ML19183A362

Audio Transcript of June 3, 2019, Webinar

ML19183A362
Person / Time
Site:	San Onofre
Issue date:	06/03/2019
From:	Division of Nuclear Materials Safety IV
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WEBINAR TRANSCRIPT This document provides the transcript from a public meeting (webinar) that was held on June 3, 2019, to update the public on the status of fuel loading at the San Onofre Nuclear Generating Station. Fuel transfer operations were suspended following an August 3, 2018, incident that resulted in the misalignment of a multi-purpose canister loaded with spent fuel at the San Onofre Nuclear Generating Station.

Hosts of Webinar:

Linda Howell, Acting Director Division of Nuclear Materials Safety Region IV Lee Brookhart, Senior ISFSI Inspector Reactor Inspection Branch Division of Nuclear Materials Safety Region IV

Good afternoon, and thank you for joining the webinar.

My name is Linda Howell, I'm the Acting Director of Region IV's Division of Nuclear Material Safety.

With me is Mr. Lee Brookhart, the region's Senior Dry Fuel Storage Inspector.

The purpose of this afternoon's meeting is to share information concerning NRC's evaluation of the final outstanding issue that I briefed you on back in March, which involves changes or exceptions planned for the UMAX Final Safety Analysis Report to accept that minor scratching might occur as the result of incidental contact between the multipurpose canisters and internal components of storage vaults in the UMAX dry fuel storage system.

Our discussion this afternoon will also cover the process that we used to make the determination that Southern California Edison could resume fuel transfer operations, and I will talk briefly about some activities that Southern California Edison has identified

as needing to occur before they begin active fuel transfer operations.

Next slide please.

As you see on the agenda, following discussion regarding NRC's decision on the resumption of fuel transfer operations we'll open the meeting to accept questions from our audience.

This is a Category 3 meeting, so public participation is encouraged.

However, due to the period of time that we have reserved for this webinar, and in the interest of fairness to all participants, I would like to ask that audience members limit their questions to two, initially, so that we can address questions from as many participants as possible in the time allotted.

As we've done in the past, questions and comments from today's session will be posted to our Spotlight page.

I acknowledge that several of you have provided feedback on our delay in responding to your questions from prior webinars, but we do have those in process now.

Up until now, our staff has been fully occupied with

inspecting SONGS efforts.

I'll also note that in addition to today's webinar Scott Morris, our Regional Administrator, and I will also be speaking at the San Onofre Community Engagement Panel meeting this coming Wednesday, June 5th.

We look forward to meeting with some of you directly and answering any questions that you may have.

Next slide please.

In the event of an emergency, all of us in the room will stay together and exit the building through the front doors.

We'll remain in the parking lot until the situation is over and we're allowed to reenter the building.

We will provide notification to the audience participants in the event that we do have an emergency.

Let me also ask the staff in the room to silence your cellphones during the meeting and please keep your voices down because the meeting is being recorded.

Lastly, be mindful that the meeting is being broadcast, so if individuals present need to exit the room,

please use the rear doors.

As noted in the slides, should we have technical difficulties with the webinar broadcast, a telephone bridge will be available.

The phone number for that bridge is on the slide.

The bridge line will only be activated if we experience technical difficulties with the broadcast.

These slides are available on the Spotlight portion of the NRC public webpage at www.nrc.gov.

From the Spotlight section on the left side of the page click on "SONGS Cask Loading Issue".

You'll find a file name with the NRC webinar presentation on our final determination on fuel loading operations.

The slides are also already available on the NRC's Agency-wide Document Access and Management System, or ADAMS.

The video and transcript from today's meeting will also be posted to the Spotlight section of our webpage.

In addition we'll post the comments and questions that we receive this afternoon.

Please note that the transcript of the meeting

and the questions will take a few weeks to be posted since NRC must receive the transcript from the contractor who is providing the webinar service, and review both the transcript and questions to ensure accuracy of the information.

We are also required by the Americans with Disabilities Act to provide closed captioning for the video.

We apologize in advance for the delays and inconvenience, but we cannot control or expedite this process.

Those of you who have registered for the webinar, however, will be able to access the video shortly after the conclusion of the meeting.

