ML14230A908

Enclosure - Elements of an AMP CC ISFSI - July 17, 2014, Summary of Meeting with Exelon Corporation to Discuss Request for Additional Information No. 4 to the Calvert Cliffs ISFSI License Renewal Application (Docket No. 72-08) TAC L24475

ML14230A908
Person / Time
Site:	Calvert Cliffs
Issue date:	08/18/2014
From:	Goshen J NRC/NMSS/SFST
To:
Goshen J
Shared Package
ML14230A903	List: ML14230A908 ML14230A909 ML14230A910 ML14230A911 ML14230A913
References
TAC L24475
Download: ML14230A908 (12)

Text

Elements El t off an Aging Management Program Division of Spent Fuel Storage and Transportation Offi off Nuclear Office N l Material M t i l Safety S f t and d Safeguards S f d U.S. Nuclear Regulatory Commission Meeting to Discuss the Request for Additional Information Responses Regarding the Calvert Cliffs Independent Spend Fuel Storage Facility License Renewal July 17, 2014 1

Regulatory Basis 10 CFR 72.42(a), 72.240(c):

1. TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.

2. A description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs SSCs.

Guidance: NUREG-1927 AMP Elements:

1.

1 Scope of the Program 6.

6 Acceptance Criteria

2. Preventive Actions 7. Corrective Actions

3. Parameters Monitored/Inspected 8. Confirmation Process

4. Detection of Aging Effects 9. Administrative Controls

5. Monitoring and Trending 10. Operating Experience For in-scope SSCs, detailed AMPs addressing the 10 elements l d to lead t efficient ffi i t staff t ff reviews i and d effective ff ti managementt off aging i effects 2

AMP Element 1:

Scope of the Program NUREG-1927: The scope of the program should include the specific structures and components subject to an AMR Identifies:

p components In-scope p and subcomponents p

Materials of construction Service environment Aging g g mechanisms for material/environment combination Aging effects associated with each aging mechanism 3

AMP Element 2:

Preventive Actions NUREG-1927: Preventive actions should mitigate or prevent the applicable aging effects Actions to minimize, control, or prevent the degradation mechanism, e.g. NRC-endorsed criteria (peak cladding temperatures below ISG-11, rev. 3 limit li it during d i drying),

d i ) consensus codesd and d standards, t d d etc.t 4

AMP Element 3:

Parameters Monitored/ Inspected NUREG-1927: Parameters monitored or inspected should be linked to the effects of aging on the intended functions of the particular structure and component Identifies:

Parameters (e.g. cracking size monitoring, rate of material loss, temperature, neutron fluence, etc.)

Location(s) to be monitored or inspected (e.g. at highest heat location, neutron fluence at 1 m from cask)

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs parameters monitored/inspected (tiered approach) 5

AMP Element 4:

Detection of Aging Effects NUREG-1927: Define method or technique, frequency, sample size, data collection and timing to ensure timely detection of aging effects collection, Identifies:

Method/technique (e.g. visual, volumetric, and/or surface inspections or surveys)

Frequency of inspection (e.g. inspection intervals)

Sample size (dependent on operational experience trending)

Calibration of equipment Data collection (clearinghouse for operational experience)

Timing (new or one-time inspections, time of year)

Learning/Proactive/Responsive L i /P ti /R i AMP:

AMP Operational experience and other quality data (tollgates)

Consensus codes and standards Informs I f methods/techniques th d /t h i ffor detecting d t ti aging i effects/mechanisms ff t / h i (tiered approach) 6

AMP Element 5:

Monitoring & Trending NUREG-1927: Should provide for prediction of the extent of the effects of aging and timely corrective or mitigative actions Trending of aging effects (e.g. corrosion rate, crack growth rate, etc.)

Assess effects per prior inspections and industry-wide operational experience i

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs monitoring and trending 7

AMP Element 6:

Acceptance Criteria NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated; should ensure that SSC functions are maintained Criteria for inspections, assessing aging effects, and decision-making Establish technical basis for specific p acceptance p criteria Domestic and international consensus codes and standards whenever practicable, or previously justified and established criteria Separate criteria should be provided for each aging effect Alternative criteria may be used if justified:

Supporting technical basis (OpE and/or engineering analysis/standards)

Avoid non-quantifiable phrases (e.g. significant, moderate, minor, little, etc.)

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs acceptance criteria 8

AMP Element 7:

Corrective Actions NUREG-1927: Corrective actions, including root cause determination and prevention of recurrence, recurrence should be timely CAP commensurate with 10CFR72 Subpart G, or 10CFR50 Appendix B Maintenance plans and/or corrective actions for specific degradation effects ff t ((e.g. repair, i replacement, l t mitigation iti ti activities, ti iti & extent t t off condition)

Actions to prevent reoccurrence Justification for actions such as repair repair, replace replace, and/or mitigate Analysis of how action may affect other subcomponents Consideration of corrective actions on other components Plans for OpE incorporation into the remediation plan Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs corrective actions 9

AMP Element 8:

Confirmation Process NUREG-1927: The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been completed and are effective Element should reference:

Quality Assurance Program consistent with 10CFR72 Subpart G, or 10CFR50 Appendix B.

Methods to confirm adequate actions are taken, and are verified as effective ff ti 10

AMP Element 9:

Administrative Controls NUREG-1927: Administrative controls should provide a formal review and approval process Elements should reference:

Qualityy Assurance Program g consistent with 10CFR72 Subpart p G,, or 10CFR50 Appendix B.

Inspector requirements Record retention requirements Review process of inspection results Frequency/methods for:

reporting inspection results to NRC evaluating suitability of AMP based on industry-wide OpE (tollgates) 11

AMP Element 10:

Operating Experience NUREG-1927: Include past corrective actions; provide objective evidence to support a determination that the effects of aging will be adequately managed so that the SSC intended functions will be maintained during the period of extended operation Critical element to Learning/Proactive/Responsive AMP Reference and evaluate applicable Operational Experience:

Industry-wide Condition Reports, Corrective Action Reports, NRC Information Notices, Notices Applicable industry initiatives (e.g.

(e g DOE cask demo, EPRI-sponsored inspections) 12