ML19057A256

Predecisional Enforcement Conference Transcript from January 24, 2019

ML19057A256
Person / Time
Site:	San Onofre
Issue date:	02/25/2019
From:	NRC Region 4
To:
A. Roberts
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Download: ML19057A256 (179)

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WEBINAR TRANSCRIPT This document provides the transcript from a predecisional enforcement conference (PEC) webinar that was held on January 24, 2019, between the Nuclear Regulatory Commission (NRC) and representatives of the licensee, Southern California Edison (SCE). This meeting was held to discuss preliminary findings of a Special Inspection that the NRC conducted at San Onofre Nuclear Generating Station in September 2018. The inspection was conducted in response to an incident that resulted in the misalignment of a multi-purpose canister loaded with spent fuel at the San Onofre Nuclear Generating Station.

NRC

Participants:

Scott Morris, Regional Administrator Region IV Ryan Alexander, Facilitator and Senior Projects Engineer Reactor Projects Branch A Division of Reactor Projects Region IV Lee Brookhart, Senior ISFSI Inspector Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Region IV Michele Burgess, Senior Regional Coordinator Office of Nuclear Material Safety and Safeguards David Cylkowski, Regional Counsel Region IV Linda Howell, Deputy Director Division of Nuclear Materials Safety Region IV Dr. Janine Katanic, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Region IV Thomas Marenchin, Enforcement Specialist Enforcement Branch Office of Enforcement

Patricia Silva, Chief Inspection and Operations Branch Division of Spent Fuel Management Eric Simpson, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Region IV Chris Smith, Reactor Inspector Engineering Branch 1 Division of Reactor Safety Region IV Michael Vasquez, Team Leader Allegations Coordination and Enforcement Staff Region IV Licensee

Participants:

Stefan Anton, Vice President of Engineering Holtec International Al Bates, Manager Regulatory Affairs and Nuclear Oversight Southern California Edison Doug Bauder, Vice President of Decommissioning and Chief Nuclear Officer Southern California Edison Lou Bosch, Plant Manager Southern California Edison Chuck Bullard Engineering Holtec International Derek Brice, Attorney Southern California Edison Mark Morgan Regulatory Affairs Southern California Edison Tom Palmisano, Vice President of External Engagement Southern California Edison

Jim Peattie, Manager Corrective Action Program and Decommissioning Oversight Tom Poindexter, Attorney Morgan-Lewis Jerry Stephenson, Manager ISFSI Engineering Southern California Edison

- [Scott] All right, good afternoon.

I'm Scott Morris, Regional Administrator NRC Region IV Office here in Arlington Texas.

This afternoon, we will conduct a public predecisional enforcement conference between the NRC and Southern California Edison concerning activities at the San Onofre Nuclear Generating Station.

During this conference, we will discuss two apparent violations of NRC requirements that we are evaluating under the NRC's enforcement policy.

Before I go any further, I'd like to ask the NRC staff to introduce themselves, then give Southern California Edison an opportunity to introduce your representatives.

So, with that, Michael.

- [Michael] Good afternoon, I'm Michael Vasquez.

I'm the Team Leader for the Allegation Coordination and Enforcement Staff.

- I'm Dr. Janine Katanic and I'm the Chief of the, can't even remember anymore, Fuel Cycle and Decommissioning Branch.

- [Linda] And I'm Linda

Howell, I'm the Deputy Division Director for the Division of Nuclear Materials Safety.

- [Eric] Eric Simpson, I was the lead inspector for the special inspection at the San Onofre Nuclear Generating Station.

- [David] I'm David Cylkowski, Regional Council for NRC.

- [Chris] I'm Chris Smith, I'm a Reactor Inspector in the Division of Reactor Safety.

- [Lee] I'm Lee Brookhart, I'm the dry cask storage inspector here at Region 4.

Okay and on the phone, we also have some NRC staff as well. We have Patty Silva, she's the branch chief in NMSS, Division of Spent Fuel Management, we also have Thomas Marenchin, he's a Enforcement Coordinator in the NRC's Office of Enforcement back at Headquarters, we also have Michelle Burgess, who is an Enforcement Coordinator in the Office of Nuclear Materials Safety and Safeguards, again at Headquarters so I'll now turn the table over to you, Mr. Bauder, and introduce your reps.

Thank you, we appreciate the opportunity to be here this afternoon, so thank you for that.

- [Doug] I'm Doug Bauder the Vice President of Decommissioning, and Chief Nuclear Officer for San Onofre.

We have Tom Palmisano, our Vice President of External Engagement, Al Bates, Manager of Regulatory Affairs & Oversight, Jerry Stevenson, our Manager of Engineering, Jim Peattie, General Manager of Oversight and Lou Bosch our Shutdown Plant Manager.

Once again, we appreciate the opportunity so thank you.

- [Scott] Ah before we move forward, just a couple of logistical things just to inform you all, and maybe you know this already, but for the visitors here today, we have facilities down the hall, restroom facilities, drinking fountains et cetera, just out this door and down.

To the left, also in the event of emergency,

we will stay together, we'll all exit through the main entrance unless that's blocked and there's a side exit as well but we would gather out in the parking lot and do a count up before we're allowed to reenter the building.

Also logistics, let me ask everybody to silence their cellphones, and let's see, for those of you who are having sidebar conversations or those in the audience, please keep your voices down to a minimum because this session is being recorded, and so just to increase the fidelity of the recording we want to keep the voices and background noise down to a minimum.

Lastly, please be mindful that this predecisional enforcement conference is being broadcast again to a wider audience, via webinar, I think we have on the order of about 400 folks who have registered.

I don't know how many

exactly are online right now but we may get more joining us as we proceed.

So if members of the public or licensee staff present here, oh also if anybody needs to take a break, please, because it's being recorded, please do so via the rear of the room, you can see that the Skype camera's right there so we want to minimize the amount of traffic walking back and forth in front of the camera.

Okay, so this is a category NRC, Category 1 meeting between the NRC staff and Southern California Edison.

It is open to public observation but not to public participation. The NRC staff will be available after the business portion of this conference has concluded to answer questions from members of the public and to receive comments concerning the

matters discussed during the conference.

Including those participants who are observing this conference via the webinar.

They can submit their questions through the webinar application, all right, so I think we can go to the next slide.

So to those of you who are participating via webinar, welcome. In the event that we encounter any technical difficulties with the webinar we do have a backup conference telephone line, it will be available, it's not active now but if the webinar has a problem we'll activate it at the number you can see and the passcode that is on that slide.

Also note that the link to the NRC Spotlight page, that's our homepage, the NRC homepage, where you can locate a copy of the NRC inspection report that's really at issue today, that describes the apparent violations that

we will be discussing.

And a reminder to all conference participants, please state your name before speaking.

Just for the benefit of the audience, it will also help with the transcribed version of this that we'll also be posting on our website in the coming weeks.

So I want to just emphasize that we, that the fact that we're conducting this conference today does not mean that we've made a final decision, or determination that the violations occurred or that any enforcement action will be taken.

The conference however is, an important step in our well established deliberative process.

The main purpose of this conference is to provide Southern California Edison an opportunity to share with us any additional information you all think we need before we make, to make an informed

enforcement decision, however again, no decisions will be reached or discussed during this conference.

So I strongly encourage all of you to be candid, provide your perspectives on the apparent violations or any other related issues, their safety significance, the circumstances surrounding the apparent violations, corrective actions you've taken or have planned or any other information you believe has a bearing on our final enforcement decision.

We get the next slide.

So the agenda you'll see here, copies of the agenda have been made available to the participants as part of our slide presentations, I think we have some in the back of the room as well so, I'm shortly going to turn over to Linda and Linda will further discuss some details about the purpose of this conference.

Afterwards I'll give you, Southern California Edison, an opportunity to make any opening remarks if you have any, and after those opening remarks I'll ask Michael Vasquez, the lead for our Allegations and Enforcement staff here in Region IV to provide a high level overview of the NRC's enforcement policy and our process, and then Dr Katanic will discuss the two apparent violations that are at issue today in a little more detail, and then we'll turn the conference over to Southern California Edison to provide your input and perspectives.

I note that, just note that near the end of the conference, business portion of the conference, there is an item listed as NRC Caucus.

That's really just an opportunity to take a short break probably 10, 15 minutes. It will give all of us here, NRC staff and

those who are participating by phone an opportunity to caucus in a separate conference room to discuss what we heard and make sure that we don't have any further questions or clarifying information that we're looking for.

I don't anticipate that caucus will, like I said, last 10 or 15 minutes at the most, we'll come back.

If we have an additional question or two we'll ask it, otherwise we'll end the conference, okay?

Okay I think that is about it, so let me just turn it over to Linda.

- [Ryan] Sorry to interrupt, we were getting some feedback about not getting enough sound from the microphones so folks please make sure that you use your microphones.

- [Scott] All right, thanks for that, Ryan.

- [Linda] Thank you.

Good afternoon, I'm Linda Howell, the Deputy Director of the Division of Nuclear Material Safety in Region IV, and since we have the conference open for public observation I'm going to repeat just a little bit of background concerning the two apparent violations that are the subject of the conference.

Those two apparent violations were described in the NRC's inspection report issued on November 28th, 2018.

That report documented the findings and observations resulting from the special inspection that was initiated in early September 2018.

The inspection was conducted to review circumstances associated with an incident that occurred on August 3rd, 2018, at the San Onofre Nuclear Generating Station.

On that day, during placement of a loaded spent fuel canister into its intended storage vault, licensee staff and

contractors failed to notice the canister was misaligned and not being loaded directly into the storage vault.

In addition to the two apparent violations which Dr Katanic will discuss shortly, other violations of lesser safety significance were identified and documented in a Notice of Violation that was issued with the inspection report.

The purpose of the conference today is to discuss the two apparent violations.

As Scott noted, there are apparent safety significance and corrective actions that have taken at the plant.

We do not plan to discuss the violations, identified in the Notice of Violations in today's conference.

The inspection report and other relevant information is available on the NRC public webpage in the Spotlight portion as Scott just mentioned.

I also want to note that the purpose of the conference

today is to share information that will be sufficient for the NRC to make an informed enforcement decision.

The purpose of the conference is not for us to make any conclusions or draw any conclusions on whether Southern California Edison's ready to resume fuel loading operations.

That decision will be made following further inspection efforts by the NRC.

The predecisional enforcement conference is being broadcast by webinar to members of the public to directly observe and listen to information presented by both the NRC and Southern California Edison.

While the conference, again, is not open for public participation, we will prove an opportunity for members of the public to ask questions of the NRC staff who are present here today concerning

the enforcement process and the next steps forward.

Members of the public who are observing the conference via the webinar can submit questions via the question box throughout the course of the conference. NRC staff will be monitoring the webinar application to collect your questions and will attempt to respond to as many of the questions as possible within the timeframe allotted this afternoon with our priority on questions that directly relate to the NRC's enforcement and decision making process.

We'll try to address this as we go.

I just want to note, only the NRC staff will participate in the public portion of the meeting after we conclude the predecisional enforcement conference.

We'll excuse Southern California Edison staff so that it's really the NRC addressing the public comments.

Presentations that are

being used in the conference have already been posted to the NRC public web page as we noted. Those presentations and other documents associated with the conference that might be received following the conference will also be made available in the NRC's Agency-wide Document and Access Management System, or ADAMS.

The video and transcript from the conference will be also posted to the Spotlight section of the webpage, and in addition we'll post the comments and questions that we receive from members of the public to the Spotlight portion of the web page.

I want to note that the transcript and the other comments and questions will take a few weeks to be posted since we have to receive the transcript from the contractor who is providing the webinar service and review both the

transcript and the questions to ensure accuracy of the information.

For the Licensee representatives, let me just remind you, I know you might probably be aware of this, should you provide us any additional information shortly after the conference that you believe is sensitive and you would like withheld from the public you must provide us with justification for doing that in writing in accordance with NRC regulations.

So were there any questions on how we plan to proceed with the conference?

Thank you.

So let me turn the discussion over to Southern California Edison now to provide any opening remarks that they might have.

- [Doug] Well thank you, once again, this is Doug Bauder, the Vice President of Decommissioning and-Thank you.

Once again, this is Doug Bauder, the Vice President of Decommissioning

and Chief Nuclear Officer for San Onofre.

I want to again appreciate the opportunity to be here today and provide our analysis about the August 3rd downloading event and what followed, to give our safety perspective and to discuss our corrective actions as well and so we really appreciate the dialogue and are thankful to be here, appreciate it.

- [Linda] Thank you Doug. We'll now turn the conference over to Michael Vasquez to discuss our enforcement process.

- [Michael] Good afternoon, my name is Michael Vasquez, again I'm the Team Leader for the Allegation and Coordination and Enforcement staff.

There are a couple of things I want to know to start off with, like Linda said before about, no final decision will be made today.

The NRC has not made any final decisions yet on whether the apparent violations actually occurred.

This conference is the last

step in our information gathering in order to make an informed enforcement decision.

We provided Southern California Edison with an inspection report and that is what really provides our understanding of the apparent violations and the circumstances, and this conference is your opportunity to provide your perspective on the apparent violations.

So during this conference, we'd like to hear your perspective on whether violations occurred, the circumstances surrounding the identification of the apparent violations, and any corrective actions you have taken or plan to take.

