RIV-2019-A-0010 Effectiveness of Corrective Actions Yes No N/A If applicable, were appropriate immediate corrective actions taken by the licensee?

Yes No N/A If applicable, were operability and reportability determinations appropriate?

Yes No N/A If applicable, were appropriate corrective actions proposed?

Yes No N/A If applicable, were issues entered into the corrective action program?

Yes No N/A If applicable, were the timelines for corrective action appropriate and timely?

Comments:

NRC Violations (substantiated concerns only)

Yes No N/A If the substantiated concern represents a violation, did the licensee appropriately acknowledge and articulate the violation in response to the RFI?

Comments:

B: NRC Independent Review Effort NRC staff evaluating the licensee's RFI response should attempt to independently validate aspects of the information provided by the licensee. Indicate any of the following that apply:

Additional questions submitted to the licensee.

Performed or coordinated an independent inspection or technical review activity to verify a condition indicated in the response.

Reviewed the results of recently conducted NRC inspections in the functional area related to the allegation concerns.

Verified the existence and applicability of technical references noted in the response.

Verified the existence and applicability of procedures referenced in the response.

Ensured revision number referenced is appropriate.

Page 3 of 4

RIV-2019-A-0010 B: NRC Independent Review Effort (Cont.)

Verified the existence and content of corrective action program documentation referenced in the response.

Checked calculations noted in the response.

Requested additional information from the licensee during the FRI review Other. Describe: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

C: CONCLUSION

_ Adequate RFI Response _ Inadequate RFI Response Basis:

Comments: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Page 4 of 4

U.S. NUCLEAR REGULATORY COMMISSION

- - - WARNING - - -

S NSITIVE ALLEGATI MATERIAL THE ATTACHED DOC MENT CONTAINS M ERIAL WHICH MAY RELATE TO AN OFFICIAi:: NRC INQUIRY OR NVESTIGATION WHICH MAY BE EXEMPT FROM PU LIC DISCLOS E PURSUANT TO ONE OR MORE PARTS OF TITLE 1 CODE OF EDERAL REGULATIONS.

OFFICIAL __LY SPECIAL HAN EQUIRED WHEN NO LONGER NEEDED, ISPOSE OF HE ATTACHED DOCUMENT IN A SENSITIVE UNCL SSIFIED WAST RECEPTACLE OR BY DESTROYING B ANY MEANS THA CAN PREVENT RECONSTRUCTION I WHOLE OR IN PART. EE MANAGEMENT DIRECTIVE 12.5 F INSTRUCTIONS ON DEL TING SENSITIVE ALLEGATION MA ERIAL FROM ELECTRONIC S ORAGE MEDIA.

ACCESS TO INF RMATION CONTAINED HEREIN LIMITED TO STAFF AS EQUIRED FOR BRIEFING AND RES UTION.

DISCLOSURE F INFORMATION TO UNAUTHORIZED ERSONS IS PROHIBITED.

NR FORM 762 (9 005)

Page 1 of 5 The Allegation Form Allegation Number: RIV-20 19-A- 001 0 GENERAL INFORMATION I Facility Nam e: San Onofre Nuclear Generating Station/Holtec Docket/License#:

Received By: Judith Weaver/Jesse Rollins Branch Review By:

Responsible Division/Branch: DNMS/FCDB Initial ARB Date:

Date Received 30 Days 70 Days 90 Days 120 Days 150 Days 180 Days 02/04/2019 03/06/2019 04/15/2019 05/05/2019 06/04/2019 07/04/2019 08/03/2019 Is there a potential safety/security issue that requires an Emergent ARB? ~IN_o_ _ ~l lfYES,immediatelyinformyourBC&ACES.

Who identified/raised the issue? An alleger (Document contact information and alleger discussion points on last page.)

Alleger's Relationship to Facility: Licensee Employee BRIEF OVERALL ALLEGATION

SUMMARY

(Provide a short summary or selected keywords/topics/subject for the a/legation.)

