ML113540582
| ML113540582 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/27/2011 |
| From: | Northern States Power Co, Xcel Energy |
| To: | NRC/NMSS/SFST |
| Longmire P, NMSS/SFST 301-492-3562 | |
| Shared Package | |
| ML113540578 | List: |
| References | |
| TAC L24589 | |
| Download: ML113540582 (82) | |
Text
1 Rockville, Maryland November 18, 2011 Prairie Island Independent Spent Fuel Storage Installation License Renewal Post-Submittal Meeting Prairie Island Independent Spent Fuel Storage Installation License Renewal Post-Submittal Meeting
2 Xcel Energy Attendees Paula Anderson - Director of Nuclear Licensing and Regulatory Affairs Lee Samson - Manager, Spent Nuclear Fuel Projects Oley Nelson - Spent Nuclear Fuel Project Engineer Jennie Eckholt - Licensing Engineer Jim Holthaus - Program Manager
3 Objective Prairie Island (PI) Independent Spent Fuel Storage Installation (ISFSI) Background Licensing Approach License Renewal Application Summary Discussion Agenda
4 Agenda (Cont.)
License Renewal Application Section 1 - General Information Section 2 - Scoping Evaluations Section 3 - Aging Management Reviews (AMR)
Appendix A - Aging Management Program (AMP)
Appendix B - Time-Limited Aging Analyses (TLAA)
Appendix C - Safety Analysis Report (SAR) Supplement and Changes Appendix D - Technical Specification Changes Appendix F - Additional Information Appendix E - Environmental Report Supplement
5 Objective Discuss licensing approach for the PI ISFSI License Renewal Application (LRA)
Discuss technical content of the PI ISFSI LRA
6 PI ISFSI Background Site Background
7 PI ISFSI Background Original Site Specific License (SNM-2506) issued October 1993 20-year license expires October 31, 2013 TN-40 cask design Amendment for TN-40HT cask design issued in August 2010 License Renewal Application (LRA) submitted on October 20, 2011 License Background
8 Licensing Approach 10 CFR 72.42 Renewal term of 40 years Time-Limited Aging Analyses (TLAA)
Aging Management Program (AMP)
Design Basis NUREG-1927 10 CFR 72.34 NUREG-1748 Recent industry applications and Requests for Additional Information (RAI)
Regulations and Guidance for License Renewal
9 Section 1 - General Information 10 CFR 72.22 Requirements Address of Applicant Directors and Executive Officers Financial Qualifications Financial Assurance for Decommissioning (10 CFR 72.30)
Abbreviations and Intended Functions Application Format and Content Administrative Information
10 Section 2 - Scoping Evaluations Scoping process involves three steps:
- 1. Identify ISFSI structures, systems, and components (SSC) that are in-scope for License Renewal
- 2. Identify and describe subcomponents of in-scope SSCs
- 3. Identify intended functions of subcomponents of in-scope SSCs Scoping Process
11 Section 2 - Scoping Evaluations PI ISFSI Licensing Basis contains two Quality Assurance classifications Safety-Related (SR)
Important to Safety (ITS)
Criteria used to determine if SSC is in-scope Criterion 1: ITS or SR Criterion 2: non-ITS or non-SR but failure would impact fulfillment of a safety function Step 1 - Scoping Criteria
12 Section 2 - Scoping Evaluations Step 1 - Scoping Results N
N N
Transporter and Supporting Equipment N
N N
Security Fence and Gates N
N N
Lighting N
N N
ISFSI Pressure Monitoring System Y
Y N
Earthen Berm Y
N/A Y
Reinforced Concrete Pads Y
N/A Y
Spent Fuel Assemblies (SFA)
Y N/A Y
Dry Storage Casks In-Scope Criterion 2 Criterion 1 Structures/Components
13 Section 2 - Scoping Evaluations Step 2 - Overview of Cask Design
14 Section 2 - Scoping Evaluations Step 2 - Description of SFA Fuel Assembly Insert Guide Tube Bottom Nozzle Top Nozzle Nozzle Spring Set Fuel Rod Grid
15 Section 2 - Scoping Evaluations Step 2 - Description of Cask Design Fuel Compartment Basket Rails Aluminum and Poison Plates Note: Sketch is of a TN-40HT basket. Construction of a TN-40 basket is slightly different.
