ML18179A260

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Enclosure 4 - Rancho Seco ISFSI License Renewal Application, Revision 1 (Non-Proprietary Version)
ML18179A260
Person / Time
Site: 07200011
Issue date: 06/30/2018
From:
Rancho Seco Assets Power Generation, Sacramento Municipal Utility District (SMUD)
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML18179A255 List:
References
CAC 000993, CAC 001028, DPG 18-114, EPID: L-2018-LNE-0004, EPID: L-2018-RNW-0005
Download: ML18179A260 (342)


Text

Enclosure 4 to DPG-18-114

Rancho Seco ISFSI License Renewal Application, Revision 1 (non-proprietary version)

PUBLIC VERSION Rancho Seco ISFSI 14440 Twin Cities Road, Herald, CA 95638-9799 Sacramento Municipal Utility District (SMUD) Rancho Seco ISFSI License Renewal Application Docket 72-11 SNM-2510 Revision 1 June 2018 The proprietary notice is withheld from this public LRA version.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page i Table of Contents 1. GENERAL INFORMATION 1.1Introduction ........................................................................................... 1-11.2Application Format and Content ......................................................... 1-31.3Facility Description ............................................................................... 1-51.3.1Facility Description .................................................................... 1-51.4Information Required by 10 CFR 72.22 ............................................... 1-61.4.1Name of the Applicant ............................................................... 1-61.4.2Address of the Applicant

............................................................ 1-61.4.3Address of the Rancho Seco ISFSI ........................................... 1-61.4.4Description of Business or Occupation of the Applicant ............ 1-61.4.5Organization and Management of the Applicant

........................ 1-61.4.6Financial Information ................................................................. 1-81.5References ............................................................................................ 1-92. SCOPING EVALUATION Introduction ........................................................................................... 2-12.1Scoping Evaluation Process and Methodology ................................. 2-22.2 2.2.1Licensing Basis for Retrievability of Rancho Seco SFAs ........... 2-32.2.2Documentation Sources Used for Scoping ................................ 2-3Results of Scoping Evaluation ............................................................ 2-62.3 2.3.1Structures, Systems, and Components within the Scope of Rancho Seco ISFSI License Renewal ................................... 2-62.3.2SSCs not within the Scope of Rancho Seco ISFSI License Renewal ....................................................................... 2-72.3.2.1Fuel Transfer and Auxiliary Equipment ..................... 2-72.3.2.2Approach/Apron Slabs .............................................. 2-82.3.2.3Miscellaneous Equipment ......................................... 2-82.3.2.4GTCC waste .............................................................. 2-8Detailed Description of Rancho Seco ISFSI Components 2.4 and Subcomponents .......................................................................... 2-102.4.1DSCs ....................................................................................... 2-102.4.1.1Fuel-Only (FO) DSC ................................................ 2-11 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page ii 2.4.1.2Fuel with Control Components (FC) DSC ............... 2-112.4.1.3Failed Fuel (FF) DSC .............................................. 2-122.4.1.4Greater Than Class C Waste (GTCC) DSC ............ 2-132.4.2HSM ........................................................................................ 2-132.4.3NUHOMS- MP187 Transfer Cask .......................................... 2-142.4.4Spent Fuel Assemblies ............................................................ 2-152.4.4.1Fuel Rods (Cladding, End Caps/Plugs) ................... 2-162.4.4.2Guide Tubes ............................................................ 2-162.4.4.3Instrumentation T ube Assembly .............................. 2-162.4.4.4Spacer Grid Assemblies .......................................... 2-162.4.4.5Lower End Fitting (and related subcomponents) ..... 2-172.4.4.6Upper End Fitting (and related subcomponents) ..... 2-172.4.5ISFSI Base mat ........................................................................

2-172.4.6Approach Slab ......................................................................... 2-17References .......................................................................................... 2-182.53. AGING MANAGEMENT REVIEW 3.1Introduction ........................................................................................... 3-13.2Operating Experience Review ............................................................. 3-33.2.1Operating Experience Review Process ..................................... 3-33.2.2NUHOMS System Operating Experience ................................ 3-53.2.2.1CoC 1004 NUHOMS System Operating Experience ................................................................ 3-53.2.2.2Rancho Seco ISFSI Operating Experience ............... 3-73.2.3Generic Industry Experience ................................................... 3-123.2.3.1INPO Database ....................................................... 3-123.2.3.2NRC Information Notices ......................................... 3-123.2.3.3NRC Bulletins .......................................................... 3-143.2.3.4NRC Inspections of Rancho Seco ISFSI ................. 3-143.2.3.5NRC Inspections of Other ISFSIs ............................ 3-163.2.4Rancho Seco ISFSI Pre-Appl ication Inspection ...................... 3-173.2.4.1Inspection Equipment and Methodology ................. 3-173.2.4.2HSM-20 Interior and DSC Exterior Inspection Results .................................................................... 3-19 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page iii 3.2.4.3HSM-20 Array Exterior Inspection Results .............. 3-203.2.4.4Chloride Sample Analysis Results

........................... 3-213.2.4.5Conclusions ............................................................. 3-223.2.5Summary of Pre-Application In spections at Other ISFSIs Using NUHOMS Storage Technology

.................................... 3-233.2.5.1Calvert Cliffs Nuclear Power Plant ISFSI, Material License No.

SNM-2505 ........................................... 3-233.2.5.2Oconee Nuclear Station ISFSI, Material License No. SNM-2503 ............................................................... 3-243.2.5.3H.B. Robinson Steam Electric Plant ISFSI, Material License No.

SNM-2502 ........................................... 3-253.2.5.4Environmental Fact ors Review ................................ 3-263.2.6Operating Experience Review Results Summary and Conclusions ............................................................................. 3-273.3Aging Management Review Methodology ........................................ 3-573.3.1Identification of Materi als and Environments ........................... 3-573.3.1.1Materials .................................................................. 3-583.3.1.2Environments .......................................................... 3-583.3.2Identification of Aging Effe cts Requiring Management ............ 3-603.3.3Identification of the Activi ties Required to Manage the Effects of Aging ....................................................................... 3-603.4Aging Management Review Results - DSCs .................................. 3-623.4.1Description of DSC Subcomponent s ....................................... 3-623.4.2DSC Materials Evaluated

........................................................ 3-623.4.3Environments for the DSC ....................................................... 3-623.4.4Aging Effects Requiring Management for the DSCs ................ 3-643.4.4.1Materials .................................................................. 3-643.4.4.2Discussion of Aging Mechanisms ............................ 3-643.4.4.3Neutron Absorber Materials Evaluation ................... 3-743.4.4.4Coating Evaluation .................................................. 3-753.4.4.5Temporary Attachment Evaluation .......................... 3-753.4.4.6Summary of Applicable Aging Effects Requiring Management for DSCs ............................................ 3-763.4.5Aging Management Activiti es for DSCs ................................... 3-773.4.5.1DSC TLAAs ............................................................ 3-77 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page iv 3.4.5.2DSC Aging Management Programs ........................ 3-773.4.6Summary of the AMR Resu lts for the DSCs ............................ 3-783.5Aging Management Review Results - HSM ...................................... 3-893.5.1Description of HSM Subcomponents ....................................... 3-893.5.1.1Excluded Subcomponents ....................................... 3-913.5.2HSM Materials Evaluated

........................................................ 3-923.5.3Environments for the HSMs

..................................................... 3-923.5.4Aging Effects Requiring Management for the HSMs ............... 3-933.5.4.1Concrete .................................................................. 3-933.5.4.2Discussion of Agi ng Mechanisms ............................ 3-943.5.4.3Steels and Other Metals ........................................ 3-1023.5.4.4Discussion of Aging Mechanisms .......................... 3-1033.5.4.5Coatings Evaluation .............................................. 3-1073.5.4.6Summary of Aging Effects Requiring Management3-1083.5.5Aging Management Activities for the HSMs .......................... 3-1093.5.5.1HSM TLAAs

........................................................... 3-1093.5.5.2HSM Aging Management Programs ...................... 3-1093.5.5.3Summary of the AMR Results for the HSMs ......... 3-1093.6Aging Management Review Results - Concrete Basemat (Storage Pad) .................................................................................... 3-1103.6.1Description ............................................................................ 3-1103.6.2Basemat Materials Evaluated

................................................ 3-1103.6.3Environments for t he Basemat