Holtec is not adhering to a Systematic Approach to Training (SAT) process when developing training for the movement and downloading of spent fuel canisters at San Onofre Nuclear Generating Station.

I ALLEGATION REVIEW BOARD INFORMATION ARB Type: Initial Today's ARB Date: Prior ARB dates:

Reason for ARB: Initial I Number of Concerns: 1 I RFI INHIBITING FACTORS The allegation is made against licensee senior management or those parties who would normally receive and address the allegation.

D The licensee could compromise an investigation or inspection because of knowledge gained from the discussions.

D Information cannot be released in sufficient detail to the licensee without compromising the identity of the alleger.

D The alleger has taken the concern(s) to the licensee with unsatisfactory resu lts AND the alleger objects to sending an RFI.

D The licensee's allegation trend, quality of RFI response(s), problem identification and resolution, and/or cycle review results over the past two years are such that the NRC should independently evaluate the concern(s).

D The NRC evaluation would be more timely and efficient - there is an ongoing or upcoming inspection which could evaluate the concern or a similar/same concern is already bein g evaluated by the NRC.

D Significant public/Commission interest warrants independent assessment of concern(s).

D The Federal or State agency providing the information objects to the information being released.

Does the Cl object to the NRC requesting information from the licensee to support our evaluation? No I ARB PARTICIPANTS:

I ARB DISCUSSION, CONSIDERATIONS, AND COMMENTS RELATED TO ALLEGATION CASE (as appropriate):

ARB Minutes reviewed and approved by ARB Chair? Yes No Form updated: 08/ 02/2018

Page 2 of 5 The Allegation Form Allegation Number: RIV-20 19-A- 001 0 CONCERN STATEMENT: Describe the impropriety or inadequacy related to NRC regulated activity. Concern#: 1 This version of the concern statement, after approval by ARB, will be used in AMS, for acknowledgment/status/closure letters, RF/s, etc.

Reviewed and/or D Clarified by Branch 0 Approved by ARB SECTION 1 -To be completed by individual receiving allegation Individual receiving allegation also must complete Section 4, Allege, Contact Information and Discussion Points.

CONCERN (one or two sentence summary) AS DESCRIBED BY THE CONCERNED INDIVIDUAL:

This version of the concern, as written by the individual taking the allegation, must nQ.t be revised or changed by the branch/ARB.

Use the "Concern Statement" box above to revise or change the concern statement.

Holtec is not adhering to a Systematic Approach to Training (SAT) process when developing training for the movement and downloading of spent fuel canisters at San Onofre Nuclear Generating Station.

Concern Details (PROVIDED BY CONCERNED INDIVIDUAL):

What? When? Where? Who? Why?

The concerned individual had a concern that Holtec practices inadequate job task analysis, in that they are not performing work based on SAT (System Approval to Training) process. This inadequate job task analysis is regarding all movement and downloading of fuel.

7 anagement (Cl believes its contract management) is aware of this issue ... l(b_l(_ _

)(C_l_ _ _ _ _ _ _ _ ___,

Concern Background & Supporting Information (PROVIDED BY CONCERNED INDIVIDUAL):

Current status, corrective actions, information/documentation to review (e.g. (Rs, NNs, WOs), who was not ified, etc.

None.

INotes and Comments from Receipt Inspector (e.g. historical perspective, etc.):

None.

!CLAIM OF DISCRIMINATION OR H&I:

Claim of Discrimination or H&I? No

!SAFETY CONSCIOUS WORK ENVIRONMENT / CHILLING:

Concern Related To Chilling/SCWE? No SECTION 2 - To be completed by responsible branch Functional Area: Discipline:

Reactor De t: Res onsible Branch:

Branch Notes and Comments:

llf Concern were True, Describe Potential Safety/Security Impact:

Form updated: 08/02/2018

Page 3 of 5 The Allegation Form Allegation Number: RIV-20 19-A- 001 0 Follow-up ARB Input, Including RAC (if applicable): (Please include date) I Does the Concern Meet the Definition of an Allegation? (Provide basis if any of the first 3 boxes are unchecked.) I Check each question as applicable to this concern. (If all the statements below are checked, the issue is an allegation.)