This is your opportunity to give us any information that you believe that we should take into account when making our enforcement decisions.

Next slide please.

If the NRC concludes a violation has occurred

then the NRC will assess the significance of that violation and we use severity levels, and in order to classify the significance of violations. There are four severity levels with Severity Level I being the most significant, and Severity Level IV being the least.

Severity Levels I, II, and III are considered escalated enforcement and are candidates for monetary civil penalties.

We take four factors into consideration when determining the severity level of the violation.

First we look at whether there were any actual consequences. Second we look at whether there were any potential consequences, third we look at the potential for impacting the NRC's ability to perform its regulatory function, and four, we consider

any aspects of willfulness associated with the violation.

Now, if we determine that a violation was categorized as a Severity Level I, II, or III, it is a candidate for, they are candidates for civil monetary penalties.

So the NRC's civil penalty assessment process appears in the NRC Enforcement Policy in this diagram but let me simplify it for you.

First, the NRC considers the enforcement history and the severity level of the violation.

Second, we may consider the circumstances surrounding identification of the violation, and that is whether the licensee is deserving of identification for that.

And third, we are always going to look at a licensee's corrective actions, whether they were sufficiently prompt and comprehensive to prevent that violation from recurring in the future.

And forth, we may consider discretion, what we term as an exercise of discretion to either increase or decrease the size of a civil penalty based on factors described in the NRC Enforcement Policy.

So, during this conference, we really want to hear your position on how the issues were identified, and corrective actions you've taken and plan to take.

Although each case is different, there are three possible outcomes on the civil penalty assessment process. First, there may be, if the licensee identifies and corrects a violation, there may be no civil penalty. Second, if a licensee corrects, or, but doesn't identify a violation, that could end up with a base civil penalty. And third, if the licensee does not identify and does not correct a violation it could end up with twice

the base civil penalty and for this case, an independent spent fuel storage installation, the base civil penalties range from $36,250 for a Severity Level III violation, to $72,500 for a Severity Level I violation.

After the conference we're going to have our enforcement decisions to make, and there are four possible outcomes for our enforcement decisions.

First, the NRC may decide to take no enforcement action if you've demonstrated that no violations occurred. Second, the NRC can issue a Notice of Violation, this is a written notice documenting that a violation has occurred and requires a written response documenting corrective action.

Third, the NRC can issue a Notice of Violation with a civil penalty. The intention of the fine is to emphasize compliance in a way that prevents

future violations and that focuses the licensee's attention on significant violations.

Fourth, the NRC can issue an order which is a written directive that can modify, suspend, or revoke a license and an order can require specific corrective actions be taken.

The NRC's enforcement actions we take are publicly available on the NRC website.

After this conference it may take us four to eight weeks to publish the enforcement decision.

If a civil penalty or an order is issued, normally our Office of Public Affairs will also issue a press release on that day or the day after.

And last, licensees, NRC licensees have appeal rights and may challenge NRC enforcement action.

The instructions for challenging an enforcement action will be discussed in the action itself when coming in.

Next slide.

Any questions on this overview

of the enforcement policy?

Thank you.

Back to Linda.

- [Linda] Okay, well I'll turn the discussion next over to Dr Katanic who will provide some details concerning the apparent violations.

- [Janine] Okay, I'm Doctor Janine Katanic, and I'm the Chief of the Fuel Cycle and Decommissioning Branch, Mr Eric Simpson who was the Lead Inspector for the Special Inspection who works with me in this branch.

I'd like to go over the two apparent violations and I will note for our audience that the apparent violations described in the slides are in abbreviated or summarized version just for ease of presentation.

I will, however, verbally provide the full text of the apparent violations, which can be found in the handout. As previously noted, the apparent violations are subject to further

review and may be revised.

On slide 10, just to give a very high level overview before I read the text of the apparent violation, this apparent violation is related to the August 3rd, 2018 incident when a loaded spent fuel canister was being lowered into the vault and the canister was misaligned and was not being supported by the redundant, important-to-safety, drop protection features which in this case were the slings.

Apparent Violation One, to read the text of it, 10 CFR 72.212(b)(3) requires, in part, that each cask used by the general licensee conforms to the terms, conditions, and specifications of a Certificate of Compliance listed in 10 CFR 72.214. 10 CFR 72.214 includes a list of all the approved spent fuel storage casks that can be utilized under the conditions specified

in a specific Certificate of Compliance.

This includes Amendment 2 of Certificate of Compliance 072-01040. That Certificate of Compliance, Amendment 2, Condition 4, heavy loads requirements requires that lifting operations outside of the structures governed by 10 CFR Part 50, must be in accordance with Technical Specifications, Appendix A, Section 5.2. Technical Specifications Appendix A Section 5.2.c.3 requires that the transfer cask when loaded with spent fuel may be lifted and carried at any height during multi-purpose canister transfer operations provided the lifting equipment is designed with the redundant drop protection features which prevent uncontrolled lowering of the load.

Contrary to the above, on August 3rd, 2018, the licensee failed to ensure

that the redundant drop protection features were available to prevent uncontrolled lowering of the load.

Specifically, the licensee inadvertently disabled the redundant important-to-safety downloading slings while lowering canister 29 into the storage vault.

During the approximately 45 minute timeframe, the canister rested on a shield ring, unsupported by the redundant downloading slings at approximately 17 to 18 feet above the fully seated position.

This failure to maintain redundant drop protection placed canister 29 in an unanalyzed condition because the postulated drop of a loaded spent fuel canister is not analyzed in the Final Safety Analysis Report.

- [Ryan] Janine, I apologize.

We're getting major feedback that folks are not able to hear so we're going to

take just a one minute pause if we can, we're going to move the mic just one second, hold on.

Please try to move your microphones to the best of your ability, close to your mouth.

- [Man] Sorry folks.

- [Janine] Thank you.

If there are no questions regarding Apparent Violation 1, I'll move on to Apparent Violation 2.

Are there any?

- [Doug] No questions, thank you.

- [Janine] All right on slide 11, regarding Apparent Violation 2, again, just to give a high level overview before I read the apparent violation, the apparent violation involved timely notification to the NRC of the disabling of important to safety equipment. The incident occurred on Friday, August 3rd, 2018, and on the afternoon of Monday, August 6th, 2018, you provided a courtesy notification of the incident to our office, in

fact, to myself and others.

Following this courtesy notification the NRC discussed the reporting requirement with Southern California Edison during subsequent conversations. On September 14th, 2018, at the prompting of the Special Inspection Team, the condition was formally reported by Southern California Edison to the NRC Headquarters Operations Center.

Apparent Violation 2, 10 CFR 72.75(d)(1) requires in part that each licensee shall notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the following events involving spent fuel in which important to safety equipment is disabled or fails to function as designed when: one, the equipment is required by regulation, licensed condition or Certificate of Compliance to be available and operable to mitigate the consequences

of an accident and two, no redundant equipment was available and operable to perform the required safety function. Contrary to the above, from August 6th to September 14th, 2018, the licensee failed to notify the NRC after discovery of important to safety equipment being disabled and failing to function as designed when required by the Certificate of Compliance to provide redundant drop protection features to prevent and mitigate the consequences of the drop accident and no redundant equipment was available and operable to perform the required safety function.

And if there are no questions about Apparent Violation 2, I'll turn it back over to Linda.

- [Linda] Thank you Janine.

We'll turn the discussion over to Southern California Edison so that you can provide your presentation, but

first in advance of that, to the extent possible I want to recommend that the NRC staff holds their questions until the conclusion of Southern California Edison's presentation to give them an opportunity to complete the full presentation.

There will be ample time for the NRC staff to ask questions at the conclusion of Southern California Edison's presentation, so let me go ahead and turn it over to you, Doug.

- [Doug] Thank you.

So for our presentation if you could just go right to slide three where the agenda is listed.

Today, we intend to talk about both potential violations, the August 3rd download event, a description of the event, its safety significance, what our causal analysis has shown us and then our corrective actions.

And then we move into

Reportability where we talk about the timeline, the causal analysis and once again, corrective actions associated with reportability.

We also have a segment on regulatory considerations, then we'll conclude, so that's the basic structure for that, if you could move to the next slide please.

The next slide.

So the incident on August 3rd, when the redundant safety functions of our lifting system were not maintained, is a serious matter which should not have been allowed to happen.

We accept the proposed violations of regulatory requirements. Next slide.

So immediately following the event, we placed the affected canister as you know in a safe condition and suspended our Fuel Transfer Operations.

We've analyzed the incident and developed corrective actions with the utmost rigor, depth,

and thoroughness. We've also used top industry experts to verify our conclusions and actions.

Further, we know now with full confidence, that in the unlikely event of a load drop on August 3rd, the canister would not have been breached, and there would not have been any radiological hazard for our employees or to members of the public.

Next slide.

There were, however, significant organizational and programmatic lessons learned.

We've established comprehensive and rigorous criteria prior to restarting our Fuel Transfer Operations.

Those include: demonstration of effective corrective actions and equipment operations to the NRC, multiple independent reviews, full satisfaction by Edison that our actions are complete and they are sustainable and then

planned post-restart actions to ensure further sustainability.

Next slide please.

You'll see this slide later on in our presentation when Jim Peattie talks to it, we've provided our corrective actions, I just want to cover a couple of highlights here.

In procedures, we took a hard look at error traps, worker usability, and we put a lot of effort into making our procedures more usable for our workers.

In training, we strengthened the entire training process for San Onofre, this includes new training materials.

And we took a look at training with the perspective that ensuring that when a new worker shows up at the station, that worker is fully trained before being able to take a spot in fuel transfer operations.

With regard to equipment, we installed load monitoring devices and those

devices have proved to be very effective. This week on Tuesday, I spent time in the field watching the load monitoring in action during an actual simulated canister download.

I am pleased with that process.

In corrective actions, we took a broad look at the program and expanded it such that we now have one corrective action database for all workers, whether they are contract workers or Edison workers, and we've encouraged lowering the threshold for workers to enter issues into the corrective actions system. Moving on to Oversight.

Simply put here, we've overhauled our oversight process, we've put new leaders in place, we looked at the organizational structure of Oversight.

That structure includes instead of filling out checklists, active coaching,and monitoring the work in the field. Also

in the area of Oversight, my managers are now in the field, more often under a structured program observing and coaching for performance.

Once again, we'll talk in more detail later on today about these specific areas.

I would like now to turn the presentation over to Lou Bosch, our Shutdown Plant Manager, for the description of the event. Lou.

- [Lou] Okay. Thank you Doug.

Next to that.

Okay, so what happened?

On August 3rd, 2018, as a loaded multi-purpose canister was being downloaded into the storage vault, it became lodged on the shield ring.

For less than an hour, the MPC remained lodged and was not suspended by the rigging.

So what is the significance of this?

Although unlikely, the canister could have fallen 18 feet to the bottom of the cavity enclosure container.

Two, the canisters have

been analyzed to be able to withstand drops of up to 25 feet with substantial margin of safety.

And three, during the event, there was no radiological risk to employees or the public.

However, this is still an unacceptable incident and Edison takes it very seriously.

Can you hear me?

So now, next slide, we're going to go to a canister download evolution, before we start, I want to take the time to walk through an animation of a canister download.

This will help in our discussion to ensure there is a clear understanding of a normal canister download, what exactly happened on the August 3rd event and what should have happened on the August 3rd event.

So start the video please.

Stop there.

So I'm going to point out the different components.

So, we're looking right here on the orange,

this is the vertical cask transporter.

The transporter is basically a mobile crane, and it's different than a normal crane in that it doesn't have a spool with a cable, instead it has rising hydraulic towers with fixed length slings.

One end of the slings is mounted to a fixed position on the tower, and the other end is on the load.

Exactly.

The next we're pointing to is the transfer cask itself.

The transfer cask is a lead shielded cask that houses the canister, its function is to provide shielding during the transport operation.

In the cutaway view, we're looking at the actual canister.

Holtec calls this MPC.

This is a five-faced stainless steel container housing 37 fuel assemblies, welded shut and back-filled with helium.

On top, is a shield cone.

The shield cone lowers the dose to our employees working on the downloading of the canister.

At the bottom, is the mating device.

The mating device, you can look at that as the doorway into the cavity enclosure container.

The cavity enclosure container which is below that, houses the canister during long-term storage of spent nuclear fuel.

Okay, continue the video.

Now the transporter is moving up to the mating device, the transfer cask will be lowered.

And we'll stop there.

The transfer cask is now bolted to the mating device, when we continue the video, you'll see the transfer cask lift links removed, the transfer towers move up and the canister rigging slings that attach to the top of the canister.

So continue.

So these are the lift links that got removed, the towers are now moving up to the top and you'll see the slings connected.

Stop there.

So now, the canister's being

suspended by the rigging slings. The crew will then remove the transfer cask lower lid, and opening the mating device door.

The canister is now ready to be lowered into the cavity enclosure container.

I will now describe the make up of the crew.

There is two people out on the MPC pad during the event. One is the actual operator, in the location and two is a spotter that is up there.

And the spotter, the roles of the spotter is to visually verify the canister continues to lower throughout the download operation and stop the transfer operation during any abnormalities.