During the presentation, you may submit written comments and questions via the webinar chat room feature.

We'll answer questions and respond to comments as time allows.

This webinar is scheduled to end at 1 p.m. Pacific Time.

Next slide please.

I expect that many of you here today are familiar with the August 3rd incident

that occurred at San Onofre.

But because we have some attendees that have not followed this particular event and follow-on activities closely, I am going to provide a brief overview of key activities that have occurred since August 3, 2018.

On August 3rd, Southern California Edison was lowering a loaded spent fuel canister into its underground storage vault.

For the current fuel offload for Units 2 and 3, Southern California Edison is using the HI-STORM UMAX dry fuel storage system designed by Holtec International which provides dry spent fuel storage in a vertical below grade configuration.

As that canister was being lowered into the storage vault, the licensee personnel failed to notice that the canister was misaligned and was not being properly lowered.

Licensee personnel continued to lower the lifting equipment until they believed that the canister was fully lowered into the bottom of the storage vault.

As the staff prepared to approach the ISFSI pad, a radiation protection technician

identified elevated radiation levels that were not consistent with a fully-lowered canister.

Licensee personnel participating in the evolution then identified that the loaded spent fuel canister was resting on a metal shield ring near the top of the storage vault, preventing it from being lowered, and that the rigging was completely slack, no longer bearing the load of the canister.

With the vertical cask transfer system lift beam completely lowered, and that equipment is used to lower and lift canisters into and from the storage vaults, the important-to-safety slings were disabled from performing their safety function of suspending and controlling the loaded spent fuel canister.

The licensee estimated that the canister could have experienced an approximate 17 to 18 foot drop into the storage vault if the canister had slipped off the metal ring or if the metal ring failed.

This load drop accident is not a condition analyzed

in the dry fuel storage system's Final Safety Analysis Report, which is tied to the Certificate of Compliance or the licensing document.

The licensee estimated that the canister was in an unanalyzed drop condition for a period of 45 minutes to one hour.

Licensee personnel did restore control of the canister load.

They repositioned the canister and safely lowered it into the storage vault.

The licensee halted all dry fuel storage movements to fully investigate the incident and develop corrective actions.

The licensee also promptly shared operational experience with other users of the UMAX storage system.

Currently there is only one other site that uses the UMAX dry fuel storage system in the United States, and that's the Callaway plant in Missouri.

Region IV became aware of the incident on August 6th when Southern California Edison provided a courtesy phone call to our staff and described the incident as a near-miss event.

NRC staff determined that the licensee should have made a 24-hour event report to the NRC operations center and informed Southern California Edison staff of their determination.

During discussions with Region IV managers on August 6th, including myself, Southern California Edison committed to suspend fuel transfer operations until they completed an investigation of the incident, understood the causes, and implemented corrective actions based on their investigation findings.

They further committed to continue to suspend fuel transfer operations until NRC completed an independent investigation, and was satisfied that Southern California Edison's corrective actions were adequate.

Hence, the prolonged suspension of fuel transfer operations at the site.

Next slide please.

NRC initiated a special inspection and had an inspection team onsite the week of September 10, 2018, to interview personnel, observe equipment, and review relevant documentation,

including the licensee's investigation and proposed corrective actions.

The inspection included many hours of subsequent in-office review of the licensee's many causal analyses and technical assessments that were not complete at the time of the onsite portion of our inspection.

The special inspection report was issued on November 28, 2018, with an errata published on December 19th.

The report documented three Severity Level IV Violations, which are the lowest safety significance for cited violations under our enforcement policy.

The report also described two apparent violations, which were considered for escalated enforcement action.

The three Severity Level IV violations involved failures to establish measures to ensure that conditions adverse to quality were promptly identified and corrected, and that refers to the licensee's formal corrective action program, failure to ensure operations of equipment and controls identified as important to safety

were limited to trained and certified personnel, and a failure to provide qualitative or quantitative acceptance criteria in procedures to ensure that important activities are accomplished as planned during dry fuel storage operations.

Correspondence transmitting the special inspection report offered the choice of participation in a predecisional enforcement conference or an alternate dispute resolution session to address the apparent violations.

