hello my name is Scott Morris I'm the
regional administrator for the NRC's
region IV office and we are based in
Arlington Texas and have responsibility
for the nation's civilian use of nuclear
and radioactive materials in the western
United States one of which is the San
Onofre Nuclear Generating Station a
little bit about me I grew up in
Southern California and in fact
graduated from San Dieguito High School
in Encinitas California in 1981 after
that I got my degree in electrical
engineering and subsequently served
seven years on active duty in the United
States nuclear submarine force I joined
the NRC in 1993 where I've served in
progressively more responsible positions
for the last 26 years today I'm going to
talk to you about what happened at the
San Onofre site in San Clemente
California on August 3rd 2018 on that
particular day Southern California
Edison and their contractor Holtec
International was lowering a 50 ton cask
full of 37 spent fuel or used fuel
assemblies into a vault that had been
constructed at the site while lowering
that canister into the vault the the
canister got stuck or hung up on a
shield ring inside the vault that was
undetected by the workers that cask or
that canister was was suspended there
hanging on this shield ring without the
benefit of the two independent safety
slings and was in a rather precarious
position for over 45 minutes
however the canister did not drop and
even if it had there wouldn't have been
a significant radiological release you
got to remember that fuel those 37
assemblies have been sitting in a pool
of water for six years they have cooled
to the point where there's simply no
longer enough energy to produce any kind
of significant emission of radioactive
material to the environment even had the
canister breached so this notion or
speculation about the off-site
consequences from an incident at this
plant causing trillions of dollars
worth of the damage or environmental impact
of the surrounding area is simply not
possible the laws of physics would
dictate otherwise on Monday August the
6th the site vice-president for San
Onofre gave me a call and informally
notified me of what had occurred at the
site that prior Friday it was during
that call that the licensee of Tom
Palmisano told me and committed that
they would not move fuel until they had
an opportunity to understand what
happened and what they needed to do to
keep it from happening again now in
hindsight we determined that they should
have made a formal notification to the
NRC's headquarters operations center
consistent with our part 72 regulations
on September 10th the NRC sent a special
inspection team to San Onofre to
evaluate what occurred on August 3rd and
assess Southern California Edison's
actions to determine why it occurred and
what they had planned to do to correct
the problems it was during that
inspection that the NRC noted five
specific violations of NRC requirements
all five of those we discussed in a
public meeting on March the 25th the NRC
released its final decision on those
significant enforcement matters
specifically we issued a violation for
failure to operate the system in a
manner consistent with our regulations
and also a failure to make a formal
report to the NRC within 24 hours of the
August third incident attached to those
violations was a one hundred and sixteen
thousand dollar civil penalty I want to
point out that this violation are these
violations and the civil penalty is
unprecedented when it comes to
Independent spent fuel storage
installation activities now during the
canister downloading operations
specifically lowering these 50 ton
canisters into the vault there is a
potential for the exterior shell of that
canister to be scratched
now this scratching issue is the
principal reason why the NRC is not yet
comfortable with or confident that the
licensee can resume
spent fuel handling so Edison is
employing a special new robotic camera
system to fully investigate the surface
area of these canisters imagine a little
car with magnetic wheels that's being
placed into a very tight space on the
order of three to five inches and
systematically driving up and down the
surface of the cask with these cameras
to characterize the scratching that they
may have been incurred
it's that system that's been being
employed right now and as of today three
canisters of the 29 have been fully
inspected using this system the NRC is
awaiting the results of Edison's of
review of each of these canisters and
specifically the results of these camera
inspections as well as their analysis of
what they found it's once the NRC
receives that information from Edison we
will then apply our own independent
technical judgment as to the adequacy
not only of the inspections but whether
or not what they found and the results
of what they found meet our requirements
one of the regulatory issues were
concerned about is that the safety
analysis that was provided to the NRC as
part of the application to certify the
Holtec ISFSI system that safety
analysis report indicated that there
would be no scratches on the canisters
however we know for a fact that some degree of
scratching or abrasions have occurred on
these canisters
so that inconsistency needs to be
reconciled now in addition to the Holtec
ISFSI system receiving a certificate
of compliance San Onofre or Southern
California Edison also has a general
license to use that Holtec ISFSI
system and in that general license the
NRC does recognize that the American
Society of Mechanical Engineers Boiler
and Pressure Vessel Code acknowledges
that there will be some scratching it's
not unusual in fact it's expected to
some degree
that during the manufacturing process in
later the operational phase of using the
system that some scratching will occur
incidentally and so some is permitted
per that code so the challenge that we
find ourselves in
specifically Edison finds itself in is
reconciling the these documents to
ensure that they fully understand why
scratching is okay how much scratching
has actually occurred and to what degree
and is it bounded by the technical basis
again that can be found in some of these
in the Boiler and Pressure Vessel Code
so there's another aspect to this that I
want to address very briefly so if it
turns out that technically what exists
at the site with respect to canister
scratching is okay is there's not a
safety issue there's still another
regulatory hurdle that has to be
addressed and specifically that is the
process by which the licensee or Edison
has to go through to reconcile these
documents that are currently
inconsistent or would not otherwise
permit scratching and that process it's
yet to be determined whether that
process again consistent with our
regulations can be done without prior
NRC approval or whether NRC prior
approval is required the latter of which
could take several weeks or potentially
months to resolve right now the ball is
in Edison's Court to deliver to us a
technical basis or rationale for why the
degree of scratching on the canisters
that they've observed is okay from a
safety significant standpoint and why it
meets our NRC requirements until the NRC
receives that information from the
licensee the NRC is not going to permit
Edison to move resume fuel handling as
an independent regulator the NRC will
continue to conduct inspections at San
Onofre for years to come in the process
we will continue to make available to
the public in its transparent manner as
possible all the information that we
derive from our inspection and
assessment activity
at that site in fact today if you go to
the NRC’s homepage WWW.NRC.gov you will
find on the left-hand side a spotlight
column and specifically a link to the
SONGS canister downloading incident if
you go to that link you will find an
immense amount of information related
all the work we have done related at
facilities since the August 3rd 2018
event and we will continue to post
information as we move into the future