The transport operator is in communication with the spotter and also is watching his tower heights and stops during any abnormal indications so To reiterate the operator's looking at tower heights and load then the actual person

up in the man basket watches, makes sure the sling continues in a downward direction.

So now I'm going to go through the three evolutions.

What does a normal download look like, what happened on the event, and what should have happened on the event.

So the way the transfer operates on normal, they lower the canister and the slings follow right down with it so this is very simple, the beam comes down, the canister goes down and it goes to the bottom and they're done.

So, what happened? In August.

About four feet down there is a shield ring down in the cavity enclosure container that I will show you.

The canister got hung up, the people did not recognize the canister got hung up, as a matter of fact the slings at this point started piling up

at this location both here, and at that location.

Once the crew recognized that the canister was in an abnormal condition they contacted a cask loading supervisor and they actually raised it back up, put it back onto the load and it safely loaded down to the bottom.

So, what should have happened?

What should have happened is, at that four foot point when it got hung up, the spotter should have operated in radio communication with the operator should have stopped.

Very simply they would have stopped the evolution, they would have put the MPC back under load, and they would have raised it up and then lowered it down.

Continue the presentation.

So they pull the mating device door out, and, stop right there.

So, right here is the area of concern where we had the shield rings, where it got hung up.

So basically, the canister was sitting here and it was on the shield ring, resting at the inner side of the transfer cask.

And then, like we talked about, they actually raised it back up and lowered it back down.

So, to finish this slide we're just going to finish the presentation, so we're just demonstrating the normal canister downloads to the very bottom and that's the final spot in the storage vault where the cask will be loaded.

I do want to mention here at the end that Jim Peattie will be presenting in his video all the improvements that we have made to the download process.

Next slide.

This kind of goes back through and explains the actual hang up. So then here is the canister which we described, here is the transfer cask on the back, this is the shield ring where it got hung up,

and this is where it was bonded to the shield ring and resting on the inside of the transfer cask.

Next slide.

As Jerry stated, I'm turning over to him for the safety significance.

- [Jerry] Good afternoon.

Good afternoon, I'm Jerry Stephenson, I'm SONGS Engineering Manager and I'll be talking about the safety significance.

I'll start with a photo of the-next slide.

Photo of the cavity enclosure container.

This assembly, the entire assembly is the cavity enclosure container.

The shield ring is marked on the slide, it goes 360 degrees around, and gets welded to the divider shell. The wall that you see there is the divider shell. The divider shell is part of the cavity enclosure container.

The shield ring is there to reduce dose to workers during the fuel transfer operation.

It's designed to be a tight fit, to be an effective shield.

It's two inches thick, and securely welded to the cavity enclosure container and reinforced with eight gussets. You can see the eight gussets there, you can see some gussets on the top.

Thank you.

The canister's carefully inserted through the shield ring, but in this case it became lodged on top of the ring.

The shield ring and the welds to the divider shell have been analyzed to be fully capable of supporting the loaded canister. We'll talk more about the shield ring and the divider shell in upcoming slides. Next slide.

Okay the actual consequences.

In this event the canister did not drop, there was no significant damage to the canister, and no damage to the fuel.

The discussions on the following slides will address what might have happened if the canister had fallen.

So what did actually happen, what the actual

consequences that occurred on August 3rd, are, with the canister resting on the shield ring, the canister was exposed to a potential drop of 18 feet.

That's because the shield ring is 18 feet above the bottom of the cavity enclosure container.

Later we'll talk about our analysis which is done at 25 feet, but the actual level of the shield ring is 18 feet.

The contact with the shield ring when it was lowered may have caused minor scratches that were evaluated to be acceptable. We'll monitor the external condition of the canister for our Inspection and Maintenance Program which will be implemented in 2020.

Next slides.

So, what was the probability of a canister drop on that day?

When the canister was lowered onto the shield ring, because of the small

contact area, the ductile stainless steel of the baseplate formed around the shield ring and the gusset and they molded against each other. Because of the weight and the small contact area, there's local conformance and the two items took each other's shape.

Once they're pushed together, formed together, a significant force would be required to dislodge them, such as a seismic event.

The canister was supported by the shield ring for less than an hour and we know from probabilistic work that we've done over the years, that the probability of a seismic event during a one hour period at SONGS is very low.

Next slide.

Okay, as I've been saying, in this event, the canister did not drop, there was no significant damage to the canister, and no damage to the fuel.

However, we did a SONGS specific analysis of what would have happened if the canister had fallen from the shield ring.

We used very conservative assumptions, and the damage to the canister would have been less than what we calculated.

We postulated a drop that was much more severe than what the canister was actually exposed to, we did a deterministic analysis with the following inputs.

We analyzed a fall height of 25 feet.

The actual fall that it was exposed to was only 18 feet from the shield ring.

We analyzed a wall thickness of a half inch, it's actually five eights inch, 25 percent thicker.

We assumed no friction all the way to the bottom of the CEC impacted with maximum energy.

We assumed an infinitely rigid bottom, actually the bottom of the cavity enclosure container would have absorbed some energy,

we assumed all the energy was available to affect the canister. We used a conservative strain limit,

.55 inches per inch, and we used the method of evaluation approved by the NRC and a computer code LS-DYNA.

Next slide.

So the calculated maximum strain was well below the conservative calculational limit of .55 inches per inch.

The external shape of the canister would be unchanged, the calculations show us that the canister will not breach.

The calculational results have a lot of margin in them and they have reviewed by Holtec, SCE, and third party experts.

So with no breach, there can be no release of radioactive material. This was a very conservative, deterministic analysis using NRC approved methodology.

We now know, with full confidence based on this thorough and conservative

analysis that even in the unlikely event that a load drop had occurred, there would not have been any breach of the canister and therefore no release of any radioactive material or change in the radiation dose rates associated with the dry cask storage system.

This system does not, therefore, present any significant additional radiological risk to our workforce or to the general public.

Next slide.

We have evaluated that there would be some fuel damage if the canister had fallen.

Our conservative analysis has shown that while there would have been some damage to the fuel, there would be no material impact to the safety considerations of cooling, or criticality.

There would be no release of radioactive material, and there would be no change in local or offsite dose rates.

Next slide.

The canister cooling would not

have been significantly more affected if there had been a load drop.

The internal cooling is dependent on geometry and to a lesser extent helium flow through the fuel bundles.

The helium inventory would be unaffected since the canister does not breach.

The helium flow through the fuel would be mostly unaffected, and conductive heat transfer, which occurs by the metallic components and the surrounding helium is unaffected.

External cooling is by air flow down the outside of the divider shell and then back up past the canister.

Clearance between the canister and the divider shell is large, six inches radially and 12 inches diametric.

Any slight deformation in the exterior dimensions of the canister would not affect flow past the canister. Our conservative analysis shows that the canister will remain cooled.

Next slide.

In summary, the possibility of a canister drop during the 53 minutes that it was on the shield ring was very low. Even if the canister had dropped, we have shown with very conservative assumptions that the canister would not breach.

Without a breach, there would have been no release of radioactive material, there would have been no impact to the cooling of the canister.

There would have been no change in local offsite dose rates, the canister would have remained cool and safe in a cavity enclosure container.

We've performed thorough and conservative analysis that shows that there was no significant radiological risk to our workforce or to the general public.

Thank you.

Now I'll introduce Jim Peattie.

- [Jim] Good afternoon, my name's Jim Peattie,

I am the General Manager for Decommissioning Oversight.

So in response to the August 3rd incident, two cause evaluations were performed to identify the causes and the corrective actions to prevent recurrence.

We utilized third party cause evaluation experts, and industry peers to assist us in the development and review of the cause evaluations and the corrective actions.

We performed a root cause evaluation focused on why the fuel transfer download team failed to recognize the unload condition and stop the download activities.

We also performed an apparent cause evaluation, in order to understand why management expectations were not met for oversight.

These expectations included:

thorough review and acceptance of contractors' programs and procedures, ensuring that the procedures and process are

adhered to by the contractors, and that we stop work if compliance or safety issues are identified.

Next slide please.

Our root cause evaluation concluded that we failed to recognize the complexity and risk associated with a long duration fuel transfer campaign while using a relatively new system design.

SONGS project is a long duration campaign and is projected to transfer more than 70 canisters of fuel from wet to dry storage. This is different from a typical fuel transfer campaign which might move five to ten canisters using a stable crew of personnel with high levels of experience.

Next slide please.

Our root cause evaluation also identified five contributing causes.

These include, number one, a design review process that did not capture the

unintended consequences of the design addition of the shield ring.

Resulted in tighter clearances during downloading and the potential for hang up.

Number two, inadequate content and procedures to recognize the special conditions related to the new shield ring.

Number three, the training program did not consider the uniqueness of the shield ring addition, nor did it consider the challenges of a long-term project.

Four, there was a lack of a continuous learning environment promoting the use of both internal and operating, and external operating experience.

Number five, the chain of command communication methods in place during the canister download were not well defined, within the procedures or training.

Our apparent cause evaluation was focused on why SCE management expectations

were not met for Oversight.

This evaluation identified one cause, and two contributing causes.

Our identified apparent cause was that we failed to establish a rigorous oversight process to ensure that we had in place technically accurate contractor procedures and effective training to support our oversight of the contractor, and sufficient guidance for Oversight personnel on when to intervene.

The two contributing causes linked to the event include, management observations of fuel transfer operation activities were not being routinely performed, and management was not consistently reinforcing the use of our Corrective Action Program.

This slide provides an overview of where our corrective actions are focused from the root and apparent cause evaluations.

It's also intended to provide an overview of how all of these areas combine to provide for what we consider to be an industry leading dry fuel transfer program.

Starting on the left, there's five areas: our procedures, in Procedures we've added a significant amount of detail for our operating and oversight procedures.

In Training we've completely restructured our training program and made it specific to SONGS.

As we've mentioned in the Equipment, we've added several new enhancements, including load monitoring shackles and use of the cameras.

Our Corrective Action Program, we've mandated the use of a single corrective action program for fuel transfer operations and we've retrained those personnel on low threshold issue identification.

And in Oversight, we now have more robust

procedures and training to provide more intrusive and effective oversight. I'd like to go into more detail in each section.

First section is Procedures.

We've made a significant number of improvements in the operating procedures for the fuel transfer project.

Prior to the event, the procedures used for the project were not robust, these procedures lacked detail and relied upon experienced supervisors to make the decisions in the field. As such, they lacked detail, and they failed to identify critical steps for higher risk activities. So what's changed?

The corrective actions that were put in place were focused on ensuring that the procedures align with the requirements of the Final Safety Analysis Reports and other regulatory documents.

They identify critical steps, they list required qualifications of workers.

They define responsibilities, they clearly identify criteria for stopping work, they incorporate lessons learned and operating experience.

And they minimize steps that allow for field decision making.

All six of the operating procedures listed have been evaluated by Holtec, SCE, and independent industry experts and in addition, these procedures have also been updated with the lessons learned from our recent training and practice activities.

Our Oversight procedures have also been greatly enhanced.

Our procedure that defines how we review and accept a contractor's procedures and training programs was revised, it now includes verifying the procedures meet the requirements of appropriate regulations and procedures identify required training and qualifications.

And in addition, we've

revised procedures describing how our Oversight personnel are to perform their effective oversight of fuel transfer work.

I'd like to talk about training next.

Next slide.

So our corrective actions for training were primarily focused on developing our own site-specific training program for the project.

So as training was an essential element of the successful execution of the project our vision was to develop a training program that is industry leading and encompasses all fuel transfer project personnel.

Prior to the event the training was conducted under the contractor's program.

It was a generic corporate program, and a program focused on the training of the supervisors and some specialty contract positions such as a vertical cask transporter operator. The craft personnel were provided very

limited training and they were under the direction of qualified supervisors.

We've accomplished our vision by bringing in multiple training experts familiar with the systems approach to training.

There was collaboration between us and the contractor to produce a new SONGS specific training program and procedure.

The new program now covers 20 fuel transfer project positions. It includes 21 lesson plans, and seven on the job training modules.

Some of the key changes that were made are that every individual is required to complete all the required training elements for their position prior to performing work independently.

Operating procedures include all required training qualifications within the procedure.

On the SCE Oversight side, we've enhanced our training program, which

should improve our technical knowledge, we now require our Oversight personnel to attend and pass the contractors classroom training as part of their Oversight qualification.

In addition we've added a training subject matter expert to our Oversight organization to assess and monitor the effectiveness of the changes we've made in training going forward.

I'd like to talk about some of the equipment changes.

Next slide.

So one of the most beneficial corrective actions we took was to install load monitoring shackles for canister downloading and uploading.

It was an important equipment enhancement.

Later in the presentation as Lou mentioned, there is a short video and I'll be able to point out some of those equipment features.

During and prior to the August 3rd event, the involved personnel relied on visual indication

of slack in the load handling slings as the primary method of identifying a hang up or interference.

The vertical cask transporter controls include the ability to observe the canister's weight and monitor load. However, on the event of the day of August 3rd, the operator had switched the indicator to monitor tower height, and that was due to a concern about maintaining the tower's level.

The use of the load indicator on the controls was not required by procedure, and the operator and rigger in charge failed to properly monitor the load.

Our newly installed load monitoring shackles are calibrated, there are two redundant portable load monitors in use at all times, they are utilized by the transporter operator and the supervisor in charge.