16 Section 2 - Scoping Evaluations Protective Cover Lid Lid Shield Plate Lid Bolts Inner Containment Shell Shell Radial Neutron Shield Upper Trunnion Lower Trunnion Bottom Drain Tube Overpressure Tank Lid Seals Top Neutron Shield Step 2 - Description of Cask Design Outer Shell Drain Port Cover
& Bolts Containment Flange Bottom Inner Containment Plate
17 Section 2 - Scoping Evaluations Containment Flange Protective Cover Lid bolt Protective Cover Seal Protective Cover Bolt Overpressure Tubing Top Neutron Shield Enclosure Top Neutron Shield Lid Top Neutron Shield Bolt Shield Plate Step 2 - Description of Cask Design Lid Seals
18 Section 2 - Scoping Evaluations Step 2 - Description of Concrete Pads and Berm
19 Section 2 - Scoping Evaluations Identify the intended functions of subcomponents of in-scope SSCs Criticality control of the spent fuel (CC)
Heat transfer (HT)
Maintaining a pressure boundary (PB)
Radiation shielding (SH)
Structural and/or functional support (SS)
Only subcomponents that perform or support an intended function require an aging management review Step 3 - Intended Functions
20 Section 3 - Aging Management Reviews AMR process involves three steps:
- 1. Identification of materials and environments
- 2. Identification of aging effects/mechanisms requiring management
- 3. Determination of the activities/programs required to manage the effects/mechanisms of aging AMR Process
21 Section 3 - Aging Management Reviews Materials of construction of in-scope structures or components Aluminum Borated Compounds Borated Polyester Carbon Steel Nickel-Based Alloys Polypropylene Step 1 - Identification of Materials Reinforced Concrete Soil Stainless Steel Zirconium-Based Alloys
22 Section 3 - Aging Management Reviews Environments seen by in-scope subcomponents during storage include Air/Gas o
Dry air (including any off-gassing of polymers) o Helium (including trace amounts of other gases)
Atmosphere/Weather o
Includes humidity, precipitation, ultraviolet radiation, ozone, and wind Soil Environments are those that are normally experienced during storage Step 1 - Identification of Environments
23 Section 3 - Aging Management Reviews Potential aging effects/mechanisms for a material in an environment were identified by Operating Experience (OE) review Literary references review The aging effects/mechanisms of a subcomponent were identified by selecting the applicable aging effects/mechanisms, based on the Material of Construction Environment Step 2 - Identification of Aging Effects/Mechanisms
24 Section 3 - Aging Management Reviews Prairie Island OE No aging effects/mechanisms identified for in-scope SSCs Industry OE EPRI Dry Cask Storage Characterization Project (EPRI 1002882)
Lid seal failures of similar TN cask designs Step 2 - OE Review for Potential Aging Effects
25 Section 3 - Aging Management Reviews Potential aging effects/mechanisms identified from the following reports:
NUREG-CR-6673, "Hydrogen Generation in TRU Waste Transportation Packages," May 2000 NRC Interim Staff Guidance 11, Cladding Considerations for the Transportation and Storage of Spent Fuel, Revision 3, November 17, 2003 EPRI Report, 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools,"
Revision 4, January 2006 EPRI Report, 1002950, "Aging Effects for Structures and Structural Components (Structural Tools)," Revision 1, August 2003 Step 2 - Literary Reference Review for Potential Aging Effects
26 Section 3 - Aging Management Reviews No aging effects/mechanisms identified for SFAs based on Dry Cask Storage Characterization Project (EPRI Report 1002882) o Low burnup o Zirconium-based alloy ISG-11 o Maximum cladding temperature < 752°F Step 2 - Potential Aging Effects for SFAs
27 Section 3 - Aging Management Reviews Identification of activities/program to manage aging effects Single program is utilized to manage identified aging effects ISFSI Inspection and Monitoring Activities Program Described in Appendix A Step 3 - Aging Management Activities
28 Section 3 - Aging Management Reviews Retrievability of SFAs requires:
Cask is transferrable (on-site)
SFAs remain structurally sound (i.e., no gross degradation) and could be handled by normal means AMP ensures no loss of intended functions of cask subcomponents Cask transferrable No aging effects/mechanisms identified for SFAs Handled by normal means Retrievability
29 Appendix A - Aging Management Program ISFSI Inspection and Monitoring Activities Program Subset of the Prairie Island Nuclear Generating Plant (PINGP) Structures Monitoring Program Program addresses all ten elements of an AMP described in NUREG-1927 AMP
30 Appendix A - Aging Management Program Visual inspection of the exterior of the casks Monitoring of the interseal pressure of the casks Radiation monitoring and associated surveillance activities of the casks Visual inspection of the concrete pads Visual inspection of the earthen berm AMP Element #1 - Scope of Program
31 Appendix A - Aging Management Program Visual inspection of a cask bottom prior to the end of the current ISFSI license period Visual inspection under a cask protective cover prior to the end of the current ISFSI license period Visual inspection of the cask bottom in the event a cask is lifted Visual inspection under the protective cover of a cask in the event the cover is removed Visual inspection of the bottom and under the protective cover of the lead cask at least every 20 years AMP Element #1 - Scope of Program (Cont.)