.............................................. 3-1103.6.4Summary of Aging Effects Requiring Management ............... 3-1103.6.5Aging Management Activities fo r the Rancho Seco ISFSI Basemat ................................................................................ 3-1113.7Aging Management Review Results - Transfer Cask .................... 3-1163.7.1Description of Transfer Cask Subcomponents ...................... 3-1163.7.2Transfer Cask Material s Evaluated ....................................... 3-1183.7.3Environments for the Transfer Cask ...................................... 3-1183.7.4Aging Effects Requiring M anagement for the Transfer Cask ...................................................................................... 3-1183.7.4.1Steels and Other Metals ........................................ 3-118 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page v 3.7.4.2Discussion of Aging Mechanisms .......................... 3-1193.7.4.3Other Materials ...................................................... 3-1233.7.4.4Coating Evaluation ................................................ 3-1243.7.4.5Summary of Aging Effects Requiring Management3-1243.7.5Aging Management Activities for the NUHOMS MP187 Transfer Cask (TC) ................................................................ 3-1253.7.5.1TC Time-Limited Agin g Analysis .......................... 3-1253.7.5.2TC Aging Management Programs ......................... 3-1253.7.5.3Summary of the AMR Results for the TC .............. 3-1253.8Aging Management Review Results - Spent Fuel Assemblies

........................................................................................ 3-1323.8.1Description of Spent Fuel Assembly Subcomponents ........... 3-1323.8.2Spent Fuel Assemblies Ma terials Evaluated ......................... 3-1323.8.3Environments for the Spent Fuel Assemblies ........................ 3-1333.8.4Aging Effects Requiring Manage ment for the Spent Fuel Assemblies ............................................................................ 3-1343.8.5Aging Management Activities for the Spent Fuel Assemblies ............................................................................ 3-1373.8.5.1Aging Management Program

................................. 3-1373.9Periodic Tollgate Assessment

......................................................... 3-1383.10Conclusions ...................................................................................... 3-1403.11References ........................................................................................ 3-141APPENDIX A TIME-LIMITED AGING ANALYSIS (TLAA) AND OTHER SUPPORTING ANALYSES FOR THE RANCHO SECO ISFSI A.1Summary Description .......................................................................... A-1A.2Analyses ............................................................................................... A-2A.2.1Fatigue Analysis of the NUHOMS DSC Shell Assembly

.......... A-2A.2.1.1Atmospheric To Service Pressure Cycle ................... A-2A.2.1.2Normal Service Pressure Fluctuation ........................ A-2A.2.1.3Temperature Difference - Startup and Shutdown ..... A-3A.2.1.4Temperature Difference - Normal Service ................ A-3A.2.1.5Temperature Difference - Dissimilar Materials

.......... A-4A.2.1.6Mechanical Loads ..................................................... A-4 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page vi A.2.1.7Conclusion

................................................................. A-5A.2.2Fatigue Analysis of the NUHOMS MP187 Transfer Cask (MP187 TC)

............................................................................... A-5A.2.2.1Atmospheric To Service Pressure Cycle ................... A-5A.2.2.2Normal Service Pressure Fluctuation ........................ A-6A.2.2.3Temperature Difference - Startup and Shutdown ..... A-6A.2.2.4Temperature Difference - Normal Service ................ A-6A.2.2.5Temperature Difference - Dissimilar Materials

.......... A-7A.2.2.6Mechanical Loads ..................................................... A-7A.2.2.7Conclusion

................................................................. A-7A.2.3Boron Depletion, Gamma Irradiation, and Neutron Fluence Analysis ....................................................................... A-8A.2.3.1Boron-10 Depletion ................................................... A-8A.2.3.2Neutron Fluence and Gamma Exposure ................... A-8A.2.4Combustible Gas Generation .................................................... A-9A.3Conclusion ......................................................................................... A-10A.4References ......................................................................................... A-11APPENDIX B AGING MANAGEMENT PROGRAMS B.1Purpose ................................................................................................ B-1B.2Methodology ........................................................................................ B-2B.2.1Scope ........................................................................................ B-2B.2.2Aging Management Progr am Elements ..................................... B-2B.3DSC External Surfaces Aging Management Program ...................... B-4B.3.1Materials .................................................................................... B-4B.3.2Environment .............................................................................. B-4B.3.3Aging Effects Requiring Management ....................................... B-4B.3.4Program Description .................................................................. B-5B.3.5Evaluation and Technical Basis ................................................. B-5B.4HSM Aging Manageme nt Program ................................................... B-13B.4.1Materials .................................................................................. B-13B.4.2Environment ............................................................................ B-13B.4.3Aging Effects Requiri ng Management ..................................... B-13B.4.4Program Description ................................................................ B-14 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page vii B.4.5Evaluation and Techni cal Basis ............................................... B-14B.5Transfer Cask Aging Mana gement Program ................................... B-21B.5.1Materials .................................................................................. B-21B.5.2Environment ............................................................................ B-21B.5.3Aging Effects Requiri ng Management ..................................... B-21B.5.4Program Description ................................................................ B-21B.5.5Evaluation and Techni cal Basis ............................................... B-22B.6Basemat Aging Manage ment Program ............................................ B-25B.6.1Materials .................................................................................. B-25B.6.2Environments .......................................................................... B-25B.6.3Aging Effects Requiri ng Management ..................................... B-25B.6.4Program Description ................................................................ B-26B.6.5Evaluation and Techni cal Basis ............................................... B-26B.7Conclusion ......................................................................................... B-30B.8References ......................................................................................... B-31APPENDIX C CHANGES TO THE RANCHO SECO ISFSI FSAR FINAL SAFETY ANALYSIS REPORT C.1Introduction .......................................................................................... C-1C.2Proposed New Rancho Seco IS FSI FSAR Sections .......................... C-2C.2.1FSAR Section 9.8 - Ag ing Management .................................. C-2C.2.2FSAR Section 9.8.1 - Scoping Evaluation Methodology .......... C-2C.2.3FSAR Section 9.8.2 - Results of Scoping Evaluation .............. C-4C.2.4FSAR Section 9.8.3 - Agin g Management Review .................. C-5C.2.4.1FSAR Section 9.8.3.1 - Results of Aging Management Review - DSC ..................................... C-7C.2.4.2FSAR Section 9.8.3.2 - Results of Aging Management Review - HSM .................................... C-8C.2.4.3FSAR Section 9.8.3.3 - Results of Aging Management Review - Concrete Basemat .............. C-9C.2.4.4FSAR Section 9.8.3.4 - Results of Aging Management Review - Transfer Cask ................... C-10C.2.4.5FSAR Section 9.8.3.5 - Results of Aging Management Review - Spent Fuel Assemblies ..... C-11 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page viii C.2.5FSAR Section 9.8.4 - Summary of Time-Limited Aging Analyses ................................................................................. C-12C.2.5.1FSAR Section 9.8.4.1 - DSC Time-Limited Aging Analyses ................................................................. C-12C.2.5.2FSAR Section 9.8.4.2 - HSM Time-Limited Aging Analyses ................................................................. C-13C.2.5.3FSAR Section 9.8.4.3 - Tr ansfer Cask Time-Limited Aging Analyses

....................................................... C-13C.2.5.4FSAR Section 9.8.4.4 - ISFSI Basemat Time-Limited Aging Analyses .......................................... C-13C.2.6FSAR Section 9.8.5 - Summary of Aging Management Programs ................................................................................ C-14C.2.6.1FSAR Section 9.8.5.1 -

DSC Aging Management Program ................................................................. C-14C.2.6.2FSAR Section 9.8.5.2 -

HSM Aging Management Program ................................................................. C-14C.2.6.3FSAR Section 9.8.5.3 - TC Aging Management Program ................................................................. C-14C.2.6.4FSAR Section 9.8.5.4 - ISFSI Basemat Aging Management Program ............................................ C-15C.2.7FSAR Section 9.8.6 -Aging Management Tollgates .............. C-15C.3Proposed Revised Rancho Seco ISFSI FSAR Sections ................. C-17C.3.1FSAR Volume I, Section 1.1 - Introduction ............................ C-17C.3.2FSAR Volume I, Section 1.2 -General Description of the Installation .............................................................................. C-17C.3.3FSAR Volume I, Section 3.3.4.1.1 -Fuel-Only (FO) DSC Design Features ..................................................................... C-18C.3.4FSAR Volume I, Section 8.1.

