EMAIL TO CEP RE: NRC NON-CITED VIOLATION AND UN-RESOLVED ITEM

To: CEP Members

From: Manuel Camargo

Subject: FYI – NRC Inspection Report

Copy: Tom Palmisano, Julie Holt, Liese Mosher, Lorraine Sandstrom, Al Bates

CEP Members,

I write to make you aware the NRC has issued a report based on a set of SONGS inspections that were
performed by the NRC as SCE prepared for the transfer of spent fuel into the newly expanded ISFSI (this
report does not relate to the recent canister handling incident). Based on feedback from the CEP at our
most recent CEP meeting, we at SCE are committed to more frequent and timely communications.

The two matters outlined below were found during a nearly year-long NRC inspection, from June 2017
through June 2018. This review included six separate on-site inspections from June 2017 to January
2018 as well as in-office review of thousands of pages of analyses, procedures, records, and reports.

The NRC inspection report concludes that SCE has completed all required activities identified in the
requirements for the HI-STORM dry cask storage system.

Field Changes to Equipment

While preparing the SONG fuel building to commence dry storage transfer operations, it was necessary
to perform a minor modification by cutting a small notch in a large steel plate to allow it to clear an
interference on the wall to which it is mounted. The steel plate is part of the structure that holds the
multi-purpose canister (MPC) while it is being processed, to assure the MPC will stay in place during a
large earthquake. In January 2018, the plate was notched using a process through which an engineer
reviewed and found there was no impact to the plate’s function. However, the process used was not
commensurate with the requirements for modification of important safety equipment. The NRC
determined that while the documentation did not include enough information to justify the
modification, the equipment did meet its designed safety function. SCE responded by performing a
Cause Evaluation and implemented corrective actions. All design changes now are reviewed by an
independent engineering group to assure that the appropriate rigor for modifications is performed.

Safety at SONGS was continuously maintained. As you will see in the attached inspection report, the
NRC issued SCE a non-cited violation (the lowest in safety significance).

Methodology Used in Evaluation of Hypothetical Event

As part of preparations for the commencement of spent fuel transfer operations, SCE evaluated a
number of hypothetical scenarios including the drop of a cask in the spent fuel pool during an
earthquake. In its inspection report, the NRC identified an “un-resolved issue” related to the
hypothetical cask drop, and whether the method of evaluation used to calculate the effects of the cask
drop are like those the NRC has previously reviewed. The hypothetical cask drop in the pool during an
earthquake has been evaluated by SCE and determined to not pose any impact to the public and all
federal limits are maintained. With respect to the NRC, SCE has prepared an analysis of the matter and it
is SCE’s belief that the method of evaluation has, in fact, previously been reviewed by the NRC. SCE will
use the subject analysis to support a discussion with NRC staff in the near term, in an effort to address
the un-resolved issue.

Please let me know if you have questions.

Best regards,

Manuel

Manuel C. Camargo Jr.

Principal Manager, Strategic Planning
SONGS Decommissioning
Southern California Edison
www.SONGScommunity.com
manuel.camargo@sce.com
W: 626-302-7902
M: 213-361-3661