Surry went a different way. We (Dominion) do not consider movement of fuel to the ISFSI as a transfer of fuel between different entities since it is still on the Surry site property. We made the ISFSI PADs another Item Control Area (ICA) on the site and tracked it with Shuffleworks as part of normal fuel shuffle 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 is mute.

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

"WILLETT, JOSEPH E" jwillett@oppd.com Sent by: pwrrm-bounces@retaqs.com 02/03/2006 07:09 AM Please respond to PWR Reactivity Management pwrrm@retaqs.com

To pwrrm@retaqs.com cc

Subject [Pwrrm] Nuclear Material Accountability Procedures for ISFSIs

To all,

Hello folks, I?m the RE at FCS responsible for SNM (NMA) tracking. I?m looking to get some procedure information on how you have implemented reporting for your ISFSI, as well as Material Balance Areas.

Additionally, there is an existing question we need to have answered regarding 72.78, which reads as follows:

§ 72.78 Nuclear material transfer reports. (a) Except as provided in paragraph (b) of this section, whenever the licensee transfers or receives special nuclear material, the licensee shall complete in computer-readable format a Nuclear Material Transaction Report in accordance with instructions (NUREG/BR-0006 and NMMSS Report D-24, "Personal Computer Data Input for NRC Licensees"). Copies of these instructions may be obtained either by writing the U.S. Nuclear Regulatory Commission, Division of Nuclear Security, Office of Nuclear Security and Incident Response, Washington, DC 20555-0001, by e-mail to RidsNsirDns@nrc.gov, or by calling (301) 415-7298. Each ISFSI licensee who receives spent fuel from a foreign source shall complete both the supplier's and receiver's portion of the Nuclear Material Transaction Report, verify the identity of the spent fuel, and indicate the results on the receiver's portion of the form. These prescribed computer-readable forms replace the DOE/NRC Form 741 which has been previously submitted in paper form.

Did you address bolded text in your procedures? If not, why? Can you send me an example of how your ISFSI is set up administratively, your controlling procedures?

J. E. Willett "Only those who will risk going too far can possibly find out how far one can go." T.S. Eliot (1888-1965) ---------------------------------------------------- Joseph E. Willett, P.E. Principal Reactor Engineer, Nuclear Operations E-mail: jwillett@oppd.com OR Joseph_Willett@hotmail.com Omaha Public Power District Phone: (402) 533-7213 P.O. Box 399 Pager: (402) 561-3899 Ft. Calhoun, NE 68023-0390 FAX: (402) 533-6747 Mail Station: FC-1-1 Plant

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