1.9 -Thermal Cycling of the Cask ....................................................................................... C-18C.4References ......................................................................................... C-20APPENDIX D PROPOSED LICENSE/TECHNICAL SPECIFICATIONS CHANGES D.1Introduction .......................................................................................... D-1D.2Proposed License Condi tion Changes .............................................. D-2D.2.1Revised License Conditions ..................................................... D-2D.2.2New License Conditions ........................................................... D-2 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page ix D.3Proposed Technical Specifi cations Changes ................................... D-3D.4References ........................................................................................... D-4APPENDIX E ENVIRONMENTAL REPORT SUPPLEMENT E.1Introduction ........................................................................................... E-1E.1.1Purpose and Need for Proposed Action .................................... E-1E.1.2Proposed Action ........................................................................ E-1E.1.2.1Licensing History ....................................................... E-2E.1.2.2Operations ................................................................. E-3E.1.3Environmental Report Supplement Scope and Methodology .............................................................................. E-4E.1.4Applicable Regulatory Requirements, Permits, and Required Consultations ............................................................. E-5E.1.4.1Threatened and Endangered Species Consultation .. E-5E.1.4.2Historic Preservation Consultation ............................ E-6E.2Alternatives ........................................................................................... E-7E.2.1No-Action Alternative ................................................................. E-7E.2.2Other Alternatives ...................................................................... E-7E.2.2.1Ship Fuel to a Permanent Federal Repository........... E-7E.2.2.2Ship Fuel to an Offsite Interim Storage Facility ......... E-8E.3Affected Environment

........................................................................... E-9E.3.1Site Location .............................................................................. E-9E.3.2Land Use ................................................................................... E-9E.3.3Transportation ......................................................................... E-10E.3.4Geology, Soils, and Se ismology .............................................. E-10E.3.5Water Resour ces .....................................................................

E-11E.3.6Ecological Resources .............................................................. E-12E.3.6.1Natural Communities ............................................... E-12E.3.6.2Special-Status Species ........................................... E-12E.3.7Meteorology, Climatology, and Air Quality

............................... E-13E.3.8Noise ....................................................................................... E-13E.3.9Historical and Cultur al Resources ........................................... E-13E.3.10Visual and Scenic Resources .................................................. E-15E.3.11Demography and Soci oeconomics .......................................... E-16 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page x E.3.11.1Demography ............................................................ E-16E.3.11.2Environmental Justice ............................................. E-16E.3.11.3Socioeconomics ...................................................... E-17E.4Environmental Impacts ...................................................................... E-18E.4.2Impacts from Refurbishm ent and Constr uction ....................... E-18E.4.3Occupational and Public Radiological Health Impacts ............ E-19E.4.3.1Occupational Dose .................................................. E-19E.4.3.2Public Dose ............................................................. E-19E.4.4Other Operational Impacts ...................................................... E-20E.4.5Accident Impacts ..................................................................... E-22E.5Mitigation M easures ........................................................................... E-23E.6Environmental Measurement and Monitoring .................................. E-24E.7Summary of Environmen tal Consequences ..................................... E-25E.7.1Unavoidable Advers e Impacts ................................................. E-25E.7.2Irreversible and Irretrievable Commitment of Resources

......... E-25E.7.3Short-Term Uses, Maintenance, and Enhancement of Long-Term Productivity ........................................................... E-25E.8References .......................................................................................... E-26APPENDIX F ISFSI DECOMMISSION ING FUNDING PLAN UPDATE F.1Discussion / Status Update

.................................................................. F-1F.2References ............................................................................................ F-3 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page xi Acronym List (3 pages) Acronym Definition ACHP Advisory Council on Historic Preservation ACI American Concrete Institute AHSM Advanced Horizontal Storage Module ALARA As Low As Reasonably Achievable AMA Aging Management Activity AMID Aging Management INPO Database AMP Aging Management Program AMR Aging Management Review AR Action Report ASME American Society of Mechanical Engineers ASR Alkali-Silica Reaction ASTM American Society for Testing and Materials AWS Automated Welding System B&PVC Boiler and Pressure Vessel Code CAP Circular Area Profiling CAR Corrective Action Report CC Criticality Control CFR Code of Federal Regulations CISCC Chloride-Induced Stress Corrosion Cracking CISF Consolidated Interim Storage Facility CMTR Certified Material Test Report CNDDB California Natural Diversity Database CoC Certificate of Compliance CPP Cosumnes Power Plant CR Condition Reports CSAR Certified Safety Analysis Report DCS Dry Cask Storage DEF Delayed Ettringite Formation DOE Department of Energy DQ Deviations from Quality DSC Dry Shielded Canister DSS Dry Storage System ECN Engineering Change Notice EPRI Electric Power Research Institute Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page xii Acronym List (3 pages) Acronym Definition ESA Endangered Species Act FC Fuel with Control Components FC-DSC Fuel with Control Components DSC FF Failed Fuel FF-DSC Failed Fuel DSC FO Fuel Only FO-DSC Fuel Only DSC FSAR Final Safety Analysis Report GALL Generic Aging Lessons Learned GEIS Generic Environmental Impact Statement GM General Manager GTCC Greater-Than-Class-C (waste) GW Underground (below grade level) HAZ Heat Affected Zone HSM Horizontal Storage Module HT Heat Transfer IN Information Notice ISFSI Independent Spent Fuel Storage Installation ITS Important-to-Safety LRA License Renewal Application MAPS Managing Aging Processes in Storage MRSA Manager, Rancho Seco Assets NCIC North Central Information Center NCR Non-Conformance Report NITS Not Important-to-Safety NMFS National Marine Fisheries Service NRC U.S. Nuclear Regulatory Commission NSP Neutron Shield Panels OD Outer Diameter OE Operating Experience PB Pressure Boundary PCI Precast/Prestressed Concrete Institute PDQ Potential Deviations from Quality PEO Period of Extended Operation Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Page xiii Acronym List (3 pages) Acronym Definition PSDAR Post-Shutdown Decommissioning Activities Report PTZ Pan-Tilt-Zoom QA Quality Assurance RSNGS Rancho Seco Nuclear Generating Station RE Retrieval (of spent fuel canister from storage cask) SCC Stress Corrosion Cracking SFA Spent Fuel Assembly SH Radiation Shielding SHPO State Historic Preservation Office SS Structural Support SSCs Structures, Systems, and Components SER Safety Evaluation Report SMUD Sacramento Municipal Utility District TC Transfer Cask TLAA Time Limited Aging Analysis TMI-2 Three Mile Island, Unit 2 TN Transnuclear TNW Trans Nuclear West TS Technical Specifications UFSAR Updated Final Safety Analysis Report USC United States Code USFWS U.S. Fish and Wildlife Service UT Ultrasonic Testing VDS Vacuum Drying System WCS Waste Control Specialists XRF X-ray Fluorescence

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-i CHAPTER 1 GENERAL INFORMATION CONTENTS 1.1 Introduction

...................................................................................................... 1-1

1.2 Application

Format and Content .................................................................... 1-2

1.3 Facility

Description ......................................................................................... 1-4

1.3.1 Facility

Description .................................................................................. 1-4

1.4 Information

Required by 10 CFR 72.22 .......................................................... 1-5 1.4.1 Name of the Applicant............................................................................. 1-5

1.4.2 Address

of the Applicant ......................................................................... 1-5

1.4.3 Address

of the Rancho Seco ISFSI ........................................................ 1-5

1.4.4 Description

of Business or Occupation of the Applicant.......................... 1-5

1.4.5 Organization

and Management of the Applicant ..................................... 1-5

1.4.6 Financial

Information .............................................................................. 1-7

1.5 References

....................................................................................................... 1-8

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-1

1.1 Introduction

Sacramento Municipal Utility District (SM UD) has prepared this application for renewal of the Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, [1-11]. The original 20-year Ranc ho Seco ISFSI license will expire on June 30, 2020. This application requests renewal of the ISFSI license for an

additional 40-year period of extended operation (PEO). This application is submitted in accordance with 10 CFR 72.42 and includes the applicable general, technical, and environmental s upporting information. The format and content is also consistent with NEI 14-03, Revision 2, Format, Content and Implementation Guidance for Dr y Storage Operations-Based Aging Management, [1-10], which was submitt ed by NEI to the NRC in December 2016 for review and endorsement. This r enewal application is limited in scope to those items required to be addressed for license renewal. No technical changes to the license are being requested; however, two editorial changes

are being requested, as ex plained in Appendix D. The Rancho Seco ISFSI is designed to provide dry storage capacity for 100%

of the Rancho Seco spent fuel asse mblies (SFAs) and Greater than Class C (GTCC) waste in order to complete full plant dismantlement. The waste is

stored in 21 spent fuel canisters and 1 GTCC canister, which is described in more detail elsewhere in the LRA.