Southern California Edison elected to participate in a predecisional enforcement conference.

That conference was conducted on January 24, 2019, and was broadcast via public webinar.

Next slide please.

NRC inspectors began Follow-up inspections at SONGS in November 2018 to independently assess the licensee's corrective actions and technical assessments.

The inspection effort is now reaching its conclusion.

During the follow-up inspections, NRC identified several

weaknesses and corrective actions implemented by the licensee.

These included: causal evaluations did not address radiation protection issues, which we believed contributed to some of the causal factors associated with the incident, and changes made to the executive oversight board process were inadequate, meaning they were more administrative than substantive.

Procedure changes, particularly for the downloading procedure, lacked contingency steps for equipment failures, had incomplete criteria for suspending downloading operations, and had incomplete steps to meet seismic criteria during canister transport from the fuel building to the spent fuel storage pad.

We also noted a weakness in review of maintenance procedures.

The new equipment enhancements put in place were improperly designated as not important-to-safety, when they should have been important-to-safety,

the new load sensing devices were not procured in accordance with the vendor's design purchase specifications, and the load sensing devices were not tested to the appropriate load capacity.

While we did identify weaknesses, I want to note specifically that the equipment was not used to transfer fuel prior to correcting these issues.

The licensee also identified that past movement of loaded canisters from the fuel building to the storage pad may have resulted in the transport unit coming too close to structures along the route.

NRC inspectors identified that when the Vertical Cask Transporter, which again, is used to move the canister on the storage pad, approached the storage vault mating device, licensee personnel prematurely removed a seismic restraint, contrary to the associated seismic analysis.

These weaknesses factored into the NRC's decision on proposing a civil penalty

for the escalated enforcement action.

Next slide please.

On March 25, 2019, the final enforcement action was issued, and a public webinar was conducted the same day to discuss the final action with public stakeholders.

The final enforcement action included two violations.

The first violation involved the failure to ensure that important-to-safety equipment was available to provide redundant drop protection for a loaded spent fuel canister during canister downloading.

The spent fuel storage system used by Southern California Edison requires its spent fuel canister be lifted and carried with redundant drop protection features.

This was categorized as a Severity Level II violation.

The NRC considered whether credit was warranted for identification and corrective action.

No identification credit was given because the violation was identified through a self-revealing event.

No corrective action credit was granted based on several considerations,

including the weaknesses that I just discussed.

In accordance with the NRC enforcement policy, this violation was assessed a $116,000 civil penalty.

I just want to pause and note that issuance of a Severity Level II violation, the second most safety significant category under our enforcement policy, has never been done for a spent fuel storage licensee.

The second violation involved failure to make timely notification to the NRC.

Licensees are required to notify the NRC within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> of the discovery of events involving spent fuel in which important-to-safety equipment is disabled or fails to function as designed.

This violation was categorized as a Severity Level III violation.

Since SONGS has not been the subject of escalated enforcement within the past two years, corrective action credit was considered.

The NRC did determine a corrective action credit was warranted, and no civil penalty was assessed for that violation.

A response to the Notice

of Violation was received by NRC on April 23, 2019.

We reviewed the licensee's response and found it satisfactory.

But I want to note that our review of the licensee's corrective actions, as described in their correspondence, was supplemented by our many months of inspection activities.

Region IV representatives subsequently attended the SONGS Community Engagement Panel meeting in California on March 28th.

We were represented by the Region IV Regional Administrator, Scott Morris, and myself.

Along with staff from the Office of Public Affairs and the Office of Congressional Affairs, Scott and I also met with congressional district staffers on March 28th while we were in Southern California.

We discussed all the observations of our follow-on inspection and the final enforcement action during those engagements.

I also want to note or remind you that during the March 25th public webinar, and the March 28th Community

Engagement Panel meeting, we discussed the licensee's corrective actions and observations from the NRC's follow-up inspection that was initiated back in November 2018, and which is still ongoing.

NRC noted that while certain weaknesses in the licensee's corrective actions were observed, with one exception, all corrective actions and observed weaknesses had been addressed as of the March 25th webinar.