32 Appendix A - Aging Management Program No preventive or mitigating actions are credited AMP Element #2 - Preventive Actions
33 Appendix A - Aging Management Program AMP Element #3 - Parameters Monitored or Inspected HT, PB, SH, SS Loss of Material Visual inspection of normally inaccessible areas (under protective cover and bottom of cask) of lead cask SH Change in material properties, Loss of form, Loss of material Visual inspection of earthen berm SS Change in material properties,
- Cracking, Loss of material Visual inspection of accessible area of concrete pads SH Loss of material Radiation surveys and monitoring via thermoluminescent dosimeters PB Loss of material Interseal pressure HT, PB, SH, SS Loss of material Visual inspection of cask exterior surfaces Intended function Monitored Aging Effect Parameters Monitored or Inspected
34 Appendix A - Aging Management Program Visual Inspections Exterior surfaces of all casks (quarterly)
Concrete pads (every five years)
Earthen berm (every five years)
Bottom of casks (inspection of opportunity, minimum 20 year interval for lead cask)
Under cask protective cover (inspection of opportunity, minimum 20 year interval for lead cask)
AMP Element #4 - Detection of Aging Effects
35 Appendix A - Aging Management Program Continuous monitoring of interseal pressure (checked daily for alarms)
Radiation monitoring at ISFSI boundary and radiation surveys of all casks (quarterly)
AMP Element #4 - Detection of Aging Effects (Cont.)
36 Appendix A - Aging Management Program AMP monitors and trends Inspection results Radiation monitoring Interseal pressure monitoring Corrective Action initiated if adverse trend identified AMP Element #5 - Monitoring and Trending
37 AMP includes acceptance criteria to evaluate Extent of degradation Need for corrective action AMP Element #6 - Acceptance Criteria Absence of an alarm Interseal Pressure Absence of an increasing trend Radiation Monitoring Criteria Absence of aging effects Earthen Berm Consistent with ACI 349.3R Concrete Pads Absence of aging effects Cask Visual Inspection Criteria Appendix A - Aging Management Program
38 Appendix A - Aging Management Program NSPM has a single Corrective Action Program Applied regardless of safety classification 10 CFR 50 - Appendix B Guidance on establishing priority and timely resolution of issues Guidance on when a condition warrants a root cause determination to prevent recurrence AMP Element #7 - Corrective Actions
39 Appendix A - Aging Management Program Confirmation process is part of NSPM Corrective Action Program Verifies effectiveness of implementing corrective actions Precludes repetition of conditions adverse to quality AMP Element #8 - Confirmation Process
40 Appendix A - Aging Management Program Formal review and approval processes applicable to the AMP are implemented in accordance with NSPM Quality Assurance Topical Report 10 CFR 50 - Appendix B AMP Element #9 - Administrative Controls
41 Appendix A - Aging Management Program Prairie Island ISFSI OE Visual inspections of SSCs performed since 1995 o Minor cases of cask coating degradation with no measureable loss of material o No anomalies identified for the concrete pads or earthen berm that affected their intended functions No age-related issues with interseal pressure monitoring system Trending of radiation surveys for casks show no degradation of shielding AMP Element #10 - Operating Experience
42 Appendix A - Aging Management Program Industry OE Corrosion of stainless steel fasteners for rear breech plate of CASTOR V/21 cask design Lid seal failures on similar TN cask designs Loose lid bolts on similar TN cask designs AMP Element #10 - Operating Experience (Cont.)