In accordance with NUREG-1927, Rev 1, Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage Syst em Licenses and Certificates of Compliance, [1-2], this renewal applicat ion is based "on the continuation of the existing licensing basis throughout the PEO and on the maintenance of the intended safety functions of the stru ctures, systems, and components (SSCs) important to safety." The existing licensing basis consists primarily of the following: A. The ISFSI Final Safety Analysis Report (ISFSI FSAR), Revision 6, Rancho Seco ISFSI Final Safety Analysis Report [1-7], B. The ISFSI license, SNM-2510, and asso ciated Technical Specifications (TS), and Safety Evaluati on Report (SER) [1-11], C. Safety Evaluation Reports (SERs) issued for the Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, original license (denoted as Amendment 0 [1-3

], and Amendments 1 through 3

[1-4] [1-5] [1-6], D. NRC Orders, E. Exemptions, and F. Other docketed licensing correspondence.

Section 2.2.2 provides a summary of each amendment and the NRC orders and exemptions.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-2 1.2 Application Format and Content The format and content of this application includes information required by 10 CFR Part 72, Licensing Requirement s for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactiv e Waste, and Reactor-Related Greater Than Class C Waste, [1-1] and is cons istent with the guidance contained in the Nuclear Regulatory Commission's (NRC's) NUREG-1927 [1-2].

Chapter 1, General Information: Th is chapter provides: (1) a general description of the Rancho Seco ISFS I; (2) information on the format and content of this application, and; (3) lic ensee information as required by 10 CFR 72.22. Chapter 2, Scoping Evaluat ion: This chapter provi des a description of the methodology used to identify the SSC s, and subcomponents of the Rancho Seco ISFSI that are within the scope of the renewal. This methodology is based on the two-step process described in NUREG-1927 [1-2].

Chapter 2 also provides a summary of the results of the scoping evaluation based on Revision 6 of the ISFSI FSAR , Rancho Seco ISFSI Final Safety Analysis Report [1-7] which reflects t he current configuration of the Rancho Seco SSCs resulting from Amendments 1 through 4 to the SNM-2510 license and changes implemented under the provisions of 10 CFR 72.48.

Chapter 3, Aging Management Review: This chapter provides the methodology used and the results of t he aging management review (AMR) of the SSCs and subcomponents of the Rancho Seco ISFSI, based on the guidance provided in NUREG-1927 [1-2]

and NEI 14-03, Format, Content and Implementation Guidance for Dr y Storage Operations-Based Aging Management [1-10]. The AMR document ed in Chapter 3 identifies the materials and environments for those SSCs and associated subcomponents determined to be within the renewal scope in Chapter 2. This is accomplished by reviewing the drawings and the desi gn basis included in the current ISFSI FSAR [1-7] Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Techni cal Specifications and Safety Evaluation Report

[1-11]. Once the component material

/ environment combinations are determined, potential aging effects r equiring management are identified and evaluated based on engineer ing literature, relat ed industry research information, and existing operating experience (OE). Chapter 3 also provides a summary of the OE accumulated over the last 20 years for the Standardized NUHOMS System. The information gleaned fr om this OE is used to identify potential aging effects t hat require management.

After applicable aging effect s are identified, it is determined whether they can be addressed by either time-limited agi ng analysis (TLAA), or if they will require an aging management program (AMP).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-3 Appendix A: This appendix pr ovides a description and results of the TLAAs and other supplemental evaluations prepared for the in-scope SSCs.

Appendix B: This appendix provides a description of the AMPs to be implemented during the PEO.

Appendix C: This appendi x provides the recommended changes to the Rancho Seco ISFSI FSAR for SNM-2510 renewal.

Appendix D: This appendi x provides the recommended changes to the Rancho Seco ISFSI license and TS.

Appendix E: This appendix pr ovides the supplement to the Rancho Seco ISFSI Environmental Report. Appendix F: This appendix addresses the Rancho Seco ISFSI Decommissioning Funding Plan Update.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-4 1.3 Facility Description 1.3.1 Facility Description The Rancho Seco ISFSI is located wit hin the Owner Controlled Area of the Rancho Seco site, which is owned and operated by SMUD. The Rancho Seco site comprises approximately 2480 acres in Sacramento County, California.

The Rancho Seco ISFSI pad is approximat ely 225 feet by 170 feet in size, and contained within an a pproximately 14 acre licensed area. The storage technology used at the Rancho Seco ISFSI is a NUHOMS canister-based system for the dry storage of irradiated SFAs consisting of a dry shielded canister (DSC) and a reinforced concrete horizontal storage module (HSM). Additional SSCs incl ude a transfer cask (TC) and other canister transfer and auxiliary equip ment used to support DSC loading and transfer operations.

The Rancho Seco ISFSI provides for th ree types of DSC design: Fuel Only DSC (FO-DSC), Fuel with Control Components DSC (FC-DSC) and Failed Fuel DSC (FF-DSC). The Rancho Se co FO, FC and FF DSC design are based on the Standardized NUHOMS

-24P DSC design, NUH-003, Certified Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, Revision 4A [1-8]

except that the FO and FC DSCs include fixed neutron absorber s in the design of the DSC basket.

Also provided is one canister for st orage of Greater th an Class C (GTCC) waste consisting of solid, reactor-related waste such as activated reactor

internals and in-cor e instrumentation.

The Rancho Seco HSM design is similar to the Standardized NUHOMS HSM design [1-8]. The HSM is a low profile, modular, reinforced concrete structure whose primary functions are to provide a means for passively removing spent fuel decay heat, provide structural s upport and environmental protection to the loaded DSC, and provide radiat ion shielding protection. The TC, designated as the NUHOMS

- Transfer Cask (TC), is certified for offsite transport [1-9]. The TC facilitated fuel loading/unloading as well as onsite transfer of a loaded DSC. In addi tion to these primary components, the ISFSI also made use of auxiliary equipment consisting of a vacuum drying system (VDS), TC lifting yoke, DSC automatic welding system (AWS),

hydraulic ram system and a transfer trailer equipped with a TC skid. No more DSCs are to be loaded at the Rancho Seco ISFSI and thus the TC, VDS, AWS and other auxiliary equipm ent will not be used at the ISFSI for any loading operations. However, to assure canister retrievability, the TC is considered in-scope for license renewal, as discussed in Chapter 2. A more complete system description, in cluding supporting design basis, is contained in the Rancho Seco ISFSI FSAR, Revision 6 [1-7].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-5 1.4 Information Required by 10 CFR 72.22 1.4.1 Name of the Applicant Sacramento Municipal Utility District. 1.4.2 Address of the Applicant 6301 S Street, Sacrament o, California 95817. 1.4.3 Address of the Rancho Seco ISFSI 14440 Twin Cities Road, Herald, California 95638. 1.4.4 Description of Business or Occupation of the Applicant SMUD was formed under the provisions of California's Municipal Utility District Act following a vote of the citiz ens of Sacramento in 1923. SMUD began operations in 1946 and is now the sixt h largest community-owned electric utility in the nation. SMUD is responsible for the acquisition, generation, transmission and distribution of electric power to its service area with a population of approximatel y 1.4 million - most of Sacramento County and small, adjoining portions of Placer and Yolo counties. 1.4.5 Organization and Management of the Applicant SMUD's Board of Directors is the policy-making body, which has ultimate responsibility for the Rancho Seco ISFSI license. The Chief Executive Officer and General Manager (GM) reports directly to the Board of Directors. The GM, through the Chief Energy-Delivery Officer, and Director, Power Generation has corporate responsibility for overall safety and management of the facility. The GM shall take any measures needed to ensure acceptable performance of the staff in managing, maintaining, and providing technical support to the fa cility to ensure nuclear safety. The Chief Energy-Delivery Officer is re sponsible for the overall Rancho Seco facility and the Rancho Seco organization. This includes ensuring the safe storage of spent nuclear fuel and GTCC waste, ensur ing effective day-to-day management, and maximizing the effectiveness of nuclear policies and procedures.

The Director, Power Generation is responsible for ensuring effective management of the licensed facilities, and ensuring the safe storage of spent nuclear fuel and GTCC waste.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-6 The Manager, Rancho Seco Assets (MR SA) is the lead SMUD representative at the Rancho Seco site and is responsible for all facets of day-to-day management of the licensed facilities. The MRSA is responsible for site security during routine, emergency, and contingency operations. The MRSA is also responsible for the implementat ion and maintenanc e of the Physical Protection Plan.

The MRSA is the Radiation Protection Manager and implements the Radiation Protection program. The MRSA is responsible for health physics surveillance, personnel monitoring and record keeping , radwaste management, emergency preparedness and environmental monitoring. The MRSA utilizes available SMUD and contract personnel to resolve engineering, design, and other technical issues required to support compliance with the 10 CFR Part 72 ISFSI license. The MRSA is responsible for ensuring that management of the Rancho Seco ISFSI is conducted in accordance with Technical Specifications, federal and state regulations, Physical Protection Plan, and plan t procedures and has the primary responsibility for cask and canister handling operations.