The monitors include an

underload alarm feature which is set by procedure to alarm an underload of 15,000 pounds which is essentially 50 percent of a fully loaded canister weight.

If a loss of load is identified on the monitor, or if the alarm is received, the operator would stop the download and immediately regain 100 percent of the load weight.

The load monitoring shackles have been installed and verified functional during recent practices of the download activity and management has been in the field observing their use.

The additional features also included the use of a camera. The camera is installed above the transfer cask and the canister and it's in a position such that the supervisor has the ability to remotely observe the canister download in progress

similar to the rigger.

Finally, we've added a physical tag-line as a method of ensuring the canister is lowering.

This tag-line is attached to the canister and it is maintained by a rigger who is in position right next to the operator such that he can detect movement of the canister in a downward position through the physical use of the tag-line.

The next area is Corrective Action Program.

The most noteworthy action we've taken in the area of Corrective Action Programs or commonly referred to as CAP, is that we have integrated the contractor program into the use of our site program into one.

We now allow the use of only one corrective action program for all issues for fuel transfer work.

SCE's program is the primary program for identifying the problems or issues for performing any fuel

transfer work activity.

Previously there were two Corrective Action Programs.

Holtec was authorized to use their program, we took their issues, we would transfer them to our program for monitoring, that's no longer the case.

We've implemented the use of our corrective action changes in December.

We've provided training to both the Holtec staff, their craft personnel and the SCE oversight personnel.

Training was conducted to reinforce the low threshold for the identification of entries into the Corrective Action Program.

We've provided examples of the impact of poor Corrective Action Program use in the training, and this included the failure to identify the unexpected difficulties that were experienced on July 22nd as a missed opportunity which should have been entered into the CAP.

The next area I'd like to talk about is Oversight.

Next slide.

So as the Management Owner for Oversight for the fuel transfer project I have overall responsibility in this area. So for background information, prior to the event, the oversight of the fuel transfer project was not sufficiently intrusive.

Oversight personnel did not participate in Holtec training.

Technical understanding of the work was learned on the job, expectations and guidance on how and when to intervene in the contractors' work were not focused on immediately addressing performance weaknesses.

As discussed earlier, one of the Oversight corrective actions was to proceduralize how we review and accept the contractor's procedures and training program to ensure that there is adequate and consistent review.

We utilized this criteria when we reviewed and accepted the new program procedure changes.

We've changed our organizational structure to improve our experience by placing a manager with extensive onsite dry fuel project experience in charge of Oversight personnel supporting the work.

We've hired several new Oversight specialists with field experience in performing fuel transfer operation activities. Another recent action taken by SONGS is that we've implemented a new senior management observation program.

We've identified 20 specific managers that are in the program with four scheduled each week to conduct field observations of fuel transfer activities.

All these observations are entered into our Corrective Action Program to be evaluated and tracked.

All these observations are

required to be debriefed with other site leaders during daily work meetings.

And lastly, I've met with my Oversight personnel.

And I've clearly defined what my expectations are going forward, on how we engage not only with the fuel transfer contractor, but all personnel on our site and the expectations are number one, ensure that work is being performed safely.

Ensure that work is being performed in compliance with the procedures or work instructions.

Perform coaching on the spot, stopping the work if necessary to restore compliance, escalate issues to the senior management personnel, and to utilize the Corrective Action Program to identify all observed issues.

Next slide please.

This slide through slide 48 are provided as

a line-of-sight matrix identifying the causes to the corrective actions for both the root cause and apparent cause and corrective actions necessary to support fuel transfer operations.

The slides were submitted for the record but it was not my intent to go through each slide.

- [Man] So we are on slide 49?

48. Okay.

- [Jim] So slide 48.

What you'll see is a short video of a recent download practice activity utilizing a simulated canister which does not contain fuel.

The things you'll see in the video are the additional personnel involved in downloading, load monitoring equipment, the camera, the tag-line, and the headset communications that personnel are utilizing.

I'll periodically stop and point out some of the details.

So we can proceed please, and stop.

So in this spot of the video, you can see first off, there's the aerial lift.

In the aerial lift there are now two personnel, both of them are qualified riggers.

One of the individuals is the Rigger in Charge.

He is the one who directs the VCT operator on whether he can proceed or not proceed.

All right, all other personnel involved can direct the operator to stop, but only the Rigger in Charge can direct the operator to continue.

On the right hand side, that is the Cask Loading Supervisor in Oversight.

The Cask Loading Supervisor has with him, an additional load monitoring tablet such that he can see what the operator is seeing as far as load weight, and he can also see what the camera sees where the riggers are at.

Right above the canister is a camera that's mounted directly above the high truck, or the high track where the transfer canister and the canister, the MPC,

such that you can observe the download of the canister.

Individuals located on the bottom, many are spotters for the movement of the vertical cask transporter.

One of the issues that resulted from this event was that the canister wasn't centered before they lowered it, such that they allowed it to catch, right, it didn't hang up.

The new procedure changes require the individuals up top to center as best as possible, the spotters down at the bottom ensure that the operator has the ability to understand whether or not the transporter can impact anything.

So they're there for the transporter operator's good.

There are RP techs located in the locations on the pad to observe from the radiological control perspective.

And go ahead and proceed.

- [Scott] Hey Jim, just for the benefit-

- [Jim] Stop please.

- [Scott] Just for the benefit of those listening, RP tech.

- [Jim] Oh I'm sorry, RP Tech would be a radiological protection technician responsible for radiological controls.

In this slide you can see that the canister is still in the up position, the rigging is attached and you'll see the two riggers in the aerial lift. In that lower right hand corner of the tower is the location, or excuse me, lower left hand corner of the tower is where the operator and the rigger would be located.

And please proceed, and stop please.

This is a practice activity.

The individual sitting in front of the control panel is the Vertical Cask Transport Operator. Directly behind him to the right is an Oversight Specialist.

To his left, is a rigger and an additional

operator who is in training that day watching the activity.

The Rigger that's standing there without the headsets is the one who would maintain control of the tag-line such that he can direct the operator to stop if in fact the tag-line is not moving.

And please proceed.

And stop please.

As you can see here, the canister is now on its way in the download, you no longer can see the shield cone above the transfer cask. The two Riggers are watching the download activity, the procedure now requires, that at a certain fixed height which is 216 inches, all downloading will stop, that is a location above the shield ring.

That's to refocus all personnel on the download operation that we are now entering the interference point and to be very sensitive to any unusual condition.

Go ahead and proceed please.

Stop please.

What you see in front of the Transporter Operator is the load readout screen.

It's a wireless tablet that directly reads both load cells and the overall total weight.

And as I mentioned, it also has a alarm that will flash from green, normal condition to red, if in fact it detects the underload condition.

Please proceed.

This is the downloading continuing.

You can see the slings, you can see the tower lowering.

Riggers continuing to monitor and stop please.

This is the camera that I mentioned that's installed.

It's physically installed onto the VCT and provides the remote indication.

So please continue.

And stop please.

I mentioned the monitor for the camera.

This is what that monitor looks like.

This is what the supervisor can observe.

In this monitor it's clear that the canister is

beyond the shield ring interference based upon how far down it is and you can observe that the slings are clearly visible going down. Please proceed.

Downloading continues and in this position the canister is fully in the down position.

Stop please.

This is the remote tablet that the Cask Loading Supervisor would have, so in his location he has similar indication to what the Operator is seeing on the machine.

On this tablet, as I mentioned, are both of the chapter read outs individually, the total weight read out, you can just make out that it's green there and in an underload condition everything would turn red to identify the underload.

Please proceed.

Alright, next slide please.

So in conclusion, so as a nuclear worker, with 37 years of experience at SONGS as an SCE

employee and now as a Manager for Oversight of the fuel transfer project I believe we demonstrated the right nuclear safety culture behaviors to address the August 3rd incident.

We placed the loaded canisters in a safe condition, we stopped all further fuel handling work and over the last five months we've developed thorough cause evaluations.

We've developed and implemented effective corrective actions by utilizing cause evaluation experts and industry peers for reviews.

In October we had an independent assessment team made up of nine nuclear industry leaders brought in to assess not only our corrective actions but our progress. Their action report in December concluded that with the completion of our remaining corrective actions, SONGS

has the tools and the organization to safely resume fuel transfer operations.

We are committed to ensuring that our corrective actions are sustainable, through effective reviews and the use of our Corrective Action Program.

We are also committed to ensuring that work is performed to high standards and to protecting the health and safety of the public and our personnel.

This concludes my discussion on the corrective actions, I'd like to turn it over to Lou.

Next slide, thank you.

- [Lou] Thank you Jim.

Okay so we're changing subjects now, we're going to reportability.

So the problem statement, on August 3rd, 2018 we had a rigging event that disabled an important safety load control function while no other support function was available.

We failed to formally report to the NRC within a

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, next slide.

This is the reporting timeline.

This slide shows the timeline of the August 3rd event which I'm not going to go through.

But we immediately suspended fuel movement at the time of the event and informed the NRC by phone at Region IV on August 6th.

We did not formally report to Headquarters but we had a narrow understanding of the regulations.

We are the licensee and we were wrong.

Next slide.

So, the root cause and contributing causes.

The root cause is management failed to recognize the transition to fuel transfer operations as requiring the integration, familiarization and application of the 10 CFR 72.75 reporting requirements into plant processes.

We had two contributing causes.

Contributing Cause 1 was we did not provide the shift managers with good guidance and training on

implementing the requirements of 72.75(d).

This resulted in a narrow understanding of the regulations which complicated the decision making process on August 3rd, and two, we were not consistent in ensuring management expectations where a conservative bias for reporting were understood.

The staff had different views on the requirements to report.

Next slide.

So under the extent of condition of the root cause:

For extent of condition we had a few issues entered in the Corrective Action Program since the beginning of fuel transfer operations.

We interviewed key SCE and Holtec personnel to identify any other reportability lapses, this review identified two additional issues that were required to be reported and this has to do with the HI-PORT and the HI-PORT is just the heavy hauler that travels from the spent fuel pool to

the ISFSI pad.

Two issues with the lateral clearance of fixed objects and the height of the center of gravity.

These issues were reported on December 20th, 2018 to the NRC and have been corrected.

Next slide.

The extent of cause.

For extent of cause, we looked broadly at reportability requirements associated with decommissioning activities.

We will enhance training to ensure that shift managers and staff have knowledge and guidance necessary to make timely decisions on reportability.

Additionally, as the Plant Manager I am personally involved as is our Chief Nuclear Officer in ensuring the site embraces a bias for reporting when there is not a clear consensus on reportability of the mission.

Next slide.

So immediate corrective actions.

We have trained the shift

managers and regulatory personnel on this event and the 10 CFR 72.75(d) notification requirements.

And we revised our procedures.

So we made two significant medium changes as a result of this event.

One, we now have a conference call if the shift manager has an issue, with the Senior Plant Manager, Ops Manager, Engineering Manager and NRA Manager.

And two, we're continuing a bias to report to the NRC whenever there is a question about the requirement to report. Next slide.

So planned corrective actions.

We're going to provide enhanced 10 CFR 72.75 training that includes a number of issues.

The design basis events, analytical limits, important to safety components and identifying potential failures.

We're also establishing biannual refresher training requirement for

reportability so that we ensure that we have sustainability.

Next slide.

So planned corrective actions continue, and the difference is the future corrective actions are more broad so it's going to be the planned corrective actions are reinforced, the shift manager is the person responsible for the final decision on reportability and two, create a reportability check off sheet to be used by the shift manager when needed for reportability calls.

And two, we're going to take a broad look at 72.75 requirements associated with other regulations, associated with extent of cause.

Next slide.

Under effectiveness review, after the required training is complete, SCE Shift Managers, Plant Manager, Operations Managers, NRA personnel and Engineering Manager will be given real

time reporting exercises once a month and success will be based on three consecutive months with no incorrect reportability calls.

Also, appoint a skeptic at reportability conference call meetings.

Next slide.

So this slide, through slide 69 are provided as a line-of-sight matrix for the cause/action correlations.

These are submitted for the record, but it is not my intent to discuss the details of each slide.

Please go to slide 68.

Okay, so conclusions.

We conducted a thorough root cause and developed effective corrective actions by using cause evaluation experts and independent peers for review.

We are committed to ensuring that our corrective actions are sustainable for effective reviews and use of our corrective action process.

We are committed to ensuring

work is performed to high standards protecting the health and safety of personnel and the public.

That concludes my area of reportability, I'm going to turn this over to Al Bates.

- [Al] Thanks Lou.

So I'd like to review the regulatory considerations for the two apparent violations now.

Slide 70 please, okay.

So, first of all, looking at the loss of redundant load protection apparent violation.

There were no actual safety consequences, no one was harmed, as you heard earlier in the presentation.

The vulnerability itself lasted for a short period of time, less than one hour, and then the canister was safely recovered and stored.

If the canister had dropped, as we had shown earlier in the presentation, the canister remains intact, there would have been no radiological release, and under a postulated canister drop, no harm to

the health and safety of the public.

However, putting a canister in a situation where it could have dropped is unacceptable and we have taken strong corrective action to never let that happen again.

We ask NRC to consider these factors in determining the final severity level. Next slide please.

So next the second apparent violation, reportability of the event.