The one outstanding issue involves scratching of canisters during fabrication or handling prior to insertion, during canister insertion, and possibly during future canister withdrawal.

This was determined to be an outstanding compliance issue, not a safety issue, which needed to be resolved before the licensee resumed fuel transfer operations.

And with that, let's move on to the next slide, and resolution of that outstanding issue and the path to resuming fuel transfer operations.

The issue of incidental contact

during canister insertion and the potential for scratching was initially discussed with Southern California Edison when we began our follow-up inspection back in November 2018.

Southern California Edison reviewed several approaches to demonstrate that potential scratching, due to incidental contact between canisters and the internal storage vault components, would not exceed allowable American Society of Mechanical Engineers, or ASME, code limits.

I'll also note that the technical specifications associated with this Certificate of Compliance do reference Section III of the ASME Code.

Southern California Edison ultimately initiated in situ visual assessments of downloaded canisters using robotics and three-dimensional video imaging.

We talked a little bit about this at the March 28th Community Engagement Panel meeting.

That method of examination

is commonly used in the aeronautics industry and is being examined for future use as an option in spent fuel canister aging management programs.

The statistically suitable number of canisters, a total of eight, were examined with imaging of the canister wall surfaces.

Using a statistical analysis methodology, and the actual canister wear data, as visualized during the three-dimensional imaging, the licensee concluded that there is 95% probability with a 95% confidence level that a scratch after canister insertion and withdrawal would not be any deeper than what is allowed under the ASME Code.

Their evaluation encompasses scratches that might occur during insertion, scratches that might occur during withdrawal, and assumes that those two models of scratches may be superimposed.

The evaluation also considers the potential for these scratches to overlay flaws that may have resulted during fabrication

or handling prior to downloading.

The scratch depth calculated by the licensee's analysis is viewed as conservative within the allowable ASME Boiler and Pressure Vessel Code limits.

For this situation, the applicable limit for wear is less than 10% of the canister wall thickness.

The licensee then used the 10 CFR 72.48 review process to support a change to sections of the UMAX Final Safety Analysis Report to acknowledge that some canister scratching or wear may occur during operational activities.

And if you recall our earlier discussions in March, there are two subsections of the Final Safety Analysis Report that stated that there was ample room between the canister and the interior wall of the storage vault such that no scratching could occur.

That's since been demonstrated to not be the case.

Next slide please.

So let's move on to the NRC's evaluation.

Now that I've shared what

Southern California Edison has completed in its evaluation, I'll explain what the NRC has done in terms of our assessment of that evaluation.

First, we had an inspector on site to observe seven of the eight canister examinations.

Our inspection activities were focused on verifying the effectiveness of the process and the validity of the data obtained, so that we would be better prepared to review Southern California Edison's report.

So our inspector was actually standing side by side with Southern California Edison's contractor looking at the data as it was transmitted so that we could verify that the data in Southern California Edison's report was the same as what we saw while the examination was ongoing.

We did not simply accept a report from Southern California Edison.

We independently validated the data obtained during the canister examinations.

NRC staff also performed independent statistical assessments using several methods which verified that the licensee's evaluation reasonably bounds

the maximum scratch depth.

We used a staff member who has a doctorate degree in statistics to verify the licensee's analysis.

That staff member also used the actual data obtained through the visual assessments to perform independent statistical analyses using several models that were appropriate for the sample size.

Our conclusion, through our independent assessments, is that the conclusion presented by Southern California Edison was conservative and reasonably bounds the maximum anticipated scratch or wear resulting from operational activities.

Next slide please.

I and my staff briefed senior agency management on our conclusions, and on May 17th I was authorized to notify senior Southern California Edison management that NRC had completed its review of the canister scratching analysis and accepted the Southern California Edison evaluations.

Southern California Edison was informed that once they confirmed that they were confident

that all corrective actions had been completed to their satisfaction, the NRC has no objection to them resuming fuel transfer operations.

Southern California Edison documented the basis for their decision to prepare to resume fuel transfer operations in a letter to the NRC dated May 17th.

That letter is now publicly available in our electronic document system, or ADAMS, and the document is also available in the Spotlight section of the NRC webpage.