43 Appendix A - Aging Management Program Lead Cask Inspection Overview Cask #1 selected as lead cask due to longest time in-service Performed visual inspection of normally inaccessible external surfaces of lead cask o Bottom of cask o Under protective cover Expanded inspection to include under the protective cover of Cask #13 o Industry OE - loose lid bolts AMP Element #10 - Operating Experience (Cont.)
44 Appendix A - Aging Management Program Bottom of Cask #1 Inspection Results Approximately 25% of coating exhibited loss of adhesion o Some corrosion of base metal o No measureable loss of material Concrete under the cask exhibited no visual signs of degradation AMP Element #10 - Operating Experience (Cont.)
45 Appendix A - Aging Management Program Under Protective Cover of Cask #1 Inspection Results No evidence of degradation of in-scope subcomponents Rust from the protective cover flange deposited on cask flange o Outside the protective cover seal o No degradation of stainless steel overlay on cask flange No loose lid bolts AMP Element #10 - Operating Experience (Cont.)
46 Appendix A - Aging Management Program Under Protective Cover of Cask #13 Inspection Results No evidence of degradation of in-scope subcomponents Corrosion on the interior of the protective cover and access plate o Rust stains on the stainless steel overlay on cask flange and the top neutron shield o No indication of corrosion of the stainless steel overlay on cask flange No loose lid bolts AMP Element #10 - Operating Experience (Cont.)
47 Appendix B - Time-Limited Aging Analyses
TLAAs are calculations or analyses that have all of the following attributes:
1.
Involves a SSC within the scope of license renewal 2.
Considers the effects of aging 3.
Involves time-limited assumptions defined by the current operating term 4.
Determined to be relevant in making a safety determination 5.
Involves conclusions or provides the basis for conclusions related to the capability of the SSC to perform its intended functions 6.
Contained or incorporated by reference in the licensing basis TLAA Attributes
48 Appendix B - Time-Limited Aging Analyses
Two TLAAs were identified for the TN-40HT casks:
1.
Basket Aluminum Components for Long Term Storage Deadweight
Disposition: The current SAR evaluation of the deadweight compressive stresses in the basket aluminum, taking into account material creep, is based on 60 years 2.
Neutron Damage of the Cask Metallic Components
Disposition: Projection of the integrated fast neutron flux inside a TN-40HT cask shows that it remains less than the threshold value for neutron damage of 1017 n/cm2 Identification and Disposition of TLAAs
49 Appendix C - SAR Supplement and Changes SAR Update Regulatory Commitments Due Date/Event 1
Following the issuance of the renewed materials license, the summary descriptions of the ISFSI aging management program and Time-Limited Aging Analyses provided in Appendix C of Enclosure 3 will be incorporated into the Prairie Island ISFSI Safety Analysis Report (SAR) as part of a periodic SAR update in accordance with 10 CFR 72.70(c).
First SAR update in accordance with 10 CFR 72.70(c) following issuance of renewed materials license.