Considerations include the impact on the ability of the NRC to perform its regulatory oversight functions and willfulness.

All downloading work was immediately stopped once MPC 29 was safely secured.

The NRC was notified informally and thoroughly briefed on the first and second working day after the event and there was no intention to hide, and this was not a willful act. The NRC have performed a special inspection as a result of

the event and have access to all the requested personnel and all the materials.

SCE maintained frequent and transparent correspondence and communication with the NRC following the event.

And the industry was notified shortly after the event.

We ask the NRC to consider these factors when determining the final severity level of this event and this violation.

So in terms of the overall regulatory considerations for the two violations.

So SONGS has had no violations in escalated enforcement in the last two years.

The redundant load drop protection violation was self-revealing. The reportability violation was NRC-identified and as explained earlier in the presentation, we have taken comprehensive robust corrective actions.

We believe in many

areas the corrective actions are industry needed.

When characterizing the two violations, SCE believes that the loss of redundant load protection and the reportability of violations could be considered a single problem with two examples.

Next slide.

In looking at the NRC's Enforcement Policy manual, we believe as I have said, that the violations represent two examples of single problems stemming from the same event and therefore both violations can be considered concurrently running through the full diagram together, not one after the other.

Looking at the diagram, the diamond shaped conditional block on the left asks the question, first willful Severity Level III in two years.

As I said, we have not had a Severity Level III violation in two years, and

neither of the violations was- (Inaudible) Non willful violations, sorry.

And then, so the answer was yes for both of these violations. The next diamond block we covered asks the question, credit for corrective actions.

As discussed earlier in the presentation, we believe we have shown for both violations, comprehensive, robust, sustainable corrective actions.

Therefore, full credit should be given for the corrective actions for both violations, and the question is answered, yes.

Now we'll turn it over to Doug for closing remarks.

- [Doug] Thank you Al.

So the San Onofre team today has brought a lot of details around the August 3rd downloading event, what we've done to improve, and further, how we have addressed our reportability knowledge processes.

In summary though, in conclusion, I would like to reinforce that SCE takes

the violations, and this incident, seriously. We have performed extensive cause evaluations and implemented timely, and what we think are effective, corrective actions.

We will be demonstrating the effectiveness of these corrective actions to the Nuclear Regulatory Commission during upcoming inspections.

The incident did not create nor have the potential to create a radiological hazard to the public or our employees.

So that's the end of our planned remarks for today, thank you for the opportunity and we'll move into the next section.

Thank you Scott.

- [Scott] Well thank you for your presentation, I know it was very helpful for me to understand the scope and depth of the corrective actions you've taken and the significance evaluations that you've performed,

clearly these are significant issues or we wouldn't be here today, a lot of elements to consider and clearly we rely on licensees to meet all of our requirements all the time, because we're not there all the time.

You own the license, so it's your overall responsibility to ensure the public health and safety.

So that's why these issues are serious and we're here today, so again, I think your presentation was very helpful to help us better understand the scope and breadth of your actions.

Nonetheless, as you might expect, I do have a few questions, I'm sure the staff here does as well. I'll just start if that's okay.

I was obviously taking notes while you were speaking.

Let's see, some of which you have subsequently answered in many of your slides so some of those are no longer applicable. You mentioned at one point

that the shield ring was analyzed and can carry the entire weight of the loaded canister.

And I guess, I mean that was demonstrated on August 3rd. I'm curious though, was that an analysis that was performed before, was that a later analysis, has our staff looked at that, have we seen that?

We have seen that, okay.

- [Linda] Yeah but I think it's still worthwhile Scott to maybe have Southern California Edison answer your first question whether that analysis was done at the time that the design was changed or subsequent to the August 3rd event.

- [Scott] Right.

- [Jerry] So subsequent to the August 3rd event we asked Holtec to do that analysis, so the analysis that I was referencing was afterwards to confirm it.

It doesn't mean that it wasn't part of the original

analysis.

- [Scott] I'm not sure what you mean by that last, the end.

- [Jerry] That would mean that you would have to direct that to Holtec.

- [Scott] Oh I see, I understand. Thank you.

And with respect to all the analysis that you did, Jerry, with respect to the significance evaluation, have those been provided, did we have those evaluations, have we seen those, do we have those evaluations or is that going to be part of our follow up inspections?

- [Man] As far as the shield ring is concerned?

- [Scott] All of them, the ones about the canister drop, the impact on the fuel cooling, all that kind of stuff.

- [Linda] I think some of us do have questions on those, and to clarify that for members of the public who may be listening, Southern California Edison has

provided several analyses following the August 3rd event to the NRC, many of them were completed by its contractor, Holtec, to the extent possible we asked Southern California Edison to redact some information so that the documents could be placed in a non-proprietary version in the NRC's public docket room, so, there are some, the drop analysis is available on the Spotlight page and in NRC's ADAMS, the electronic docket system, there is another analysis, there are a few analyses that we'll ask questions about this afternoon that remain proprietary.

- [Scott] Yeah, I mean I think that it's appropriate that we do some independent look at that, that's really my point. I wanted to make sure that we had an opportunity to see that, I didn't know if we had seen it, we all hadn't seen it yet or not, so.

You mentioned the changes to the Corrective Action Program and having a single program, combined program, and lowering the threshold, and providing training on how to use it, et cetera, one thing I didn't hear is, when the issues come in and are documented, I don't know what you call those documents, condition reports or whatever, but whatever you call it, how often do those get reviewed and by whom?

- [Jerry] Yeah so we use a system they're called action requests, we call it the AR system, all action requests are reviewed every business day by a screening committee, and the screening committee is leaders including the Operations Manager, Engineering Manager, Plant Manager typically, CAP Manager, so there's some core key individuals that must be there to have a quorum to review those and we also

invite Holtec personnel to sit in on that discussion so we have a clear understanding of the issues we've identified.

- [Scott] Thanks for that, so what decisions, what range of decisions might you make after having that screening review?

- [Jerry] So during that screening process we would look at the description of the issue itself, the grammatical understanding of what was observed, what the issue is, we would also look at the significance level of that issue, whether or not that issue is a CAP item such as a condition adverse to quality or condition adverse to regulatory compliance and then we would also assign the actual assignment to an individual as an owner and then in many cases we would escalate that also to a manager to own the overall issue.

- [Scott] Thank you. Do you have a-

- [Linda] Yeah I have a remaining question and you may want to elaborate a little bit more.

- [Scott] By the way Linda, we're not following our own rules which is that you identify yourself.

- [Linda] Thank you, I'm Linda Howell, the Deputy Division Director.

- [Scott] I'm guilty as well, so.

- [Linda] A clarifying question, if you could explain in a little more detail since we have some members who are observing the conference and don't have the benefit of having some of the information we've taken, how your current process, the enhancements that you have done to the Corrective Action Program which you hold high in the programmatic changes that you've made, differs today from how it was being conducted on August 3rd

and along with that, some specifics on how you ensure the field change report that might be implemented by a Holtec employee makes its way to an AR report and what's done with that and then I'll follow up with another question.

- [Jim] Okay, so Jim Peattie, I'm the General Manager of Decommissioning Oversight.

Previously I was the CAP Manager, so.

Prior to this change, Holtec was authorized to do their work in their Corrective Action Program.

They utilized a field condition report process.

What we did earlier in the project, based upon our previous issue, we decided that all field condition reports, upon their generation, would then be copied into our Corrective Action Program for tracking, not necessarily for assignment of our

actions but mostly to ensure that we understood the issue, the significance of the issue that was identified in the condition report and ensured that an order was assigned with Holtec that we would follow that.

The biggest change is the field condition report process in place could not be implemented at the craft level, the Holtec field condition report procedure process allowed it to be executed at the supervisor and project manager level.

All right, so a craft person on the project could not generate an FCR without going through management, going through supervision.

So that was fundamentally, what we considered a gap in how our process works.

So one of the biggest changes was, first off, recognizing that that procedure itself had some weaknesses overall. The

July 22nd event, within the definitions of procedure, would not clearly require them to generate that FCR and that was essentially the position taken whereas ours would say that was definitely an unexpected condition, we would have expected that to be generated.

So that was the first change.

The second piece to that was, Oversight also was aware of the issue previously of July 22nd, there were Oversight specialists who were aware of the issue but because they were reliant on Holtec to use their process, they didn't take it upon themselves to identify the issue within our station program, so that was also a gap.

- [Linda] If I could just ask you to clarify a couple of things on this Jim just for the benefit of the audience, if you could just very briefly,

a few sentences, remind everybody what the July 22nd event, I don't really know that it was an event, and then go ahead and go on.

- [Jim] On July 22nd we have documentation within our turnovers that there were unexpected conditions, issues that had to be dealt with during the download of a canister. During that canister download it took an extra hour, hour and a half to get the canister downloaded.

And in fact there is documented hang ups in the Cask Transport Operator during that evolution it observed a unloading condition. So they followed their procedure, they escalated it internally, they had notified their project manager, they got additional supervisors and ultimately within an hour and a half they were able to recover and lower that canister safely. What

didn't occur is that condition was never identified within either of the corrective action programs to be followed up.

So essentially, management in our case was unaware of that actual issue until we went backwards for root cause (inaudible).

- [Doug] And perhaps Linda, and Jim just for the benefit of the audience again, during the July 22nd incident the load was always supported, the slings were never what you would call slack sling conditions and that's different from the August 3rd event.

- [Jim] Yes.

- [Linda] Thanks for adding that, that was some of the additional feedback.

Maybe you could help us understand some of the specific actions that you may have taken to address the transition from going from two Corrective Action Programs or at least

documenting issues to a single program. You noted that the field change report process previously in use by Holtec, who is your contractor, had the potential for the craft workers who are really, you know, the majority of the people who are out there on the pad, doing canister downloading, to not have been able to raise issues up, so now that you've transitioned to a Southern California Edison Corrective Action Program what steps have you taken to ensure that the contractor has trained his craft people to ensure that the information gets to the right level of supervision so that you can ensure that it gets into your Corrective Action Program.

- [Jim] Right, so as the Corrective Action Program Manager I specifically had the existing Corrective Action Program revised, the training

material revised, that was number one. We then delivered that new material, including the recent lessons learned to both the Holtec personnel, all personnel including all the craft people personnel on site and I personally delivered that training, so essentially I was the one who presented the material, and I answered any questions.

So that was the primary.

The second thing is we took it upon ourselves to go put in computers in their actual craft briefing locations such that the craft personnel had access to the computers and those computers allow them to write an action request anonymously.

We were more interested in them writing the issue and putting it in the system than to have to log in and have to put in a name.

And we communicated that in the training, we want your input.

We've had numerous

action requests written.

Very low threshold, like the need for batteries for devices, very low threshold, so it appears that it's working. But along those lines, we're also weekly going out and reinforcing during those Holtec craft briefings what's occurred. What we've seen, what's been generated through the action request system and providing that feedback to individuals on what's being done about the issues that are raised and that's an ongoing action that I'm also tracking as a CAP action in my change management plan.

- [Linda] Okay. Thank you Jim, Linda Howell again.

- [Eric] This is Eric Simpson, I was the lead inspector for the special inspection out at SONGS.

You've mentioned the Corrective Action Program and how it is now, a single Corrective Action Program

that will encompass Southern California Edison with whatever contractor they are using, Sonic, Holtec, how do you communicate?

See, as an inspector, I know what a low threshold looks like and a Corrective Action Program has it, by reviewing the corrective actions that come in for a period of time, how do you train, how do you communicate to bring up low threshold incidents into the Corrective Action Program?

- [Jim] I think the primary means is you provide examples to them of what low threshold means.

And then secondary, we do observations so my Oversight personnel do observations, those observations are looking for low threshold CAP treated follow up. Right.

If they see issues in the field, right, where the craft people are generating

those, are those issues being generated during the observation process.

Additionally, SCE management is now in the field, so we're spending quite a bit of our time in the field, also following up with how CAP is being implemented and are our corrective actions or our action requests being generated at the right threshold.

So I would say that's to ensure that there's consistency going forward.

- [Eric] So essentially you're saying you also know it when you see it and you see improvement already in lowering the threshold, items being addressed into the Corrective Action Program.

- [Jim] Yes, that is correct.

- [Scott] I'm going to switch topics. I have a question about, this is Scott Morris, I have a question about the, in the process of downloading the canisters into the vaults, because of the shield ring, because of the

tight tolerances which you actively demonstrated today, there is a high likelihood of impacting the canister itself on the shield ring or other parts of the vault, which induces potential flaws, scratches, call them what you will, and I know there's been some evaluation done around the impact of those scratches long-term, short-term, long-term, and I know we've had some conversations, the NRC staff's had a number of conversations with Edison about that.

I guess, what my question is, so with that as sort of a preamble, my question is what, because of the propensity to induce scratching because of this design, to what extent have prevention measures been put in place to mitigate or otherwise prevent or minimize the frequency and/or significance of those scratches?

- [Jerry] Okay, so the

significance of those scratches, I'm sorry Jerry Stephenson, Engineering for SONGS.

The significance of the scratches has been evaluated in great detail.

We have not done anything to mitigate those scratches because they are so minor in the first place and there's no need or feasibility to reduce it further so we calculated that the depth of the scratches using very conservative analysis is the thickness of a couple of sheets of paper at the worst. We've documented their existence in the design, we've added them to the FSAR and addressed them in the 72.212, so they are now officially part of the design. Okay.