Staff under the direction of the MRSA ar e trained and qualifie d, as described in Volume I, Section 9.3, of [1-7]

to ensure that ISFSI operations are conducted in a safe and efficient manner. As required by site procedures, personnel under the direction of the MRSA check, analyze, and log system parameters, and initiate corrective actions when abnormal conditions exist.

These personnel perform initial fire response and notifications in accordance with the fire prot ection program.

Individuals on shift are trained and qualifi ed to implement appropriate radiation protection procedures.

Power Generation Regulatory Compliance Program is responsible for ensuring that the quality assurance program is implemented in accordance with regulatory requirements. The Power Generation Regulatory Compliance organization has the authority to take any issue regarding the quality of program management at Rancho Seco to the General Manager and the Chief Energy-Delivery Officer.

Emergency Preparedness is responsible fo r maintaining and administering the Emergency Plan under the direction of the Manager, Rancho Seco Assets.

The Emergency Preparedness staff trains all personnel implementing the Emergency Plan as well as directing drills and other activities necessary to maintain regulatory compliance. The Emergency Plan is outside the scope of this LRA per NUREG-1927 [1-2].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-7 Rancho Seco ISFSI Security is res ponsible for providing personnel, as required, to implement the Physical Protection Plan. Security is also responsible for staffing the security f unctions, as required, during routine, emergency and contingency conditions at the facility. All of the Security functions are staffed by contract personnel under the direction of the Manager, Rancho Seco Assets. Security is outsi de the scope of LRA in accordance with NUREG-1927 [1-2]. 1.4.6 Financial Information As required by 10 CFR 72.22(e), SMUD will remain financially qualified to carry out the activities associated with spent fuel storage at the Rancho Seco ISFSI throughout the PEO. Governed by an elected board of directors (Board), SMUD has the rights and powers to fix rates and charges for commodities and services it furnishes, incur indebtedness, and issue bonds or other obligations.

The estimated operating costs for the R ancho Seco ISFSI specific license are conservatively estimated to be $200M in 2017 dollars for the duration of the 40-year license PEO, or approximately $5M per year. There are no plans to expand the capacity of the Rancho Seco ISFSI. SMUD has an annual budget in excess of $1.0 billion and maintains an AA- credit rating. This information provides reasonable assurance of SM UD's ability to obtain the necessary funds to cover the operating costs over the PEO.

The Rancho Seco Decommissioning Funding Plan Update is provided in Appendix F. SMUD provides financial assurance for the decommissioning of the Rancho Seco ISFSI using the exter nal sinking fund method. Contributions to the trust fund are based upon a site-specific cost estimate that includes license termination activities includi ng decommissioning of the Part 50 Phase II licensed area and the Part 72 ISFSI licensed area. The Rancho Seco decommissioning trust fund was considered fully funded in 2008. At this time, no future contributions are planned, but SMUD will continue to perform decommissioning cost estimates and com pare the results with the available funds in the decommissioning trust. As a municipal utility, SMUD has the ability to recover costs of service, including decommissioning, through rates, thereby providing reasonable assurance that sufficient funding is available for decommissioning.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 1 - General Information Page 1-8 1.5 References 1-1 U.S. Nuclear Regulatory Commission, 10 CFR Part 72, "Lic ensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater T han Class C Waste," Code of Federal Regulations. 1-2 U.S. Nuclear Regulatory Commissi on, NUREG-1927 Revision 1, "Standard Review Plan for Renewal of Spent F uel Dry Cask Storage System Licenses and Certificates of Compliance," June 2016. 1-3 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, Amendment 0, June 2000, (Docket 72-11). 1-4 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, Amendment 1, April 2005 (Docket 72-11). 1-5 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, Amendment 2, April 2005 (Docket 72-11). 1-6 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, Amendment 3, August 2009 (Docket 72-11). 1-7 Rancho Seco ISFSI Final Safety Analysis Report, Revision 6, August 2016 (Docket 72-11). 1-8 Vectra Technologies, Inc., "NUH-003, Certified Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, Revision 4A," June 1996 (Docket No. 72-1004). 1-9 U.S. Nuclear Regulatory Commission, Ce rtificate of Compliance for Radioactive Material Packages, Certificate Number 9255, Revision 13, issued to TN Americas LLC, NUHOMS MP187 Multi-Purpose Cask, approved January 30, 2017. 1-10 Nuclear Energy Institute, "Format, Content and Implementation Guidance for Dry Storage Operations-Based Aging Management," NEI 14-03 Revision 2, 2016. 1-11 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510, including Technical Specifications and Safety Evaluation Report, Amendment No. 4, November 2017 (Docket 72-11).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-i CHAPTER 2 SCOPING EVALUATION CONTENTS Introduction

...................................................................................................... 2-12.1Scoping Evaluation Process and Methodology ............................................ 2-22.2 2.2.1Licensing Basis for Retrievabili ty of Rancho Seco SFAs ........................ 2-32.2.2Documentation Sources Used for Scoping ............................................. 2-3Results of Scoping Evaluation ....................................................................... 2-62.3 2.3.1Structures, Systems, and Co mponents within the Scope of Rancho Seco ISFSI License Renewal .................................................... 2-62.3.2SSCs not within the Scope of Rancho Seco ISFSI License Renewal .................................................................................................. 2-72.3.2.1Fuel Transfer and Auxiliary Equipment...................................... 2-72.3.2.2Approach/Apron Slabs............................................................... 2-82.3.2.3Miscellaneous Equipment

.......................................................... 2-82.3.2.4GTCC waste .............................................................................. 2-8Detailed Description of Rancho Seco ISFSI Components and 2.4Subcomponents ............................................................................................ 2-102.4.1DSCs .................................................................................................... 2-102.4.1.1Fuel-Only (FO) DSC ................................................................ 2-112.4.1.2Fuel with Control Components (FC) DSC

................................ 2-112.4.1.3Failed Fuel (FF) DSC .............................................................. 2-122.4.1.4Greater Than Class C Waste (GTCC) DSC ............................ 2-132.4.2HSM ...................................................................................................... 2-132.4.3NUHOMS- MP187 Transfer Cask ....................................................... 2-142.4.4Spent Fuel Assemblies ......................................................................... 2-152.4.4.1Fuel Rods (Cladding, End Caps/Plugs) ................................... 2-162.4.4.2Guide Tubes ............................................................................ 2-162.4.4.3Instrumentation T ube Assembly .............................................. 2-162.4.4.4Spacer Grid Assemblies .......................................................... 2-162.4.4.5Lower End Fitting (and rela ted subcomponents) ..................... 2-172.4.4.6Upper End Fitting (and rela ted subcomponents) ..................... 2-172.4.5ISFSI Basemat ...................................................................................... 2-17 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-ii 2.4.6Approach Slab ...................................................................................... 2-17References ..................................................................................................... 2-182.5 LIST OF TABLES Table 2-1 Scoping Evaluation of Rancho Seco ISFSI SSCs ................................. 2-20Table 2-2 B&W 15x15 Mark B SFA Characte ristics Allowed for Storage at Rancho Seco ISFSI .............................................................................. 2-22Table 2-3 Summary of Contents Allowed for Storage in GTCC Canister .............. 2-23Table 2-4 Listing of Amendments to Rancho Seco Materials License SNM-2510 and Rancho Seco ISFSI Active Exemptions ................................ 2-24Table 2-5 Listing of Rancho Seco ISFSI 10 CFR 72.48 Evaluations for the Period 2000-2002 [2-13] ....................................................................... 2-25Table 2-6 Scoping Evaluation Results for DSCs ................................................... 2-26Table 2-7 Scoping Evaluation Results for HSM .................................................... 2-32Table 2-8 Scoping Evaluation Re sults for TC ....................................................... 2-35Table 2-9 Scoping Evaluation Results for SFAs ................................................... 2-38Table 2-10 List of Rancho Seco ISFSI Drawings .................................................... 2-39Table 2-11 Loading Overview at Rancho Seco Nuclear Generating Station

........... 2-40 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-1 Introduction

2.1 Chapter

2 describes the evaluation pr ocess and methodology used to identify the structures, systems, and components (SSCs) and associated subcomponents of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) that are within the scope of the Rancho Seco Independent

Spent Fuel Storage Installation Mate rials License SNM-2510, including Technical Specifications and Safety Evaluation Report [2-7] renewal. In accordance with the guidance contained in NUREG-1927, Rev 1 Standard

Review Plan for Renewal of Spent F uel Dry Cask Storage System Licenses and Certificates of Compliance [2-1], the first step of the renewal process is the performance of a scoping evaluation. The scoping evaluation identifies the

ISFSI SSCs that are within the scope of renewal. The second step is the aging management review (AMR), described in Chapter 3, whereby the SSCs that are identified to be within the scope of renewal are subsequently subjected to evaluation for potential degradation due to aging effects.