50 Appendix D - Technical Specification Changes No Changes to ISFSI Technical Specifications No proposed changes to the existing Prairie Island ISFSI licensing basis Technical Specification Changes
51 Appendix F - Additional Information 10 CFR 72.28 Requirements Technical Qualifications Personnel Training Operating Organization Financial Assurance for Decommissioning included in Section 1 Additional Information
52 52 Environmental Report Supplement Environmental Report (ER) Supplement was prepared in accordance with:
10 CFR 72.34, Environmental Report 10 CFR 51.60, Environmental Report-Materials licenses 10 CFR 51.45, Environmental Report NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs NSPM used precedent ERs as benchmarks Scope and Methodology
53 53 Environmental Report Supplement NSPM analyzed impacts of ISFSI license renewal (LR) against the following documents:
1990 ISFSI Environmental Report 2008 ISFSI TN-40HT Environmental Report Supplement NRCs Generic Environmental Impact Statement for the License Renewal of Nuclear Power Plants, Supplement 39; Regarding Prairie Island Nuclear Generating Plant, Units 1 and 2, Final Report (May 2011)
Ongoing operational reports and ISFSI SAR ER Supplement defines major updates from previously submitted environmental documents Scope and Methodology
54 54 Environmental Report Supplement NSPM consulted with the following agencies to determine impacts of the proposed action:
U.S. Fish and Wildlife Service Minnesota State Historic Preservation Office (SHPO)
Minnesota Department of Natural Resources Prairie Island Indian Community (PIIC)
In December 2009, the Minnesota Public Utilities Commission authorized storage of up to 64 casks in the ISFSI ISFSI LRA requires no other site-specific federal, state, or local permits or authorizations Permits and Consultations
55 55 Environmental Report Supplement Alternatives N/A No Reduce the rate of spent fuel generation N/A No Ship the fuel to existing storage facilities N/A No Increase the capacity of the existing fuel pool No Yes No-action alternative No Yes Construct a new spent fuel pool No Yes Construct another ISFSI at a off-site location No Yes Use alternate design at the PINGP ISFSI No Yes Construct another ISFSI at PINGP N/A No Ship the fuel to a reprocessing facility N/A No Ship the fuel to a federal facility N/A No Expand the existing fuel pool Environmental Advantage Reasonable Alternative Alternative
56 56 Environmental Report Supplement NSPM updated information in the 1990 Environmental Report for the following areas:
Land Use Transportation and Social Services Geology and Soils Water Resources Ecological Resources Meteorology, Climatology, and Air Quality Noise Historical and Cultural Resources Visual and Scenic Resources Socioeconomics Affected Environment
57 57 Environmental Report Supplement Ecological Resources NSPM conducted a survey of medicinal and culturally important plants at PINGP in 2008-2009. No such plants would be impacted.
No special-status species would be impacted.
Affected Environment (Cont.)
58 58 Environmental Report Supplement Historical and Cultural Resources NSPM conducted a Phase I Survey of the ISFSI in 2010. Survey concluded that subsurface deposits are significantly disturbed and contain limited original integrity. The proposed action does not disturb the ground and thus, the resources will not be impacted.
SHPO commented that no properties listed in or eligible for listing in the National Register of Historic Places would be affected.
Affected Environment (Cont.)
59 59 Environmental Report Supplement Issue Environmental Impact Land Use None Transportation and Social Services None Geology and Soils None Water Resources None Ecological Resources None Air Quality None Noise None Historic and Cultural Resources None Visual/Scenic Resources None Socioeconomics None Waste Management None Environmental Impacts
60 60 Environmental Report Supplement Environmental Impacts (Cont.)
Issue Environmental Impact Environmental Justice SMALL. The PIIC is located directly adjacent to the PINGP site boundary; however, impacts on all other resources are small.
Occupational Dose from Normal Operations SMALL. PINGP workers conducting maintenance operations would receive an annual collective dose of 4.470 person-rem. PINGP workers participating in cask loading, transport, and emplacement would receive a collective dose of 3.117 person-rem per TN-40HT cask.
Other Occupational Health Effects SMALL. Any other health effects would be the result of normal workplace hazards (moving heavy objects, etc.)
Dose to the Public from Normal Operations SMALL. The maximum dose to the nearest potential resident is 2.20 E-3 rem/year. The total collective off-site dose is calculated to be 3.60 person-rem.
Dose to the Public from Accidents SMALL. Even with total loss of the confinement barrier, the site boundary accident dose rates would continue to be below 5 rem to the whole body or any organ as specified in 10 CFR 72.106(b).
61 Summary Application submitted on October 20, 2011 Complies with 10 CFR 72.42 and 10 CFR 72.34 Follows the guidance of NUREG-1927 Prairie Island ISFSI LRA