In its correspondence Southern California Edison described additional activities that must occur prior to resuming fuel transfer operations.

These include training employees, ensuring that personnel qualifications are in place, and completing certain equipment checks.

Completion of these activities is expected to take several weeks, and Southern California Edison is committed to provide us verbal notification when they are ready to resume fuel transfer operations, in

advance of actually doing so.

In the interim, I and my staff continue weekly teleconferences with senior Southern California Edison managers to obtain updates on site activities so that we can plan our inspection and oversight activities effectively.

Depending on the type and extent of training that will need to be done prior to resuming fuel loading we may be on site to observe those activities.

Once the licensee resumes fuel transfer operations, we will initiate unannounced inspections that will be performed frequently to observe the licensee's implementation of their enhanced programs.

I anticipate performing inspections several times for a few days during the calendar quarter, and then we will produce formal reports to let the public know how the activities are proceeding.

We'll continue to engage with the public to keep you informed.

We plan to support the upcoming June 5th Community Engagement Panel meeting,

and we are developing strategies for holding a public meeting in a community local to SONGS.

With that, I'd like to turn the meeting over to our facilitator, Mr. Austin Roberts.

Austin has been monitoring questions as they've been submitted during the webinar.

And again, I want to note that in the interest of fairness, we'll limit questions from a single audience member to two, so that we can maximize the ability for all participants to submit questions, and then we'll come back for additional submittals as time permits.

Thank you.

- Good morning, or good afternoon.

My name is Austin Roberts and as facilitator for this meeting I will be asking questions and addressing comments from the public and putting them to our panel here.

From the back of the room, so far we have not had any public questions put to us through the attendees of the webinar.

If you are attending the webinar, you have a Questions tab at the side of your screen, which you can use to put questions to us.

It is similar to an instant message feature.

We'll be seeing those on our side, and we'd be happy to address any public comments or questions that you may have regarding our decision to allow the resumption of fuel transfer operations.

Our first question from the public, how is the NRC factoring lessons learned from the San Onofre event into its oversight efforts at other sites?

- That's a great question, and we have talked about that in the past.

We will be collectively, with our peers in the other regional offices and the applicable division in the Office of Nuclear Materials Safety and Safeguards, taking a look at the oversight process.

By that I mean our inspection procedures, to see if anything can be enhanced to either look at things in different sequences or at different frequencies.

- Thank you.

If there are any other

questions from the public, again, it's the Questions tab, it should be on the right-hand side of your screen.

Our second question from the public, excuse me one second, the contents of can number 30 were removed from the spent fuel pool 10 months ago.

Canister number 30 is now in the fuel handling building inside a transfer cask; is the NRC concerned about dangerous heat buildup inside canister number 30?

And they also want to know if you can tell us what is the internal and exterior temperatures of can number 30?

- When we were on site during January and February we did go into the building that contains the canister number 30.

We are not concerned with the heat on the canister.

They go in every day, I think two times a day, every 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br /> and take measurements on the outside of the canister, and is well below any kind of the design safety values.

So there's no concern on the canister.

It can stay in the fuel building

indefinitely, if need be.

- Thank you.

Will there be any design changes to the ceiling alignment rings in the vaults?

- At the present time we have no indication from Holtec that they anticipate any design change with those components.

- I have another design related question:

Are you addressing the substandard thin casings issue?

We need the super thick casings that are transportable to be used instead.

- I'll take that one.

The canisters that are in use for the UMAX spent fuel storage system have been approved, and there is no foreseeable safety issue with them.

- Thank you.

Did the NRC's root cause analysis determine that gouging on the walls is caused by a lack of a precision canister downloading system?

- The NRC evaluated the root cause analyses completed by Holtec- or by Southern California Edison and its contractor Holtec.

And we have no indication that the gouging

needs to have any further evaluation.

We're comfortable with their conclusions on how the gouging, actual scratching occurred.

- Thank you.

Will the NRC be on hand for the first canister loading once it resumes?

- Yes, we do plan to be on hand when the licensee resumes fuel transfer operations.