A description of the scoping evaluation process and methodology is provided in Section 2.2. The results of the scoping evaluation are provided in Section 2.3. A detailed description of the Rancho Seco ISFSI SSCs and associated subcomponents within the scope of renew al is provided in Section 2.4.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-2 Scoping Evaluation Process and Methodology 2.2This section describes the scoping ev aluation process and methodology used to determine the SSCs and associated subcomponents that are within the scope of renewal. The scoping evaluatio n is performed based on the two-step process described in Section 2.4.2 of NUREG-1927 [2-1].

The first step is a screening evaluation to determine which SSCs are within the scope of the renewal. In accordance with the NUREG-1927 [2-1] guidance, SSCs are considered to be within the sc ope of the renewal, if they satisfy either of the foll owing two criteria:

Criterion 1: The SSC is classified as important-to-safety (ITS) as it is relied on to perform one of the following functions: 1. Maintain the conditions required by the regulations, specific license or CoC to store spent fuel safely. 2. Prevent damage to the spent f uel during handli ng and storage. 3. Provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved wit hout undue risk to the health and safety of the public.

These SSCs ensure that important-to-safety functions are met for (1) criticality, (2) shielding, (3) confinement, (4) heat transfer, (5) structural integrity, and (6) retrievability.

Criterion 2: The SSC is classified as not important-to-safety (NITS), but according to the licensing basis, its failure could prevent fulfillment of a function that is ITS, or its failure as a support SSC could prevent fulfillment of

a function that is ITS.

The second step involves further review of the SSCs that are determined to be within the scope of the renewal to identify and describe the subcomponents and subcomponent parts that support the in tended function or functions of the SSCs. The intended functions of the SSC subcomponents (and the corresponding abbreviations used to denote this function) include: Providing criticality contro l of the spent fuel (CC), Providing heat transfer (HT), Directly or indirectly main taining a pressure boundary (PB), Providing radiation shielding (SH), Providing structural support, functional support, or both, to SSCs that are ITS (SS) and Providing retrieval of spent fuel canister from the storage cask (RE).

The scoping of the spent fuel assembli es (SFAs) authorized for storage at the Rancho Seco ISFSI has been addressed as specified in Section 2.4.2.1 of NUREG-1927 [2-1].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-3 2.2.1 Licensing Basis for Retrievability of Rancho Seco SFAs A brief discussion is presented here to clarify the licensing basis for Rancho Seco SFA retrievability. Rancho Seco Independent Spent Fuel Storage Installation Final Safety Analysis Report (ISFSI FSAR) [2-2], Section 4.2.2.1.12, states:

"Retrievability: By using a transportable storage system, the st ored fuel can be transferred directly to a DOE facility after DOE acceptance of the fuel. The steps involved in placing a loaded vertical cask on the transfer trailer and transferring the cask from t he trailer to a rail car and preparing it for transport are covered in the NUHOMS

-MP187 Multi-Purpose Transportation Package Safety Analysis Report, Document No. NUH-05-151 submitted in accordance with 10 CFR 71." The NRC accepted this canister-based approach to retrievability as meeting Interim Staff Guidance, ISG-2, Revision 0, Fu el Retrievability [2-14]. It is to be noted that at the time of SNM-2510 approval in June 2000, ISG-2, Revision 0 [2-14] was applicable, while, Interim Staff Guidance, ISG-2, Revision 1, Fuel Retrievability [2-15] was not issued until February 2010. As stated in Section 4.3.7 of the original SNM-2510 SER [2-4]: The design criteria with regard to retrieval considerations for SSCs

important to safety are governed by 10 CFR 72.122(l). As stated in ISG-2, as long as the design of the storage system has a method to repackage into a transportation cask for shipment offsite for further processing or disposal, a facility meets the requirements of 10 CFR

72.122(l). -therefore, the staff considered that the requirements of

10 CFR 72,122(l) are met by the design of the Rancho Seco ISFSI-.The Rancho Seco ISFSI m eets the guidance of ISG-2 for fuel retrievability. 2.2.2 Documentation Sources Used for Scoping In accordance with NUREG-1927 [2-1

], the renewal is based on the continuation of the existing licensing bas es throughout the period of extended operation (PEO) and on the maintenance of the intended safety functions of the SSCs important to safety. Accordingl y, the sources of information reviewed in the scoping evaluation are those that describe the licensing basis and the intended safety functions of the ITS SSCs.

The current Rancho Seco ISFSI licensi ng bases consists primarily of the following: Rancho Seco ISFSI F SAR, Revision 6 [2-2], Rancho Seco Independent Spent Fuel Storage Installation Materials License SNM-2510, Amendment 4 including Technica l Specifications and Safety Evaluation Report [2-8],

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-4 Safety Evaluation Reports (SERs) issued for the Rancho Seco Independent Spent Fuel Storage Insta llation Materials License SNM-2510, original license (denoted as Am endment 0) [2-4] and Amendments 1 through 3 [2-5] [2-6] [2-7], Exemptions [2-10] [2-11], NRC Orders, Docketed licensing correspondence, as applicable. The Rancho Seco License SNM-2510, Amendment 4 [2-8] encompasses the initial approved license (Amendment

0) and subsequently approved amendments (Amendment 1 through Amendment 4).

A brief summary of the contents of eac h amendment to Rancho Seco license SNM-2510 is presented in Table 2-4 and summarized below: Amendment 1 [2-5] deleted annual e ffluent reporting requirement of Technical Specification 5.5.2, Amendment 2 [2-6] authorized storage of greater than class C (GTCC) waste at Rancho Seco ISFSI in a GTCC dry shielded canister (DSC), Amendment 3 [2-7] approved the retr ospective re-classification of six intact SFAs in five FC DSCs as damaged fuel, and Amendment 4 [2-8] authorized posse ssion of a Sr90 source under the Rancho Seco 10 CFR Part 72 license.

Amendment 1 is related to record keepi ng and reporting. Amendment 4 adds a source to the allowed material to be possessed under the 10 CFR Part 72 license. Therefore, Amendments 1 and 4 do not have any impact on the renewal of Rancho Seco Materials License SNM-2510. Amendments 2 and 3 are addressed in this LRA.

Also listed in Table 2-4 are two active exemptions to Rancho Seco Materials License, SNM-2510. The approved exempti ons from 10 CFR 72.72(d) [2-10], and from 10 CFR 72.44(d)(3) [2-11]

are related to recordkeeping and reporting, and remain necessary. However, they do not have any impact on the renewal of Rancho Seco Materials License SNM-2510.

The two security-related orders remain in effect and have no impact on license renewal. In addition, the changes to the Rancho Seco ISFSI components and subcomponents implemented under the provisions of 10 CFR 72.48 are documented in the Rancho Seco ISFSI Bi ennial Reports for the periods from 2000-2016. The 72.48 changes that impact ed the configuration of Rancho Seco ISFSI SSCs are those documented in Rancho Seco ISFSI Biennial

Report for the period 2000-2002, [2-13]. These changes are listed in Table 2-5.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-5 The updated Rancho Seco ISFSI FSAR [2-2] is the primary source used in the scoping evaluation. It incorporates the first three appr oved amendments to Rancho Seco license SNM-2510, as well as the changes impl emented to the Rancho Seco ISFSI SSCs under the provisions of 10 CFR 72.48.

As documented in Volume 1, Section 3.