62 Discussion Questions?
63
64 Supporting Slides The following slides contain tables that summarize information and/or results in the License Renewal Application
65 Supporting Slides for Scoping Evaluations Intended Functions of SFA SS None CC, HT, PB, SS CC, HT, PB, SS None None Intended Function Not in-scope Instrument Tube Not in-scope Fuel Rod Spring Not in-scope Fuel Pellet Zirconium-Based Alloys Guide Tube Zirconium-Based Alloys Fuel Cladding End Plug Zirconium-Based Alloys Fuel Cladding Material Subcomponent
66 Supporting Slides for Scoping Evaluations Intended Functions of SFA None None SS CC, HT, SS CC, HT, SS Intended Function Not in-scope Nozzle Spring Set Stainless Steel Top & Bottom Nozzle Not in-scope Fuel Assembly Insert Nickel-Based Alloys Grid Assembly, Top & Bottom Zirconium-Based Alloys Grid Assembly, Middle Material Subcomponent
67 Supporting Slides for Scoping Evaluations HT, SS CC, HT HT CC, HT, SS Intended Function Aluminum Aluminum Plate Stainless Steel Fuel Compartment Aluminum Basket Rails Borated Compounds Poison Plate Material Subcomponent Intended Functions of Cask Subcomponents
68 Supporting Slides for Scoping Evaluations Intended Functions of Cask Subcomponents SH, SS HT, SS SH HT, PB, SH, SS HT, PB, SH, SS HT, PB, SH, SS HT, PB, SH, SS Intended Function Carbon Steel Outer Shell Carbon Steel Bottom Borated Polyester Radial Neutron Shield Nickel-Based Alloys Inner Containment Aluminum Radial Neutron Shield Box Carbon Steel Shell Nickel-Based Alloys Bottom Inner Containment Material Subcomponent
69 Supporting Slides for Scoping Evaluations Intended Functions of Cask Subcomponents None None PB, SS PB SH HT, PB, SH, SS SS Intended Function Carbon Steel Drain and Vent Port Cover Bolts Not in-scope Protective Cover and bolts Not in-scope Overpressure Tank, Isolation Valves and Tubing Carbon Steel Trunnions Stainless Steel Vent & Drain Port Covers Carbon Steel Shield Plate Carbon Steel Lid Material Subcomponent
70 Supporting Slides for Scoping Evaluations SS SS SH PB, SS PB PB, SS Intended Function Carbon Steel with Stainless Steel Overlay Containment Flange Carbon Steel Top Neutron Shield Bolts Carbon Steel Top Neutron Shield Enclosure Carbon Steel Lid Bolts Aluminum Lid, Drain and Vent Port Cover Seals (metallic O-ring)
Polypropylene Top Neutron Shield Material Subcomponent Intended Functions of Cask Subcomponents
71 Supporting Slides for Scoping Evaluations None None None None None Intended Function Not in-scope Protective Cover Seal (Viton O-ring)
Not in-scope Overpressure Port Cover and bolts Not in-scope Lid Alignment Pins Not in-scope Vent and Drain Quick Disconnects Not in-scope Overpressure Port Cover Seal (metallic O-ring)
Material Subcomponent Intended Functions of Cask Subcomponents
72 Supporting Slides for Scoping Evaluations Intended Function of Concrete Pads SS Intended Function Reinforced Concrete Concrete Pads Material Structure
73 Supporting Slides for Scoping Evaluations Intended Function of Earthen Berm SH Intended Function Soil Earthen Berm Material Structure
74 Supporting Slides for AMR Potential Aging Effects/Mechanisms Loss of Material Loss of Material Loss of Material Aging Effect Crevice corrosion Atmosphere/Weather Stainless Steel General corrosion Galvanic corrosion Pitting corrosion Pitting corrosion Crevice corrosion Atmosphere/Weather Carbon Steel Pitting corrosion Galvanic corrosion Crevice corrosion Atmosphere/Weather Aluminum Aging Mechanism Environment Material
75 Supporting Slides for AMR Potential Aging Effects/Mechanisms Loss of Material Loss of Form Change in Material Properties Cracking Change in Material Properties Loss of Material Cracking Change in Material Properties Aging Effect Frost Action Desiccation Atmosphere/Weather Soil Settlement Leaching of Ca(OH)2 Soil Concrete Leaching of Ca(OH)2 Atmosphere/Weather Concrete Reaction with aggregates Erosion Freeze-thaw Reaction with aggregates Freeze-thaw Freeze-thaw Aging Mechanism Environment Material
76 Supporting Slides for AMR AMR Results - Casks
77 Supporting Slides for AMR AMR Results - Casks (Cont.)
78 Supporting Slides for AMR AMR Results - Casks (Cont.)
79 Supporting Slides for AMR AMR Results - Casks (Cont.)
80 Supporting Slides for AMR AMR Results - SFAs
81 Supporting Slides for AMR AMR Results - Concrete Pads