Is it a declaration, statement, or assertion of impropriety or inadequacy?

Is the impropriety or inadequacy associated with NRC regulated activities or policy (e.g. SCWE)?

Is the validity of the issue unknown?

!Other exceptions to the allegation definition: (If any box below is checked, the issue should not be characterized as an allegation.) I If the concern does not involve potential wrongdoing, is the issue in the licensee's CAP and not accompanied by an assertion of inadequate licensee follow-up by the alleger?

Is the issue being handled by another form a I process, such as a petition for rulemaking or a petition filed in accordance with 10 CFR 2.206? Note: Allegation concerns forwarded by the 2.206 petition review committee should be treated as allegations.

  • d t* *
  • Allegat1on e m1t1on met.7 r YES ,-. NO l

I Note:

Licensee-identified wrongdoing I issues are treated as al/egat,ons.

!Concern Considerations: (Detailed discussion of wrongdoing, discrimination, etc. documented in ARF.}

Safety Significance: Use drop-down to make selection Describe the basis for the safety significance:

Alleged Wrongdoing? Use drop-down to make selection Regulatory Requirement (Req'd for Wrongdoing}:

Security Category: Use drop-down to make selection

!WILLFULNESS OR WRONGDOING:

    • For wrongdoing, provide a draft NOV for the underlying technical violation to ACES prior to ARB.**

Is there alleged willfulness or wrongdoing? Select One fTecHNICAL STAFF RECOMMENDATION(S):

    • If an RF/ is recommended, provide suggested RF/ questions to ACES prior to ARB**

Date Technical Staff Recommendation(s) Assigned Branch Est. Date Use drop-down to make selection Select Form updated: 08/02/2018

Page4 of 5 The Allegation Form Allegation Number: RIV-2019-A- 0010 ARB Discussion and/or Comments Related to Concern (if applicable):

IRFI Justification:

Were RFI inhibiting factors on the first page reviewed? Make selection

~ B DECISION: ~

ARB Date ARB Decision(s) Assigned Branch Due Date l_j Form updated: 08/ 02/2018

Page 5 of 5 The Allegation Form Allegation Number: RIV-20 19-A- 001 0 O In person O Email O Inspection O 0 1Transcript D OPA (FB, blog, etc.) O News Media

~ Telephone O Letter 0 HOO O DOL Complaint D Other office/ region O Internet O Other (describe): O Green Ticket IALLEGER CONTACT INFORMATION:

This information Full Name: [REDACTED) Email: marked "REDACTED" is in the original in the Mailing Address: [REDACTED) Telephone: allegat ion file.

[REDACTED) Cell Phone: [REDACTED]

[REDACTED) Occupation:

LLEGER PREFERENCE FOR FUTURE CORRESPONDENCE Contact by: Telephone Best time to contact: Between (' am and (' am

(' pm (' pm 0 Postal Service Ema il or: Between ('am and (' am

(' pm (' pm Other Requests/

Comments:

LLEGER DISCUSSION POINTS:

IDENTITY PROTECTION POLICY Was the Cl informed of the identity protection policy? Yes Does the Cl OBJECT to the release of their identity to another agency/jurisdiction? If the concerns are an Cl not asked agreement state issue or w ithin the jurisdiction of another agency (OSHA, FEMA, etc.), explain that we w ill t ransfer the concern to the appropriate party. If the Cl agrees, we may provide the Cl's identity for follow-up.

Was the Cl informed that their identity may be disclosed by 01 during an investigation of wrongdoing? No Did the Cl request no further contact with the NRC? (If yes, discuss t he value of continued involvement in t he No allegation process. Inform Cl we may stil contact him, if additional information is needed.