4.1 of the Rancho Seco ISFSI FSAR [2-2], the safety classifications of t he Rancho Seco SSCs are similar to those of the Standardized NUHOMS System SSCs listed in Section 3.4 of the CSAR, NUH-003, Certified Safety A nalysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, Revision 4A [2-3]. Table 3.4-1 of the CSAR summa rizes the safety classification of the major Standardized NUHOMS System components. The HSM, DSC and TC drawings, contained in Volume 4 of the ISFSI FSAR [2-2], list all the associated subcomponents of these SSCs, their quality categories and their materials of construction. The drawings listed in Table 2-10 provide a roadmap to the detailed description of the Rancho Seco ISFSI SSCs presented in Section 2.4. These documents were reviewed to determine the SSCs and associated subcomponents that meet either Scoping Criterion 1 or 2. Based on this review, those SSCs and subcomponents t hat perform or support any of the

identified intended functions , identified in Section 2.3.1, are determined to require an AMR, which is presented in Chapter 3. Those SSCs and associated subcomponents that do not perform or support one or mo re of these intended safety functions are excluded from further evaluation in the AMR. Section

2.3.2 identifies

those SSC s that are out-of-scope.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-6 Results of Scoping Evaluation 2.3This section discusses the renewal scoping results. Table 2-1 summarizes the results of the scoping evaluation, list ing the SSCs that are identified to be within the scope of renewal and the cr iterion upon which this determination is based. Detailed scoping evaluation results for each SSC and associated subcomponents have been generated based on the current revision of the Rancho Seco ISFSI FSAR [2-2]. These detailed scoping evaluation results, along with AMR results, are presented in Table 2-6 (for DSCs

), Table 2-7 (for HSMs), Table 2-8 (for TC), and Table 2-9 (for SFAs). The scoping results presented in these tables represent a consolidated scoping evaluation of the storage system as currently designed and licensed. The source drawings, upon which these detailed scoping tables are based, are listed in Table 2-10.

Note: As discussed in Section 2.4.1.4, t he external design characteristics of the GTCC waste containing DSC are ident ical to the fuel-containing DSCs (FO/FC/FF DSCs). Hence, the term "DSC" has been used to address both the fuel and the GTCC DSCs in this application, unless a distinction is necessary to address a specific charac teristic of the GTCC DSC. 2.3.1 Structures, Systems, and Compo nents within the Scope of Rancho Seco ISFSI License Renewal The SSCs determined to be within the scope of Rancho Seco ISFSI license

renewal under Criterion 1 are the DSC, HSM, and TC. The subcomponents of the in-scope SSCs and their intended functions are identified in Table 2-6 (DSCs), Table 2-7 (HSMs), and Table 2-8 (TCs). A detailed description of the Criterion 1 in-scope SSCs and associat ed subcomponents, including their intended functions, is presented in Section 2.4.

At the Rancho Seco ISFSI, all spent fuel and GTCC waste is currently in dry storage and no more DSCs are to be l oaded at Rancho Seco ISFSI. Hence, the TC and the auxiliary equipment, descr ibed in Sections 2.3.2 and 2.4.3, respectively, will not be used for any loading operations. The only remaining TC safety function during the PEO is re trieval of the DSCs from the HSMs prior to offsite shipment of the DSC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-7 The SFAs, which are stored in an inert and sealed environment and are supported inside the FO/FC/FF DSC basket assembly, are also determined to be within the scope of renewal consistent with NUREG-1927, Section 2.4.2.1.

Table 2-2 provides a summary of the c haracteristics of the SFAs allowed for storage at the Rancho Seco ISFSI. Tabl e 2-11 provides an overview of the SFAs loaded at Rancho Seco Nuclear Generating Station (RSNGS). Table 2-3 summarizes the radioactive waste contents allowed for storage in the GTCC DSC. The in-scope subcom ponents of the SFAs and t heir intended functions are identified in Table 2-9. NITS subcomponents that m eet Criterion 2 are also within the scope of renewal. For these NITS subcomponents, the intended ITS function that could be prevented from being fulfilled is identified in Table 2-6, Table 2-7, Table 2-8, and Table 2-9. A detailed description of the Criterion 2 in-scope SSCs and associated subcomponents, including their intended functions, is presented in Section 2.4.

The basemat is a NITS structure. Sinc e settlement of the basemat may affect retrievability of the DSC, the basemat is included wit hin the scope of renewal (monitoring for basemat settlement). Ther e are no other credible failure modes of the basemat that could prevent the HSM safety functions from being fulfilled. The accessible above-grade and inaccessible below-grade areas of

the storage pad are within the scope of renewal. 2.3.2 SSCs not within the Scope of Rancho Seco ISFSI License Renewal SSCs that are not in the scope of renewal include the fuel transfer and auxiliary equipment. These components ar e classified as NITS and do not meet scoping Criterion 2. Also not within the scope are those NITS subcomponents of the DSC, HSM and TC that do not m eet Criterion 2 because their failure does not prevent fulfillment of an ITS function.

Explanation or justification for these items is provided in Table 2-6, Table 2-7, and Table 2-8 or the DSCs, HSMs, and TCs, respectively. The GTCC waste as described in Section 2.3.2.4 is also not in the scope of renewal. 2.3.2.1 Fuel Transfer and Auxiliary Equipment Fuel transfer equipment necessary for ISFSI operations includes the lifting yoke, the primary mover and transfer tr ailer, skid positioni ng system, hydraulic ram system, ram support assembly, and the cask support skid. Auxiliary equipment used at the Rancho Seco ISFSI to facilitate canister loading, draining, drying, inerting, and sealing operations include the following systems:

the vacuum drying system, automatic welding equipment, the waste processing system, the security system, and the temperature monitoring

system.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-8 At the Rancho Seco ISFSI, all of the spent fuel and GTCC from plant operations is currently in dry storage and no more DS Cs are to be loaded at the Rancho Seco ISFSI. Hence, the fuel transfer and auxiliary equipment listed above will not be used for any loading operations.

The fuel transfer and auxiliary equipment are NITS items and their failure would not prevent fulfilment of an y intended function supporting storage operations. The auxiliary equipment used to retrieve the DSCs from the HSMs

is subject to standard maintenance and r epair prior to use. Hence, the fuel transfer and auxiliary equipment does not meet scoping Criterion 2 and, therefore, are not in the scope of renewal. 2.3.2.2 Approach/Apron Slabs The approach or apron slab is a NITS re inforced concrete structure, designed and constructed to Rancho Seco site s pecific conditions. The slab provides access to the HSM but does not support the HSM. It does not provide a safety function, and its failure would not prevent fulfillment of a safety function of the HSM loaded with a DSC.

The transport trailer used to retrieve the DSCs has features that enable adjustment to any credible different ial settlement between the basemat and the apron slab. The apron slab can be r epaired if needed to maintain access to the HSM during DSC retrieval. 2.3.2.3 Miscellaneous Equipment ISFSI miscellaneous equipment (e.g., IS FSI security fences and gates, lighting, lightning protecti on, communications, and monitoring equipment) is NITS and its failure would not prevent fulfillment of any ITS function. Security equipment is excluded from the scope of license renewal consistent with Section 1.2 of NUREG-1927, [2-1]. 2.3.2.4 GTCC waste Table 2-3 summarizes the radioactive waste contents allowed for storage in the GTCC DSC. GTCC waste is non-fuel related material generated as a result of plant operations and decommi ssioning. This waste includes such items as incore components and instrum ent tips, activated metal from core support structures, and small reactor-related miscellaneous parts resulting from the reactor vessel internals segmentation/decommissioning process

[2-2].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-9 The GTCC DSC provides confinement of radioactive materials, encapsulates the waste in an inert helium environm ent, and together with a TC or HSM, provides biological shielding during GTCC DSC closure, transfer and storage operations. Since the GTCC waste does not include any spent fuel assemblies or fissionable material, the GTCC DS C basket is entirely NITS. The GTCC waste does not directly perform any safety function associated with criticality, shielding, confinement, heat transfer, stru ctural integrity or retrievability nor would its failure prevent fulfilment of any intended function supporting storage operations. As listed in Table 2-1, the GTCC waste does not meet Scoping Criterion 1 or Scoping Crit erion 2 and, therefore, it is not in the scope of renewal.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-10 Detailed Description of Rancho Seco ISFSI Components and Subcomponents 2.4 This section provides a detailed de scription of the Rancho Seco SSCs and associated subcomponents, including ma terials of construction and intended functions. A listing of the drawings for the DSCs, HSMs, and the TC is provided in Table 2-10. Volu me I, Chapter 1 of [2-2] provides figures depicting the Rancho Seco DSCs, HSMs and TC.

2.4.1 DSCs The Rancho Seco ISFSI provides for storage of 100% of the Rancho Seco spent fuel assemblies and control com ponents. To fulfill this requirement, three types of DSCs are provided: (1) F uel Only (FO), (2) Fuel with Control Components (FC), and (3) Failed Fuel (FF). The Rancho Seco DSC designs are based on the Standardized NUHOMS

-24P DSC design [2-3] except that the FO and FC DSCs include fixe d neutron absorbers. In addition, modifications have been made to the DSC cavity basket and spacer disc

design to qualify the DSCs for offsite transport. The Rancho Seco ISFSI also provides for storage of 100% of Rancho Seco GTCC waste in a GTCC DSC.

All three types of DSCs containing SFAs are SA-240, Type 304 stainless steel, welded pressure vessels that provide conf inement of the radi oactive materials, encapsulate the fuel in an inert atmo sphere, and provide axial biological shielding during DSC closure, transfer operations and long term storage. The Rancho Seco ISFSI configuration cons ists of eighteen FC DSCs, two FO DSCs and one FF DSC.