- [Scott] I just want to make sure I understand that question.

Or that response, this is Scott again.

You captured the occurrence of scratches on canisters as part of the design, it's like,

in other words, it's a given, it's going to happen based on the way canisters are manipulated and the evaluations found their significance in your words, not your words, my words, it's okay, and we've captured it in our design document.

Is that what you're-?

I'm just trying to make sure I've heard it correctly.

- [Jerry] We evaluate- I can say it's been very thoroughly evaluated, it's well below the size of the defect allowed by the ASME code, it's well within the manufacturing tolerances that Holtec uses in the shop for fabricating these canisters and it's been thoroughly documented and evaluated and will be of course monitored by our inspection and maintenance program, and (inaudible) aging management.

- [Tom] This is Tom from Oversight. You might have mentioned the improvements for the procedures and

the alignment of the canister to minimize the incidental contact on the download.

- [Jim] Right, as part of the- I'm sorry, this is Jim Peattie, General Manager of Decommissioning Oversight.

As part of the procedure review changes we recognize that the centering of the canister within the transfer cask was essentially a critical step prior to download, so there is additional steps that are captured within the procedure now, focused on ensuring that the canister is visually centered before you attempt to do any downloading of the canister so hence the presence of additional spotters and that actually takes us a little bit more time because we want to spend as much time as possible ensuring that a hang up doesn't occur through preventive measures by ensuring the canister is centered

before we download it.

- [Scott] So thanks for that, this is Scott again.

So that's done before the initial lowering or that's done when you get to the, I think you said the 216 inch or lower.

- [Jim] That's done before we do any lowering essentially as you open the mating device gate and it's free hanging, validate that it's centered, and at the 216 inch just above the shield ring, you evaluate again that it still appears centered before you continue downloading.

- [Scott] Did you have any follow up questions?

- [Linda] This is Linda, I do have a follow up question, and perhaps Jerry is the one to answer this. You mentioned that you've done extensive analysis and I think that analysis, are you referring to the scratch analysis, okay.

So, that analysis was done

based on the NRC's prompting following the August 3rd event, it's based on a slightly different technique than some of the other analyses and its largely based on engineering judgment but the question that we have because the information that was given to us by Southern California Edison employees, the Holtec contractors is that it was not uncommon.

And this is documented in our special inspection report for the canisters to come in contact with the CEC even when they were well aligned, something different from the August 3rd event, as they were being lowered to the CEC height.

What gives you confidence that the calculations that you've done in that scratch analysis are really and truly representative of the body of canisters that has already been downloaded. Have you done

any additional physical testing, or are there plans to do physical testing to ensure that those canisters and future canisters that you're going to download even with better central alignment are going to be within the manufacturing tolerances that are accepted and assessed as part of the COC design basis?

That is a long question, I apologize Jerry.

- [Jerry] Yeah so, the calculations that we did were very conservative, they were by established methods developed in the 1800s, it's not new evaluation techniques and we have high confidence that the numbers are very, very well-bounded by the design. We also-

- [Tom] Jerry- again this is Tom. Let me interject. So as Jerry is describing, we do the specific analysis that we've done (microphone fades out)

When we've looked at the downloading activities, the depth of scratching is very shallow, I think we've provided information that shows a protective oxide layer forms relatively quickly in that environment on one canister's surface.

And as Jerry noted, we are implementing an inspection maintenance program somewhat similar to a NRC aging program (inaudible) so we factor all this in to the need in future to look at some physical activities on scratching.

But that provides the basis for our confidence and certainly if the staff has more questions we'll be glad in the future to answer those questions for you.

- [Linda] Okay thank you Tom, it looks like you're prepared.

- [Doug] I'm just going to follow up and mention pretty much what Tom just mentioned regarding the issue.

We're looking at it, we fully expect as part of our inspection program which will be implemented before November 2020 to take a look at this and so I think as Jerry indicated, we're well-bounded, we have a good analysis, it's a conservative analysis yet we're still interested in it and so we still want to look at it and that will be part of our inspection program which, we indicated, prior to November 2020 but also taking into consideration the NRC's aging management program well in front of that.

- [Linda] Thanks for that addition Doug, we discussed preliminarily some of your plans in that area.

I'll leave with that, we may have additional questions concerning the scratch analysis, we have looked at it, it will be part of our continued inspection activity so we'll see if we have

additional questions here this afternoon but we'll probably be looking at it further.

- [Scott] This is Scott again, I've got one more question and then I'm going to yield.

The other question I had had to do with, I think it was on slide 54 where you're talking about extended condition of the reportability issue.

And specifically the first bullet on that slide, it talks about in the course of the extent of condition of the reportability issue, the two additional issues associated with HI-PORT were noted.

I assume you mean two additional issues associated with reportability or is it-

- [Jerry] Yes, yes.

- [Scott] Okay. And thank you, so, I'm not personally familiar with these other issues, are these lateral clearance of fixed objects, height of center of gravity, this is with the transfer vehicle, while moving the transfer cask.

- [Tom] That's correct.

- [Scott] I'm just trying to understand from a-what made those reportable?

And what, well only just answer, start with that.

- [Lou] Okay, so, during our review, this is Lou Bosch, I got that right.

So during our review of the reportablility, we looked at a lot of other issues out there.

One of them had to do with the actual physical movement of the HI-PORTs, the, this is the heavy hauler that goes from the spent fuel pool to the ISFSI, that it actually traveled too close, okay, to some of our fixed objects.

Okay, so then we reported that under the same regulation 72.75(d)(1), okay, and we sent that report to the NRC.

- [Scott] So, just to clarify, so what made that reportable because presumably something in your design or licensing basis

is specific to the lateral distance allowed during the movement of that cask?

I apologize, you know, I don't have all the details of your exact license.

- [Lou] So, it was, I'll just read it to you here, it says the HI-PORT lateral clearance between the transporter and other structures did not maintain in accordance with the procedure directions, it was less than the analyzed clearance limit, and because of that, the analyzed clearance limit, that's why it made it reportable because it failed its function.

- [Scott] So, I'm not going to go down this rabbit hole too far, but, so there's a body of questions around that issue and what was that about, how significant was that, and I presume our staff is working on those issues with you?

- [Linda] Yeah, I'll supplement that.

There are criteria in the COC that requires a specific vertical height off the ground, as well as the lateral distance away from a big structure and in doing the extent of condition, Southern California Edison made the staff at Region IV aware that those criteria may not have been met, and so that will be part of our future inspection activities prior to making a decision for resuming fuel loading operations because it is considered part of the-.

- [Scott] Okay, that's fine.

- [Al] Yeah and this Al Bates, Scott, to put that into context, that particular issue had been entered in our Corrective Action Program and then when we did the extent of condition, in other words applying our new criteria for our new threshold for reporting, we found this issue.

- [Scott] I see.

- [Man] And that's how it ended up in the, as we report.

- [Scott] And I don't want to get ahead of our inspectors but I would surmise there is probably, we've got a quite a few questions about that I would imagine so we'll, that'll be captured as part of our follow up, okay.

That's all the questions I have for now, let me defer to you Linda.

- [Linda] Okay, thank you, I'm just going to do a follow on here so maybe we can move past reporting issues.

In the Corrective Action Program when we have gone through the matrices that you provided as part of your presentation, I know we didn't talk about it, or you didn't talk about it in detail here this afternoon, but one of the questions that the staff has concerning the upgrades or revisions to the

Corrective Action Program relative to reportability, in your daily meetings that you have now expanded are you looking at those entries for reportability criteria as well? We want to understand the full extent that you're examining reportability.

- [Lou] This is Lou Bosch, so every morning we have a screening committee, and every AR that's written gets screened for significance and reportability, so every one of- every AR that gets written, I personally look at on a daily basis, I look at it and then we actually have a management team that actually looks at this and they screen it.

One of them is its significance, is it corrected, is it part of the CAP system, is it a condition adverse to regulatory quality and, we also look at reportability.

The shift manager every

day in real time looks at these for reportability, okay, so we're kind of a back up, the shift managers looking at it in real time.

- [Linda] Thanks Lou, I just wanted to make sure that you had the opportunity to get that on the record since that is part of your corrective actions for that apparent violation.

I'm going to turn this over to Janine in case she has any questions.

- [Janine] Sure, again, this is Janine Katanic.

And I did want to go back to the scratch analysis if you don't mind so you've discussed the enhancements that have been put in place, and Jim, you talked about making sure the canister was centered and the things you're doing in that regard.

So is it the position that there won't be scratches in the future, or given

those very tight tolerances of a quarter inch, are we just still accepting of yes, there will continue to be scratches going forward?

- [Jerry] This is Jerry Stephenson.

Yeah we put these scratches into the design as a potential, not that they are on every canister, we don't know if they're on every canister but there is the potential for scratches on every canister.

They've been evaluated, the same evaluation that we did applies to every canister.

- [Tom] This is Tom Palmisano, I would add that the way we look at this, the incidental contact, the potential we have for every download, some downloads we may not have any incidental contact but practically there would would be incidental contact as there are for many dry cask storage systems. So it's important to recognize that as Jerry said, any scratches that would occur are well within acceptable limits

and monitored in the inspection report.

- [Janine] Okay and then Tom again, this is Janine.

So all that that you've just stated again is based on a engineering judgment, it's just not based on actual inspections to confirm that judgment.

- [Scott] Listen I don't want answer for you but I will, I think what I heard, Janine, was the evaluations that they did were, there was a calculational methodology employed, and it's not just judgment.

That's what I heard, just, I'll give you an opportunity to -

- [Tom] I think this is something that warrants further discussion but it is an engineering evaluation. It estimates the worst case scratch we put it on canister 29 and found (inaudible) to be acceptable.

- [Scott] Okay.

- [Janine] I did have a question

in the area of Oversight.

I heard some of the numbers regarding how many Oversight personnel there were and some of the changes that have been made to the training for the Oversight personnel and just as a matter of function, will those Oversight personnel be present during the entire downloading ops or are they people that kind of come and spot check and leave.

- [Jim] This is Jim Peattie.

So the answer to your question is the procedure for downloading actually has the requirement for Oversight to be there.

That one procedure actually has repeated direction for Oversight to be there.

I would also tell you that not only downloading but other canister lifting activities that are medium-high risk, will have an oversight person there, 100 percent of the time for a pre-job brief

through to the end of the actual evolution.

- [Linda] Just a follow up question on that one.

This is Linda again, I didn't want to stop you during the presentation because I advised everybody not to do that but in the video for the changes that you have made to equipment and downloading, could you maybe elaborate, Jim, for the record, the true changes you talked about, more people in the aerial lift, you have more people at the VCT control panel, you now have, you know, greater ability to truly monitor the load but one of the things that we noticed back on the August 3rd incident is that the people who were supposed to be monitoring the downloading basically reduced people on the pad to two people and they weren't really monitoring the

things that we would have expected, and hence they didn't notice that the slings had gone slack.

So, what have you modified in the downloading procedure that ensures that the riggers that you've got positioned on the aerial lift will actually be able to view in addition to the camera since you have an expectation that they are part of your safety net, the canister being centered before you actually lower it down and that the supervisors will be able to actually observe what's going on in a little more closer fashion, I'll just turn it over to you Jim.

- [Jim] Yeah so if we go back to the August 3rd event as you mentioned, there was really only one person that had the ability to visually monitor the download activity, right, and that was the individual that was in the aerial lift.

That individual at that time was not a rigger, they were not qualified as a rigger, they were just a JLG Operator, an aerial lift operator, assigned the duties of a spotter.

So what's changed? The procedures been changed now such a they use a pre-scripted pre-job brief.

So all the details of lessons learned are all discussed through the pre-job brief as you go through each item. The procedure itself actually lists every required position to execute the download activity.

So it identifies the riggers, the Rigger in Charge, the VCT Operator, the Cask Loading Supervisor, the Oversight specialist, every single position is now described in the procedures required here, and they're actually acknowledged.

In addition we've put two personnel who are responsible to visually observe the canister physically

going down, so those two individuals are ideally in two aerial lifts but the procedure allows for them both to be in one single aerial lift to monitor, both doing the download observation.

In addition we have the camera.

The camera allows the supervisor to observe essentially what the rigger in the JLG is seeing.

Right? So now the supervisor can ask questions through the headset communication on what the individuals are doing, confirming that he sees what they see, when they say the canister is centered, and then lastly we put a physical tag-line also maintained by a rigger by procedure who understands that, I should expect to see the line move during different downloading activities.

So essentially we've increased from the single person operation to a six

person operation and in addition we've mandated Oversight presence there and I also mandated two Oversight person.

One person to directly engage with the CLS, or the Cask Loading Supervisor, and an additional Oversight person to stand back and be that third party observer overall of how the process is doing.

- [Linda] Thank you.

- [Janine] And Jim, this is Janine again.

I appreciate your discussion of all of the enhancements that were made, such as the camera, the load indicator, so those types of equipments and enhancements that have been made, if any of them were to fail during a downloading operation that the camera goes out, the load shackle fails, what would be the process, how would that be handled?

- [Jim] So in the procedure,

those events such as the loss of a load monitor occurs.