If "YES", were the benefits of continued process involvement discussed? N/A

!DISCRIMINATION / HARASSMENT & INTIMIDATION Was the Cl informed of their DOL rights and need to file with DOL w/in 180 days for personal remedies? No Does the Cl OBJEC to the release of their identity? Explain t hat t o follow-up on discrimination cases, their No identity will need to be released for the NRC to obtain specific and related information from the licensee.

!LICENSEE REQUEST FOR INFORMATION I Explain that if concerns are discussed with or information is requested from the licensee, the alleger's identity will typically flQt be revealed.

Does the Cl OBJECT to the NRC requesting information from the licensee to support our evaluation? No lf"YES", is the Cl concerned about being identified to the licensee? Yes Does the Cl OBJECT to the release of their identity to the licensee if necessary to obtain resolution (e.g. Cl not asked access authorization, FFD, dose records, etc.)? If the Cl agrees, we may provide t he Cl's ident ity for follow-up.

Form updated: 08/02/2018

Allegation Receipt

& Review Form ADDITIONAL CONTACT INFORMATION NRC Headquarters Department of Labor HOO (Immediate Safety Concerns): 1-301-816-5100 Main Call Center: 1-866-4-USA-DOL (M-F, 8am-5pm)

Non-emergency Toll-Free Hot Ii ne*: 1-800-695-7403 http://www.dol.gov

  • This hotline is not recorded from lam-Spm Eastern. Discrimination/Wage/Back-Pay Issues: 1-866-487-9243 After hours, this call will be transferred to a recorded line. TTY for all DOL issues: 1-877-889-5627 RIV Allegations OSHA Hotline: 1-800-952-9677 ext. 1245 1-800-32 1-OSHA Regional Offices:

Fax:1-817-276-6525 http://www.osha.gov/htm 1/RAmap. html Email: R4Allegation@nrc.gov BASIS FOR 01 PRIORITY (Taken from Allegation Manual, Exhibit 16):

HIGH PRIORITY = Matter, if proven, is of very significant regulatory concern. The potential consequences for safety, given the position of the person(s) involved and the safety significance are very high and would likely result in prompt regulatory action.

Examples:

  • Manager, RO, or RSO directing/performing/condoning any deliberate violation including providing false information to NRC or creating fa lse records that may raise an integrity issue calling to question NRC's reasonable assurance.
  • Directing/performing/condoning a deliberate violation In which, without consideration of intent, wou ld be SL-I, SL-II, or SL-Ill.
  • Knowingly providing incomplete/inaccurate information to NRC or licensee with the purpose of influencing a significant regulatory decision (i.e. restart, operability, license amendment, enforcement decision or discretion).
  • Deliberately covering up a matter so that a required report was not made. Had the report been made, NRC would likely have promptly sent inspectors or correspondence to follow up.
  • Deliberately covering up a matter to prevent identification of a significant issue during an inspection.
  • Willfully providing inaccurate/incomplete information to NRC or licensee, or creating false records that caused a wrong decision to be made by NRC or licensee.
  • Tampering w ith vital equipment at a power reactor that indicates a potential act of sabotage.
  • A deliberate violation of normal priority with the need for immediate investigation because of indications evidence may b e lost/tampered with.
  • Discrimination resulting from providing information regarding nuclear safety/regulatory issues directly to NRC.
  • Discrimination caused by licensee/contractor mid-level manager or above.
  • Discrimination resulting from raising concerns of degraded/non-conforming conditions that, if true, would impact operability of a safety-related SSC or safeguards equipment.
  • Discrimination that appears particularly blatant or egregious.
  • Other matters to which, because of the potential regulatory safety significance, a regional administrator or office director, with the concurren ce of a Deputy EDO, assigns a high priority.

NORMAL PRIORITY = Matter, if proven, is of significant regulatory concern. The potential consequence for safety is of concern.