I mentioned in my discussion that we are holding weekly conversations with Southern California Edison, and the purpose of those conversations is to actually be aware of what their schedule and their anticipated resumption date is.

- Our next question is about the physical condition of the canisters.

The canisters would have months of coastal salt air and soot baked onto the surface.

How did the licensee clean the surface of the canisters before the visual inspection with the cameras?

- There was no need to clean the exterior of the canister.

The robot could very easily determine where, if any, scratches or where marks were

and what the depth were, or the depth was, each scratch that it found.

There was no reason to clean it.

- Another question, can you tell us what the target date to resume loading is?

- No, we actually can't speak to that.

That will be a decision made by Southern California Edison.

And as I mentioned, it depends on several factors including the need to do training and qualified personnel as well as equipment checks.

So we have no projected timeline for that at this point.

- Thank you.

According to a number given by-according to a number given at the predecisional enforcement conference, canisters one through four have an estimated 51 broken bolts and shims between them, or shim standoffs, has the NRC determined that these canisters are safe?

- Yes, so the four canisters in question relating to the shim standoff was an issue that has been identified by the licensee to the NRC, and that has been, went through-the Division of Spent

Fuel Management reviewed, because it's a generic concern.

It's not just Southern California Edison's canisters that were affected.

They did provide analysis to our Division of Spent Fuel Management that they did review, and those canisters are safe for storage, and there's no issues with them continuing to be stored at Southern California Edison.

- I have another question about the thickness of the canister walls, or a comment, rather.

The lack of concern about what a leak out of these thin canisters would mean to containment is still evident by the nonchalant answers provided.

Thick-walled canisters should be provided for public safety.

- That's a comment?

- That's a comment, not a question, but we do want to respect those comments and make sure that your comments are brought to attention.

What ASME pressure vessel in service code was used to determine that less than 10% gouging is acceptable?

- That value comes from Section III of the ASME Boiler and

Pressure Vessel Code.

- Thank you.

A question I asked earlier, that you did answer, was about whether the NRC determined that a root cause from our root cause analysis determined that gouging of the walls was caused by the contractor's lack of precision canister downloading system; a follow-on question to that is, what was the root cause that was derived from that root cause analysis?

- The root cause was more than just looking into the design.

It was looking at the training, the corrective action program, the procedures, and what led to the two individuals being out on the pad that disabled the important-to-safety slings.

So it really looked at the root cause.

And the root cause was basically that the management had failed to recognize the implications of a long storage campaign operation where usually they're a lot shorter unless they're unloading the whole pool to pad, and all the new influx of new individuals,

the training, the procedures.

So it really combined a bunch of contributing causes.

- Thank you.

We still have time for some more questions.

Again, we would like the focus of this question and comment to be about our decision to allow the resumption of fuel transfer operations.

Here we have one, another question.

Does the NRC agree that the scratches heal over time?

- On stainless steel There is, it's called, re-, re-,

I can't think of the word.

Cast, bind, or something.

Yes, I don't know if they necessarily heal.

But I have heard of that term.

I don't know if I definitely believe that.

- I believe that's terminology that has been used by Southern California Edison at various public meetings.

- Thank you.

We have a question about the licensee, how are public safety concerns being addressed given that Edison has discontinued the alert system?

- The alert system, if it's the notification system required under Emergency Preparedness Programs, is something that needs to be active while the facility is in operation.

Once they decommission and they are no longer operating, that system can be eliminated under exemption authorized by the NRC.

- Thank you.

Our next question from the public:

the NRC has claimed that the cans are compliant with ASME code but they are not ASME certified.

Can you explain the difference?

Can you explain why not?

- Sure, I'll take that and Lee can supplement if he chooses to.

These canisters under 10 CFR Part 72, they are not required to be fully ASME certified because they are not a true pressure vessel.

However, the ASME code is recognized as an acceptable method of demonstrating certain design features.

And for the technical specifications associated with this Certificate of Compliance,

Holtec International did refer to certain sections of the ASME Code.

- Thank you.

What monitoring mechanism is being provided on the storage canisters?

And what schedule to guarantee that no leaks are about to occur?

- Do you want to take that?