The procedure now drives the individuals to stop the work and go to the abnormal operations procedure and in that procedure it will detail exactly what you're supposed to go do, what are the steps.

And those steps would depend on where the position of the canister is in relation to the download.

If the canister is in the position above the shield ring and you lose load monitoring the safest position might be to put it back within the transfer cask and close it up. If it's within the shield ring on its way down, the safest position most likely would be to continue lowering with additional sensitivity to visually monitoring that.

But those are now all captured within the procedure and we've provided gap training last week to the downloading crews on the

transition between the two procedures.

Additionally during that training we utilized our Oversight personnel to participate in that training so there's a clear understanding between the cask loading supervisors and our Oversight personnel on how those procedures are to be executed.

- [Janine] Thanks Jim, I appreciate that.

Another thing I wanted to ask about was, and I was there as an observer during the special inspection but one of the documents that the Special Inspection Team had reviewed was the SCE Program for Abnormal Occurrences and how, you know, this August 3rd event just did not fit into that process so have there been changes made to that Abnormal Occurrence Procedure and, you know, have the experiences from the August 3rd event and the July 22nd incident, have those things been taken into consideration in updating that?

- [Jim] I'm going to have to get back to you

on that Janine, I'm not sure, are you asking about the reporting procedure in which case we review an event to determine how we report or an actual procedure that SCE has-

- [Janine] No there is a procedure for, and I think Tom or Al, you may know what I'm talking about, where there's a procedure that says, if a canister is damaged do X, but there were no criteria for entry into canister damage so in this case, you know, there could have been damage to the canister but that procedure was not entered to and so, has that procedure been enhanced as to what might constitute entry into that procedure?

- [Tom] I think Jim's right, what is (mic interference) we'll provide an answer after the break and if not we'll get back to you.

- [Scott] That's fine. That will be good.

- [Linda] Okay let me do just a few more questions and then we might be ready to caucus. You noted it and I appreciate, you know, your going through several of the analyses, under the safety significance portion of your presentation I think it was around slide 19, you did note that one of the analyses that you completed, although it indicated that there would be no breach of the canister, had a drop occurred on August 3rd that there may have been some fuel damage and hypothetically speaking, I mean, the canister was not dropped, I'm going to make that absolutely clear but hypothetically speaking, knowing what you know today and even with the improvements that you've made, are you looking at any contingency planning should that occur, you know, what you would do if a canister

inadvertently did drop during downloading operations?

- [Doug] This is Doug Bauder, so we would as the procedures would direct, would stop and place all equipment at a safe condition. Hypothetically, if the canister dropped.

However if that was to occur, as Jerry indicated there would be a potential for fuel damage inside the canister.

There would be no canister breach so no release of radioactivity, no threat to our employees or to the public and so since we know that, we know that's the case, after placing the equipment in a safe condition, we would have plenty of time to develop a strategy as it's such a low, such a long-term event for us that we would have plenty of time to back off, develop a strategy, engage the appropriate

vendors with specialty equipment, if needed, to address the next steps for the canister and you know, we know that the canister would also remain cool and there would be no criticality inside the canister, there is no moderator that would be introduced during an event like that because the canister stays sealed so, once again, the canister would be in a safe condition and it's a long-term issue for us to deal with at that point.

No threat to our employees or to the public.

- [Linda] Thank you Doug.

- [Scott] I think we're, what questions do we have that haven't been answered?

We're going to caucus very briefly we'll take a ten minute break, tops, and we'll be back here at 20 after the hour, and if we have a couple of extra questions we'll ask them otherwise we'll

go ahead and close up the meeting.

For those of you on the webinar, we're going to go silent for about ten minutes.

- [Linda] For NRC staff who are-

- [Scott] Okay, we're back.

As you might expect we do have a couple of follow up questions, I'm going to ask Chris Smith to go first.

- [Chris] Yeah, hi, I'm Chris Smith, I'm a Reactor Inspector from the Region IV office.

My question to SCE is, to perform the drop analysis for the MPC for a hypothetical drop, and we did review that but the question I had is, did that analysis address potential stress cracking or the ability to cause cracks?

I know that the conclusion was there was no immediate breach but was there any concern or analysis of the long-term crack propagation that would lead to a release, because the NRC study comes up with a non-zero probability of a release for a similar drop event.

- [Jerry] Okay Chris,

I'll answer the last part first, okay. The NRC analysis you're referring to is NUREG-1864?

- [Chris] Yes sir, that's correct.

- [Jerry] Okay that, the analysis in that document is for a different MPC, an MPC 68, with different internals that significantly increase the stresses.

So long-term, the first part of your question was the long-term potential for scratches.

We didn't- this is a long-term potential for cracks.

We analyzed ductile material and the strain rate, strain limits and concluded it wouldn't crack and being the type of material that it is, we wouldn't expect it to crack promptly.

I'll have to get back to you on maybe some longevity of the design after they drop.

- [Chris] Okay, thank you.

- [Scott] All right, this is Scott.

Janine, you had a question?

- [Janine] Sure. And again, this is Janine, and Jerry, this might be for you.

Again, going back to the scratch analysis,

and just recognizing that, our greater audience doesn't have the benefit of having reviewed or read that analysis as we have, can you comment on what was found as the worst case scratch, what width and depth would be the worst case scratch?

- [Jerry] Okay, so we postulated a worst case misalignment. Okay remember the transport canister cask that goes right in the canisters is very tight fit so you can't misalign much so we just took just a simple geometry and came up with the worst case misalignment and then resolved the forces involved and the maximum transverse force that you can come up with is about 2000 pounds, about two percent of the weight of the canister, okay?

With that small transverse

force, and using conservative assumptions on the depth of the scratch, conservative assumptions on the different inputs into the equation and I reviewed the paper that was produced and there is an engineering judgment, there's a few places where numbers have to be chosen with some engineering foresight and the numbers were chosen conservatively which is different than engineering judgment, choosing a conservative number and so using the inputs that were chosen conservatively, the maximum depth of the scratch with the two percent transverse load is about 10,000ths of an inch. Compare that, that's about as thick as two to three sheets of paper and I'll compare that for the layman to the acceptance criteria which is a sixteenth of an inch

or 62,000ths so the acceptance criteria for the manufacturing procedure and bounded by the ASME code is six times the maximum depth that we calculated in the paper.

I don't recall the width of it, I'll have to get back to you on the width but the length of it could be the full length of the canister.

- [Janine] Okay, and again, this is Janine and just given that, given the scratch analysis and maybe this is for someone else on the panel, I mean what is precluding Southern California Edison from actually examining the worst case canister that's out on the pad currently?

- [Tom] Yeah this is Tom Palmisano, as I said, this would be an input in consideration of the Inspection and Maintenance Program (inaudible) I think you're all familiar, the NRC's Aging Management Program is required at the 20 year point as

part of the license renewal.

For the Holtec system which was submitted to an inspection and maintenance program much earlier, this will be one of the inputs we consider. We see no need for any immediate inspection, we think it's more appropriate to factor this into the upcoming inspection program.

- [Doug] This is Doug Bauder, I also want to emphasize that in a prior statement that we made, indicated that we would be inspecting, I'll choose my words carefully here, we would be inspecting on or before November 2020, in fact our requirements are to have the program developed and ready in place prior to November 2020. So it's not a big difference but it's something we indicated earlier.

- [Scott] Thank you.

That's it.

I had a question, I want to take you to slide 24,

if we could pull that up. Basically this is a statement of your root cause evaluation, I'm sorry, your root cause for the first of the two apparent violations and, management failed to recognize the complexity and risks associated with the long-term, long duration fuel transfer campaign while using a relatively new system design. So, I think what I would like to focus on, really the question is, it wasn't- granted, a relatively new system design, right, the UMAX system and obviously your employment of that is new to you certainly. So my question is, if consistent with your root cause statement, if it's true that it's management failed to recognize the complexity and risks associated with using a relatively new system design, my question is, why? I mean it's a simple question but I'm trying to understand why?

If you have a new design then it's, you know, it's, well I don't want to go too much further than that because I don't want to sound overly pejorative, I'm just trying to understand, why is it, how is it you accept that as a root cause?

That's my question.

- [Jim] Yes, this is Jim Peattie.

The root cause of corrective action for that goes back to the Holtec design procedure, the design (inaudible) procedure and it really, of the corrective actions associated with having a second independent team looking at it from a site support services execution side of the design, more so than the engineering technical design itself.

So in the case of the shield ring, the shield ring was designed but that design wasn't reviewed or challenged by personnel that had to

go then execute the work utilizing that new design so the corrective action there associated with changing the design review process.

- [Scott] Okay I think I understand but it's-Okay, let me try to repeat back, so I make sure I have your answer, clear.

So the shield ring, the addition of the shield ring inside the walls was also new, it was an addition based on, there was some reasoning that was applied, presumably for dose reduction but that introduced additional challenges associated with tolerance, clearances and downloading and so what, are you saying that management failed to recognize that the addition of that shield ring introduced additional complexities associated with the downloading operations and all the manifestations of those complexities in terms of training and procedures and everything else?

Is that what you're saying?

I'm just trying to be clear.

- [Jim] This is Jim Peattie.

So the answer is yes, that's exactly what we're trying to say.

- [Tom] Scott this is Tom Palmisano, the addition of the shield ring is one factor, it's certainly feasible to download the canister successfully with the shield ring (inaudible).

The real issue in looking at some of this, looking at the extent of a 73 canister campaign and the turnover of people that is going to occur, I think Jim in his earlier comments laid out that when you're doing a five to ten canister campaign, you typically have one or two experienced crews that stay together during the course of the campaign, but we failed to really appreciate that you'd have of turnover of people (inaudible) experience and that's where the quality of the procedures and training and supervision, it

became apparent that we had underestimated the complexity from that standpoint.

- [Scott] So I'm going to play that back again so I understand it. So, the training, the presumption is, that the training, the procedures, the oversight, was all adequate before, assuming that it was a short duration campaign.

- [Tom] And assuming there was a certain ,say, prior experience level, and that, you know-

- [Scott] So the root cause statement, I'm sorry to cut you off Tom.

- [Tom] Yeah and when you've got a small group of people on a short campaign you don't have the turnover, your lessons learned are much easier to deal with, they have experience, they've learned the lessons. As you turn over people in the longer campaign that's where some of the weaknesses contributed to the event.

- [Scott] So, okay. So thank you for that.

So the root cause then is management failed to recognize that because of what you just said, because it was a long duration evolution, and because of that, there is turnover, the changing of the guard, so to speak, you know, experience that you might have had at the beginning was no longer there because of turnover, attrition, whatever, and management didn't recognize that that loss of experience, knowledge, skill, what-have-you, then that ultimately was why the quote-unquote, inadequate training, inadequate procedures revealed themselves.

- [Tom] Yeah so exactly, we had procedures and training that may have been adequate for the short campaign but not adequate for the longer campaign.

- [Scott] Did you have a follow up on that?

- [Linda] I did, that's a perfect segue,

this is Linda again. You've provided us with a lot of corrective actions here, I know it's not all encompassing, but the benefit of it lies in it gets you on the record, since this is an important element for both of the apparent violations you've identified management oversight as an issue.

And there's not a lot of specific corrective actions in your presentation that are directly related to that element and it is related to what Scott was just asking about, so bottom line question is, can you just review for us the corrective actions that directly relate to management oversight because this is not a Holtec activity, this is a Southern California Edison activity, so it's not sufficient to just say, we didn't recognize that they weren't minding the store,

its all of you sitting at the table minding the store.

And then if you've added anything into the Corrective Action Program now that you're using that maybe a little more aggressively, or will be in the future, that also would capture management oversight gaps or issues.

And I'll let whoever on the panel thinks that you're the appropriate person to answer.

- [Jim] So I'd like to start by just explaining that I am the new General Manager for Decommissioning Oversight.

I am an SCE employee, I've been an SCE employee for 37 years, my experience is, I've been in maintenance, I've actually been a refueling supervisor for I don't know, 13, 14 outages, in fact I was the Manager in Charge of safely defueling both units after we announced the shutdown, also utilizing

essentially a small crew of experienced personnel so, you know, I take this issue very seriously.

As far as other changes, I've actually changed my organization such that I go back to the model that works for me which is Oversight is intrusive, right, that the personnel that I put to go oversee the contractor are in fact in the field providing guidance to the contractor, validating that the contractor is in fact following your procedures step-by-step, doing their pre-job briefs, such that personnel are properly instructed before they go out in the field.

In fact, we're doing what we committed to go do by our procedures, that is a full-time responsibility that I've assigned to my Oversight people.

All right, that is a separate oversight function than how it was being performed previously which was more of a

surveillance activity where you could plan and then go monitor and then basically document what you're observing.

I think that's the primary thing.

In my CAP experience, the new senior management observation process where all observations now have to be entered into the Corrective Action Program also helps us ensure that Management is doing observations at the level that Senior Management would expect right, and that screening committee should be challenging those observations with regard to their depth, are these management observations adding value, are they looking at the right things, in that I'll be reporting directly to Doug with regard to what we're seeing within the Senior Management Observation Program also.

- [Doug] Thank you Jim and this is Doug Bauder, I'd like to emphasize a couple of points.

First, although the number of corrective actions around Oversight are not as great as in other areas the impact is pretty high. Some of the key ones Jim discussed, changes in roles and responsibilities, holding his organization accountable.