Examples:

  • Any individual directing/performing/condoning a deliberate violation in which, without consideration of intent, would be SL-IV, and the violation was either NRC-identified, or involves a supervisor or a licensed operator, or the licensee has not taken sufficient corrective action (including sufficient d isciplinary action).
  • Licensee officials directing/performing/condoning violations in careless disregard of req uirements in which underlying violation would be SL-I, SL-II, or SL-Ill.
  • Knowingly providing incomplete/inaccurate information directly/indirectly to NRC or in records (if relatively isolated or insignificant record) maintained by licensee.
  • Deliberately covering up a matter not required to be reported to prevent identification during an NRC Inspection.
  • Willful failure to submit a required report to NRC for a matter not considered high priority.
  • Discrimination not amounting to high priority.
  • Relatively isolated deliberate failure to file a Form 241, "Report of Proposed Activities in Non-Agreement States," notwithstanding the examples considered a high priority.

LOW PRIORITY = Matter, if proven, is of concern but does not rise to the significance of high or normal priority.

Examples:

  • A situation in which, without consideration of intent, the underlying violation wou ld be cha racterized as minor, or as an SL-IV for situations that are licensee-identified, involve only low level non-supervisory personnel, and for which the licensee has taken sufficient corrective action (including significant disciplinary action against the responsible individual(s)).
  • Relatively isolated fa lsification of a record or falsification of records that are not significant.
  • Violations carused by careless disregard not covered by '1igher priorities.
  • Licensee or contractor-identified will ful violations of limited safety significance committed by individuals holding relatively low level positions.

Form updated, 08(02/2018

From: Evans Robert To : R4ALLEGATION Resource Cc : Katan jc Janine: Howell Linda Subject : Followup with SCE regarding RFI Letter dated 3/ 26/ 19 Date: Thursday, April 04, 2019 5:23:15 PM The RFI letter to Doug Bauder dated 3/26/19 for allegation RIV-2019-A-0010 included a request for SCE to contact the FCDB BC within 5 days to discuss SC E's evaluation or investigation plan and how it will incorporate the RFI. The letter also gave SCE the opportunity to ask any additional questions they may have concerning this RFI. In response , I discussed the licensee's plan and addressed their questions for the RFI.

SCE 's representatives on the call included Al Bates, regulatory and oversight manager, Manny Alverado, ECP manager, and Chris Cates, project manager.

The licensee plans to research and discuss how SONGS approaches training per regulations , specifically the systems approach to training. Their review will include interviews of those who developed the training program (before and after the 8/3/18 misalignment event). They will look at the Holtec training program before and after the 8/3/18 canister misalignment event.

We also discussed the types of information needed to respond to the RFI. We went through each request, discussing what information was needed to meet the intent of the request.

The licensee planned to complete the RFI within 30 days, but acknowledged that it may be necessary to ask for a short extension. Any extension would be coordinated through ACES.

Rob Evans Acting BC, FCDB

From: Kataoic Janine To : R4ALLEGATION Resource Subject : RIV-2019-A-0010 Date: Thu rsday, April 11 , 2019 4 :28:12 PM Hi Jesse :

I spoke to Ch ris Cates w/SONGS and he asked for an extension to May 10. I told him May 3. He hesitantly agreed that they wou ld work toward that date. He understands that we have time lin ess met rics. I to ld him that if they had comp leted any specific portion, t hey cou ld consider sending us in a partial so that we can start reviewing their response, and they ca n send in the rema in ing items at the extended date of May 3.

Janine F. Katanic, PhD, CHP Chief, Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety US Nuclear Regulatory Commission Region IV office: 817-200-1151 email: Janine Katan ic@nrc gov

From: Kataoic Janine To : R4ALLEGATION Resource Subject : RIV-2019-A-0010 HQ panel outcome Date: Thursday, February 28, 20 19 10:31 :04 AM Importance: High Listened to the HQ ARB on this matter. Since it has been determined that Holtec does not have a direct requ irement for a SAT but may have requirements under the SONGS training program , they will refer the allegation back to R4. HQ will send ack letter to meet timeliness goals.

I am guessing we need to take this back to an ARB and go forward with our initial thought of sending an RFI to SCE.