- Well the licensee does have radiation protection, TLDs or monitoring systems, set up around their owner controlled barrier and around the ISFSI that would monitor for any type of release.

On the system itself there's temperature monitoring and they also inspect the vents to ensure that they're open on a daily basis.

So if any kind of rise in temperature above a certain degree, they would go out and look at the canister and verify everything's acceptable.

- Thank you.

How was the Final Safety Analysis Report able to be revised regarding possibility of an acceptability of scratches without approval from the NRC?

- Under the 72.48 process, the licensee

is allowed to make design changes to their systems.

They have a set of questions to go through that's listed in the regs that they must answer, and that if they do pass, then they can make that change.

Only when they do not pass those questions would they have to submit it to the NRC for review and approval.

And the scratches did pass all those questions.

- Thank you.

We have a follow-up to our question from before about the alert system at San Onofre.

It's a follow-up:

Given the near accident being discussed today, is it possible that the NRC can require the licensee to restart the alert system?

- We generally would not do that.

And I don't know who posed the question, but we've stated in several public meetings that even if the canister would have dropped into the storage vault, its integrity would have been maintained and there would have been no release of radioactive materials.

- Thank you.

Could you describe your coordination with SCE and the Community Engagement Panel regarding presenting at the CEP meeting?

Please advise the names of persons from the NRC that communicate with SCE and the Community Engagement Panel.

Who from the licensee has communicated with the NRC about the same issue?

- Could you repeat That question please?

- I think they want the names of individuals from the NRC and from the licensee that were in communication in preparing for the Community Engagement Panel.

- I generally serve as the primary communication point between the Community Engagement Panel, and that's independent from my contacts with Southern California Edison.

I'm also one of the primary contacts for the regional office, at least for inspection oversight activities, with Southern California Edison managers.

- Thank you.

We have a question about, again about ASME compliance.

What about internal pressure

buildup from hydrogen off gassing from damaged fuel.

Would that not make the fuel canister a pressure vessel?

- The canisters are drained of all water, down to vacuum levels, and then back-filled with helium.

So there is no hydrogen generation in here because there's no water to be separated to make hydrogen.

Helium's a noble gas.

It's not going to divide on its own.

So there would be no risk of hydrogen buildup inside the canister.

So once they're back filled with helium to a certain value it's going to stay that value until it's eventually opened to remove the canisters, or the fuel.

- Next question is, if monitoring shows that a breach has happened, how would you transport the breached canister, to which location and structure, to prevent further leaks from the damaged canister and then what would be the ultimate fate if there were a breach of the canister?

- At the present time there's no anticipated breaching of canisters.

They're stable, they're designed

to remain in dry storage for many, many years.

If a canister, if something happened to a canister, the licensee would have to come up with a plan.

Generally we believe they would probably use an overpack of the canister.

- Thank you.

We have a couple questions along the same lines.

The commenter says: my understanding is that there is at least a liter of water in each canister; can the expert prove his claim?

And again, a second question, are you saying there is no water in the canister?

- Yeah, they're vacuumed down to very low levels, and at the system used at Southern California Edison they used forced helium dehydration to remove all water from the system.

So there is no, there is no water in these systems, definitely not a liter of water, really none.

- Thank you.

Looking at long-term storage, a question from the public is,

would you say that these canisters can safely store nuclear waste at its current site for over 50 years or over 100 years?

- The Certificates of Compliance are being renewed for a period of 40 years.

So the 50-year period, yes it is likely.

They are designed to be able to be both stored in the dry fuel storage system as well as transported to a final storage site.

- We have a follow-up about the names of people and the nature of coordination with the licensee regarding the Community Engagement Panel:

please answer the question as to whom you communicate with to coordinate your appearance and presentation.

Who from Southern California Edison?

Who from the CEP?

- When we're invited to attend a Community Engagement Panel meeting, it's Dr. David Victor, the chair of the panel, who typically extends the invitation.

I am not sure who Southern California Edison communicates, who they designate for

communicating with the CEP is.

I cannot speak for them.

- And a follow-up to the question before that.

Over 50 years of storage you'd say wouldn't exactly be safe, is the question from the public.

(inaudible)

- That was not the statement.