These oversight specialists, some were let go, additional skilled people were brought in, and their expectations to directly coach in the field not just sit back and write an observation sheet.

Further, what I've asked for, is a management program for us, that includes me, to be out in the field in teams on a structured basis.

So Lou Bosch has put that together.

We had our first team in the field last week, I think that's correct, right Lou?

- [Lou] That's correct.

- [Doug] And on Tuesday I spent three and a half hours observing a training download evolution

as we indicated, I had six or eight comments that Jim is working through the process to put in place, so I completely understand the perspective here, Edison owns this, this is not a contractor issue, it's our oversight responsibility, and we take it serious, I will tell you that from my perspective if the right oversight had been in place, on August 3rd and prior to that, the other aspects of shortfalls that have been talked about here:

procedures, training, they would have been identified and we wouldn't have just been relying on skill of the craft as Tom indicated.

So we talk about Oversight, maybe the number of actions isn't as great but the impact is great.

- [Scott] So thank you for that.

The reason we're boring in on this issue is because this is central to your root cause, right.

So if your root cause is about oversight, the failure to recognize, that's why we're trying to draw out you know, more precisely, what specific actions were taken to address that failure to recognize, do you have a follow up?

- [Eric] This is Eric Simpson.

I had a question and this is sort of an inspection item that we'll fire on you now but, your Oversight Specialists, are they going to be in the field for each and every evolution or only the most critical tasks?

Or will they be in the field observing every task 24/7?

- [Jim] Eric, this is Jim Peattie.

So to answer your question, the procedures actually require their presence in the field for medium and high risk activities especially those activities that have already been pre defined for lifting. But that is a requirement by procedure.

Other activities that are

of low risk would not be a procedure requirement but it is my expectation that as long as I have Oversight personnel available that they are out in the field observing the work activities for that day.

- [Linda] Jim, this is Linda again.

Just for the benefit of the audience and the benefit of those of us on the NRC side, who are participating, could you just give us a couple of examples of when a medium or high risk would be, so we can kind of understand what the threshold is?

- [Jim] Yes, so a high risk activity would be essentially activities that involved handling the fuel, so loading of the canister, removing of a canister with a NUREG-0612 activity would be a high risk activity. A medium risk activity could be a heavy lift that's outside of the guidance of NUREG-0612, so it may not be

handling the fuel but we would still look at that as it's a heavy load, heavy activity, it has risk, industrial safety risk.

We would expect the same behaviors apply.

- [Linda] Okay, thanks Jim.

- [Scott] I think we've reached the end of our questions.

Was there any additional information, Doug, that you or your team wants to provide before we move to close?

- [Doug] I think one item is a follow up to a question that Janine had regarding kind of the procedural flow path we would go through if we had an incident in the dry fuel storage area. So, Jim if you don't mind stepping us through that, or Lou.

- [Jim] Yes Janine, so I think your question was, what action would we take if we found that there was MPC damage, right. The Holtec property procedure

600 which is the Abnormal Operations Procedure has a section in it specific to damage.

It does not say canister drop, it's essentially any damage to a canister.

That procedure directs the supervisor in charge to place the equipment in a safe condition to move personnel to a safe low dose area, to immediately notify the Shift Manager and Senior Management and then our RP or Radiation Protection Technicians would survey the area for radiological conditions or changes.

We would also then write an action request, enter that into our Corrective Action Program with as much detailed information as a supervisor can provide regarding the actual condition, in which case that action request would be evaluated and appropriate action taken, work planned and approved before we

proceed with any recovery.

- [Janine] Jim, thank you for that.

It's Janine and just to follow on with that, one of the questions that underlies all that is, what is considered MPC damage?

So in this particular case, it even has been noted on slide 16 where it talks about the ductile baseplate locally conforming to the shape of the ring, you know, essentially a dent in the canister is that something that would cause you to enter into that procedure?

What is considered MPC damage?

- [Jim] This is Jim Peattie, so, without having the procedure in front of me, in understanding what the definition within the procedure was, I can't really answer that completely, but I would tell you that the day of the event, August 3rd, that in fact those actions were taken although personnel may not have known whether or

not the MPC had damage or the dent at the time.

So there was a action request generated, right, to identify that event which ultimately led our engineering group to assess it.

- [Tom] So Jim I think this is probably one where more- we need to provide more information to the inspection team to follow up with that discussion. Just to add to what Jim said, once our Shift Manager is notified, he assesses the overall condition, he reviews our emergency plan for any entry criteria, would review the radiological conditions, to ensure any actions needed on a broader basis are taken.

- [Linda] Thanks for elaborating on that Tom, this is Linda again.

That procedure along with several of the other procedures identified in the presentation, even though Holtec may have authored them, I know

they have gone through Southern California Edison review, those will be the subject of our additional future near-term inspection activities so just to put that on the record.

- [Scott] All right can I get the NRC slide 13 up please.

So I'm going to go ahead and move to close the meeting, note that, again, as we said at the outset, the NRC will consider all the information we have obtained today in making our final enforcement decision and of course will notify you by telephone and in writing which should be publicly available when we're ready to announce our decision.

We strive to make that decision within 45 days, it could be sooner. At the outside I would say 45 days.

So what comes next?

We'll make a final determination as to whether or not apparent violations constitute actual violations, and

their severity levels, consistent with our enforcement policy.

This determination will be communicated to Southern California Edison and will be made public.

As we've noted a couple of times, the NRC staff in Region IV plans to conduct follow up inspections to determine whether corrective actions are appropriate and adequate to prevent future recurrence of the issues.

And in addition, the results of those follow up inspections will be communicated to the public in the form of a public meeting or webinar prior to or concurrent with the release of the inspection report.

As Linda mentioned earlier, a decision on whether or not Southern California Edison is ready to resume fuel loading operations will be made after our inspection efforts which I believe we have planned here in the next couple of weeks. That decision will be shared with the public

during the aforementioned public meeting or webinar as well as in writing on the public record.

I'll remind everyone, that the apparent violations discussed at this conference are subject to further review and may be revised prior to any resulting enforcement action and that any statements or expressions of opinions made by NRC employees made at this conference, or the lack thereof, are not intended to represent final agency positions.

Slide 14.

The NRC is interested in feedback from all participants and observers on how it conducts these meetings and other meetings, and in particular, interested in comments about this meeting today.

We provided written comment forms which are available in the back, we invite any person who has a comment to complete the form,

please leave the forms with the individuals in the back or if you prefer you can send them in via email or mail.

Persons attending through the webinar can find the feedback form on our website.

So with that, the business portion of this conference is closed, thank you.

Slide 15 please.

All right, now that the business portion of the conference is concluded, I'd like to offer any observers the opportunity to comment on the meeting or to ask the NRC staff present any questions they may have about the NRC and/or our enforcement process.

Doug, you and your team are welcome to stay and observe or you're also welcome to depart, it's your decision, you're not going to be asked to respond to any questions that we get, so if you're at the meeting we have collected comments and

questions through the webinar application and in the time remaining we'll try to answer those questions with a priority on questions that relate directly to our enforcement process.

All questions received via the webinar will be posted on our Spotlight page on the NRC homepage, along with closed captioned video and an audio transcript of today's meeting, that will take a couple of weeks, as Linda mentioned at the outset.

So I'm going to hand this over to Ryan Alexander in the back, where's Ryan? There's Ryan.

So Ryan, take it away.

- [Ryan] All right, good afternoon, thank you Scott, I appreciate it.

My name again is Ryan Alexander, and I'm actually a member of the NRC Region IV staff who's primarily involved with our operating reactors and doing inspections and oversight of those facilities but I was asked to support today for the Q&A session.

As Linda and of course now Scott has also

mentioned, our priority in this portion of the meeting is to address your questions related to the NRC's enforcement decision making process.

Now most of those questions that have all been raised have all been from the webinar.

Just for everybody's-and full disclosure, there are no members of the public that have arrived at this meeting that are with us today, so all the questions that we'll be presenting to the NRC staff came from the webinar straight, which myself and several members of the staff have been monitoring throughout the activities this afternoon. So first of all, I want to thank you all for pointing out some of the technical difficulties that we were having at least early on with microphones and volume on the systems.

We hope we appropriately

addressed those for you so you could continue to participate here as we went through that this afternoon.

And the other thing is, is that there were many, many questions that were asked, most of them, I'll be honest, were very focused on some of the technical aspects which ultimately either SCE addressed at least in its part of the Q&A session with the NRC throughout many of these questions.

But as Scott mentioned, a full transcript of all the questions will be posted at some point in the future from this webinar.

What we want to focus on with the NRC staff right now is to focus on those questions related to the enforcement and decision making process and so I'll go ahead and just pose those questions to staff, and Scott, and take them or hand them off as necessary.

One question from one

member of the public, and these are in no particular order, is can the public challenge any NRC enforcement actions and if so, how?

- [Scott] So really the only mechanism for the public to challenge an enforcement decision rendered by the NRC is through what we call, what we refer to the 2.206 process, it's actually Part 2 of the Code of Federal Regulations 10 CFR part 2, section 2.206 and that is basically a request by anyone to take some enforcement action against a licensee, it's not necessarily a challenge to a decision per se, it's another request to consider an alternate course of action and that- there is a very formal process by which that can be done.

- [Ryan] All right, thank you Scott.

Another question that we received was, and I think Scott you may have just touched on this in your closing

remarks but just to clarify for the individual, what is the expected timeline for the NRC's enforcement actions on each of these apparent violations?

- [Scott] Yeah, so consistent with our own internal metrics and policies, and like I said, we strive to get a final enforcement decision in the public domain within 45 days.

- [Ryan] 45 days, okay, appreciate that.

Moving on, third question, a little more technical in nature in terms of the process, is:

How does the NRC consider the licensee's failure to identify the July 22nd precursor event in determining the violation, either significance or severity level of the event?

- [Scott] I'll open that up to Linda or anyone.

- [Linda] This is Linda.

The July 22nd incident, I don't want to use the term event, has already

been discussed in the inspection report, and documented the results of the special inspection and the other two apparent violations and it has been handled in one of the lesser safety significant violations at Severity Level IV, really had to do with entering information into the Corrective Action Program, so that has been dispositioned.

- [Ryan] Along those lines, there is something that came in when we were in caucus with the staff that also goes back to the special inspections.

How did the NRC assess the licensee's implementation of their fitness for duty program for those individuals involved during the August 3rd event?

- [Scott] Eric or Janine?

- [Eric] It was my understanding, and I've discussed it with the Licensee, they did perform a for-cause fitness for duty evaluation of those individuals involved in the event and

they both came back negative.

They were not impaired during this evolution so there was no fitness for duty impact to the individuals.

There was no fitness for duty issue.

- [Ryan] Different line of question that came up was regarding what it means, Southern California used the term self-revealed in terms of some of the events, can the NRC describe what this means and how the NRC considers this in determination in the enforcement process.

- [Scott] Michael, do you want to take that?

- [Michael] I'd be happy to. Self-revealing is a term that we use when we're considering identification credit, some of that is identification of an event that was self-revealing and so when we're looking at identification credit, we look at the licensee's

actions in there. Were they self-monitoring and that's how they found it, we look at the ease of discovery, were there prior opportunities to have discovered it, that's the kind of thing we look at for a violation when we're considering identification for that.

- [Scott] But with respect specifically to self-revealing it's an incident that occurs, nobody found it before it occurred, it found you. It's a self-revealing event is, you know, I'm trying to think of a good example.

- [Linda] Let me use the August 3rd example to be you know, very obvious, the redundant safety systems were the slings that were connected to the vertical cask transport system and it was very obvious that they were no longer supporting the load of the canister so that is why we believe Southern California Edison characterized

that one as self-revealing.

- [Ryan] I appreciate the clarification on that.

With that, we actually have one last question that had not been addressed either in Mike's preamble on the enforcement process and it had to do with the NRC's interactions with the US Attorney General or the Department of Justice and specifically, in this case, are the findings turned over to the US Attorney General or Department of Justice for criminal prosecution?

- [Scott] So the short answer to that question is no.

I know that we've had conversations with members of the FBI, maybe Linda you want to just comment on that.

- [Linda] Sure. In this particular case, the NRC has sole jurisdiction over taking a civil action, we have been in communication with the Bureau of Investigations, there has been no expressed interest nor would they

have the primary jurisdiction at this point in time.

We have coordinated information with them.

- [Ryan] With that I'm going to look back to my cohorts in the back, were there any other process or enforcement agency questions that have come up just in the last few minutes while I've been up here that you would share? No.

Okay, we're getting no on that, so with that, Scott, I'm going to turn it back to you.

- [Scott] Well remarkably we were able to get everything covered within the allotted three hour window and I want to thank everybody, I want to thank the staff.

I want to apologize again to those of you participating on the webinar for the technical challenges you experienced during this with respect to, I understand there has been some feedback and some difficulty hearing.

This format for conducting

these type of meetings is a relatively new innovation for us, it's not innovative by any stretch, but for us it is and we haven't done too many of these and I think this is actually only our second or third where we've conducted a public meeting like this via webinar and so there's bound to be challenges so again, I apologize for those challenges and I look forward to any and all feedback we get about how we conducted this meeting.

With that, we are adjourned, thank you.