Earl Love mentioned that the Cl does not want to be called , since the phone is from the company. But the Cl has apparently recently exchanged some emails with Earl. I have not seen those. But I am wondering if we need them (redacted) or a synopsis from Earl to make sure we are not missing any information.

Janine F. Katan ic, PhD, CHP Chief, Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety US Nuclear Regulatory Commission Reg ion IV Division of Nuclear Materials Safety office: 817-200-1 151 email: Janine Kataoic@nrc gov

From: R4ALLEGAIION Resource To : Katanic Janine Cc : Pruett Troy: Howen Linda Subject : ACT: Review Allegation for ARB I RIV -2019-A-0010 (SO,~>L..,-------"-"'-""'!-'--1-'=--eu..u:=L..ll..ll.'LillL"--'---"J:ll,"L***

Date: Thursday, February 28, 20 19 2:04:34 PM Both attachments were Attachments: 19010 REDACTED ALLEGATION FORM 031319,pdf provided to requester in NRC-19010 HO Initial ARB odf 2021-000055, Interim irnaae003 ° 0 Response #2 , pgs. 95 and Importance : H~ h 126.

Janine, As you know, HQ sent this case back to Region IV for review.

Please update the RIV allegation form with the relevant information from the HQ ARB, and provide a new recommendation . Please return completed form to ACES by Wednesday, March 6 th .

V/r Jesse M. Rollins Senior Allegation Coordinator RIV/ORA/ACES 817-200-1431

From: R4ALLEGAIIQN Resource To: Crutchley Julie Cc: HOAl!egations Resource: Katanic Janjne: Evans Robert

Subject:

RE: New Allegat ion Regarding Holtec Date: Thursday, February 14, 2019 2:10:52 PM Attachments: imaqe002.png Thanks, Julie.

I've copied Janine Katanic and Rob Evans on this email. They'll be your technical points of contact from Region IV on this issue. Please include them on the invite to your ARB.

V/r Jesse M. Rollins Senior Allegation Coordinator RIV/ORA/ACES 817-200-1431 From: Crutch ley, Julie Sent: Thursday, February 14, 2019 1:43 PM To: R4ALLEGATIO N Resource <R4ALLEGATION.Resource@nrc.gov>

Cc: HQAllegations Resource <HQAllegations. Resource@ nrc.gov>

Subject:

RE: New Allegation Regard ing Holtec Thanks Jesse - our number is NMSS-2019-A-0004.

From: R4ALLEGATION Resource Sent: Thursday, February 14, 2019 11:26 AM To: HQAllegations Resource <H0Allegatjons.Resource@nrc.gov>

Subject:

New Allegat ion Regarding Holtec Importance: High HQ, Attached is a new concern regarding Holtec's fai lure to adhere to a Systematic Approach to Training (SAT) at SONGS. Dori - this is the one we spoke about over the phone.

We discussed this allegation at a RIV ARB on February 12, 2019, and the ARB determined that the allegation should be provided to HQ since it's primarily about Holtec, and the likely method of evaluation (if warranted) would be an RFI to Holtec. There also may be some SCE (SONGS) aspect to the allegation since they have oversight responsibilities. T he ARB proposed HQ ownership with RIV participation in the ARB and assistance as needed. Let

me know what you think.

As you 'll see, the Cl's concern is lacking a lot of specifics so we 've tried to reach out and get more. The Cl has not returned our call. The Cl initially called us on a company cell phone to report the concern , then got a little spooked whens/he real ized that the licensee may be able to view a record of the call , and asked us not to call back on that number. The Cl instead gave us their spouse's cell phone number. We reached the Cl 's spouse and requested a call back but we have not received one.

I've asked our technical staff to speak with the group that would handle this up in HO so they're not surprised . I wanted to get this to you now instead of waiting any longer for a reply from the Cl.

Please confirm receipt.

V/r Jesse M. Rollins Senior Allegation Coordinator RIV/ORA/ACES 817-200-1431

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