Dominion went a different way. Dominion does not consider movement of fuel to the ISFSI as a transfer of fuel between different entities since it is still on the same site property. We made the ISFSI PADs another Item Control Area (ICA) on the site and tracked it with Shuffleworks as part of normal internal fuel movement. As a result, no transfer of fuel occurred, just movement within a given site with the use of existing fuel tracking procedures.

I don't have any insight on the second question since it has not come up. I would assume that since the only source of fuel to Surry's ISFSI can only come from Surry's reactor that issue does not apply.

Matthew W. Streibich
Reactor Engineer
Kewaunee Power Station
Email: Matthew Streibich@Dom.com
Phone: 920-388-8624
Pager #: 920-305-0363

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