We said that there is ample evidence that it would be safe in 50 years and beyond.

The canisters are not only designed to be maintained safely in the dry fuel storage system, but they are also designed for transportation to a final repository or an interim repository site.

- Yeah, I'll add onto that.

There's many systems that have gone beyond their 20 years, and they've gone and done these inspections on these canisters and they're not seeing any issues of corrosion or deformation to the canisters.

And they're easily again renewed for another 40-year licensing period.

- The questions have slowed down a little bit coming in.

We want to remind everybody we have about 10, 15 minutes remaining here.

We do want to focus on questions and comments that you might have about our decision to allow the resuming of fuel transfer operations at SONGS, at San Onofre.

Given the public health risks at stake, and given that the NRC is the regulating body, don't you feel that to simply say that you don't anticipate something to a canister, without a backup plan, is a sufficient answer?

The canisters are scratched, on a seismic fault line, and in a tsunami zone.

That is a-that's more of a comment than a question, but we do want to voice those so that they are part of the record.

- (inaudible)

(inaudible)

- We have another request for additional-for elaboration from the public.

The commenter says, I question your saying that the canisters are transportable as is, please cite your sources that ascertain that the present canisters with

overpack are transportable.

- Yeah, these licenses, Holtec has a Part 71 license for them to be transportable.

So that's why they're called the multi-purpose canister.

They're both for storage and transportation.

So there is an NRC approved transportation license for these canisters.

I used to know the docket number, but I'd have to go to my computer to find it.

- That's good.

- Another question, do you anticipate that the NRC will be frequently monitoring the remaining spent fuel transfer to the dry cask storage?

- Yes, I do expect to do that.

I mentioned in my discussion that we anticipate conducting frequent inspections, on the order of several times a calendar quarter in order to observe ongoing activities since it'll be an ongoing continuous fuel loading, offloading campaign, sorry.

- I'd like to point out that

the transportation package has a name and it's called the HI-STAR system.

And that's Holtec's transportation overpack.

- Seems like the pace of questions has slowed down quite a bit.

We want to give a last opportunity for the attendees who are viewing the webinar to add a few last questions and comments.

We're about 10 minutes from the scheduled end of our discussion.

All right, we have another comment.

That there is no plan for breached canisters, as in a backup plan if a canister were to breach, is extremely concerning and inadequate.

The thin-walled canisters do not have a very long lifetime.

Your resistance to use better canisters can only be explained by not wanting to pay the higher cost.

Is the public not important to you?

I think we can call that a comment, as opposed to a question, but that is for the record.

Oh and we have a request from the public, would the lady please restate her name?

I missed it at first.

- Yes, I'm Linda Howell.

I'm the Acting Director of the Region IV Division of Nuclear Materials Safety.

- With that I think we're ready to end the-oh we have a couple more comments coming in.

Getting that indication.

The NRC approved license for transport, what is its name?

Semi One and then there's a question mark.

Looking for the name that we use for that license.

- It's called the HI-STAR system.

is what Holtec's name for it is.

Has a Part 71 docket number, which is its license.

I don't know if it has a name other than that.

- Actually it's another Certificate of Compliance that's issued for transportation package, and I'm sure that if the questioner wanted to find more information on that, you could probably go to the NRC public webpage and actually just do a search on ours, using the name of the package and you should be able to locate information on it.

- All right, and with that we're going to bring a close

to the public questions and comments period.

Linda if you have any, Linda or Lee, if you have any closing remarks.

- Sure, thank you, Austin.

Again, I thank the audience for participating this afternoon.

We think it's an important part of our mission is to be transparent and keep you informed.

The video and transcript from this webinar will be posted to the NRC Spotlight page under the San Onofre Cask Loading issue portion of the page along with other documents that are relevant to the event and our follow-up activities.

We will be producing an inspection report on those follow-on inspection activities that I mentioned during my discussion.

That is probably a few weeks away.

We will continue to post inspection reports on the Spotlight page for San Onofre, when we do the future, as of yet to be determined, resumption of fuel transfer operations, so that we can keep you informed.

And with that, we'll conclude the meeting.

Thank you.