All three DSC types have an outside diameter of 67.2 inches (nominal) and are 186.2 inches (nominal) long. The DSC is composed of a 5/8-inch thick austenitic stainless steel shell. The cylindrical shell and the top and bottom cover plate assemblies form the pressure retaining boundary for the spent fuel and cover gas. The DSCs are equipped with two shielded end plugs so that the occupational doses at the ends ar e minimized for drying, sealing and handling operations. The DSCs have redun dant seal welds, which join the shell and the top and bottom shield plug and cover plate assemblies to seal

the canister. The bottom-end assembly we lds are made duri ng fabrication of the DSC. The top-end closure welds are ma de after fuel loading. Both top plug penetrations (siphon and vent ports) are redundantly sealed after the DSC drying operations are completed.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-11 The internal basket assembly contains a storage position for each fuel assembly. The basket is composed of circular spacer discs machined from

thick carbon steel plates. Axial support for the DSC basket is provided by four high strength stainless steel support r ods (FO and FC DSC) or four carbon steel support plates (FF DSC), which ex tend over the full length of the DSC cavity and bear on the canister top and bottom end assemblies. All DSCs are inerted with helium before being sealed. Carbon steel components of each

DSC basket assembly are coated with a thin layer of nickel to provide corrosion resistance for the short time that the DSC is in the spent fuel pool for

fuel loading. After the DS C is drained, dried, inerted and sealed for storage or transportation, there is no mechanism av ailable for corrosion of the carbon steel components.

On the bottom of each DSC is a grappl e ring that allows the DSC to be transferred in and out of the NUHOMS storage modules from the TC horizontally. The DSC basket is keyed to the DSC shell and the grapple ring is keyed to the cask bottom closure to ma intain the basket-to-cask alignment during all operations. The specific feat ures of the three types of DSCs provided at Rancho Seco ISFSI are as follows: 2.4.1.1 Fuel-Only (FO) DSC The FO DSC has a cavity length of 167 inches and has solid steel shield plugs at both ends. The FO DSC is capable of storing 24 intact B&W 15x15 Mark B SFAs with characteristics as listed in Table 2-2. The FO DSC basket assembly consists of 24 guide sleeve assemblies wit h integral borated neutron absorber plates, twenty-six spacer discs and four support rods. The spacer discs have machined openings, which allow the guide sleeves and the fixed borated

neutron absorber plates to pass through. 2.4.1.2 Fuel with Cont rol Components (FC) DSC The FC DSC has an internal cavity l ength of 173 inches to accommodate fuel with control components. To obtain this increased cavity length the shield plugs are a composite of lead and steel.

The use of lead in the shield plugs allows them to be thinner, thus increasing the DSC cavity length. The support rods are six inches longer above the t op spacer disc than those in the FO DSC. The FC DSC has a capacity to st ore 24 intact B&W 15x15 Mark B SFAs with control components (wit h the exception of six damaged SFAs stored in accordance with footnote 3 in Table 2-2).

The SFA characteristics are listed in

Table 2-2 while the control component characteristics are listed in Volume 1, Table 3-2 of the Rancho Seco ISFSI FSAR

[2-2]. To ensure that guide sleeve displacements during a top end drop do not uncover the active portion of the fuel assemblies, four 6.25-inch lengths of angle, or formed plates, protrude above the top of each guide sleeve. Angles are used to preclude interference of the fuel handling grapple during insertion and removal of fuel assemblies.

All other features of the FC DSC are the same as those of the FO DSC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-12 2.4.1.3 Failed Fuel (FF) DSC The FF DSC is similar to the FC DSC in most respects wit h the exception of the basket assembly. The internal cavi ty length is 173 inches. The FF DSC has a capacity to store 13 damaged fuel assemblies.

The FF DSC shell and top and bottom ends enclose a basket assembly, which serves as the structural support for the fuel assemblies. The fuel assemblies may be intact or damaged fuel assemblies as defined in Section 1.1 of Rancho Seco Technical Specifications [2-8] with characteristics as listed in Table 2-2. Because of the fuel cladding defects, individual (screened) fuel cans are provided to confine any loose material, and facilitate loading and unloading operations.

The FF DSC basket assembly consists of fifteen carbon steel spacer discs, four carbon steel axial support plates, and thirteen stainless steel failed fuel cans. The carbon steel components are coated with electroless nickel. The spacer discs maintain the cross-sectional spacing and provide lateral support for the fuel assemblies and failed fuel c ans. The spacer discs are held in place by the support plates, which maintain l ongitudinal separation.

The failed fuel cans are removable and ar e not permanently attached to the basket assembly or DSC shell.

The spacer discs in the FF DSC have thirteen square cut-outs. Additionally, the four support plates ar e fitted between cut-outs in the spacer discs. These plates have the same function as t he support rods in the FO and FC DSC design. Support plates are welded between the spacer discs at the 45 , 135 , 225 , and 315 azimuthal positions. The FF DSC failed fuel can consists of a seam-welded stainless steel tube with a welded bottom lid assembly and a welded removable top lid assembly.

The cans do not contain any borated neutr on absorber materials. They provide for the confinement of the fuel pelle ts/shards by means of a fixed bottom screen and a removable top screen. The bottom lid and top lid stainless steel

screens allow for dewatering of the failed fuel can. The bottom end of the can also include provisions for fuel support.

The fuel can lid is fitted with a fuel handling type pintle to interface with the plant fuel handling equipment for

placement of the lid and handling of the removable fuel can.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-13 2.4.1.4 Greater Than Class C Waste (GTCC) DSC The SMUD ISFSI is provided with one GTCC DSC designed to store 100% of Rancho Seco's solid reactor-related waste only, consisting of activated reactor vessel internals and other in-core instrumentation. The radioactive waste contents authorized for storage in this DS C are listed in Table 2-3. The GTCC DSC is an ASTM A-240 stainless steel , welded vessel that provides confinement of radioactive materials, encapsulates the waste in an inert helium atmosphere, and together with a TC or HSM, provides biological shielding during GTCC DSC closure, transfer and storage operations.

The external characteristics of the GTCC DSC are identical to the FO/FC/FF DSCs. The GTCC basket, with an internal cavity length of 167 inches, has been modified to accommodate different wast e forms and, therefore, does not contain spacer discs or guide sleeves. The basket, consisting of a perforated metal canister, is designed to accommodate 100% of Rancho Seco's GTCC

waste. 2.4.2 HSM The Rancho Seco HSM is a massive reinforced concrete structure that

provides protection for the DSC agains t tornado missiles and other potentially adverse natural phenomena during storage. The HSM also serves as the principal biological shield for the spent fuel during storage.

The Rancho Seco HSM design is similar to the Standardized NUHOMS HSM design [2-3]. The Rancho Seco ISFSI includes 22 HSMs, consisting of two HSMs for storing FO DSCs, 18 HSMs for FC DSCs, one HSM for an FF DSC, and one HSM for storing a GTCC DSC.

The HSM contains four shielded air inle t openings in the lower side walls of the structure to admit am bient ventilation air into the HSM. The cooling ventilation air flows around the DSC and exits near the top of the HSM. Air warmed by the DSC is exhausted thr ough four shielded vent openings near the HSM roof slab. Adjacent modules are spaced to provide adequate ventilation flow and shielding. This passive system provides an effective

means for spent fuel decay heat removal. Roof and side-wall mounted heat shields are provided between the DSC and HS M concrete to mitigate concrete temperatures. The DSC rests on a carbon steel frame structure with support rails in the cavity of the HSM. The support struct ure is anchored to the HSM floor slab, side wall, and the front wall. The steel support rails extend into the HSM front wall access opening, which is slightly la rger in diameter than the DSC. The HSM front access opening has a stepped fl ange sized to facilitate docking of the TC. This configuration minimizes streaming of radiation through the HSM opening during DSC transfer.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-14 The top surfaces of the rails on whic h the DSC slides ar e coated with a dry film lubricant that is suitable for a radiation environment. The support rail sliding surfaces consist of hardened st ainless steel plates for corrosion protection and added lubricity.

Inside the HSM, the heat rejected from the DSC has a drying effect. Decay heat warms the air, which may reduce the accumulation or condensation of moisture inside the HSM. The DSC is prevented from sliding along the support rails during a postulated seismic event by rail stops attached to the back ends of the DSC support rails and a DSC axial retainer located in the front access doo r of the HSM. The HSM wall and roof thicknesses are primarily dictated by shielding

requirements. The massive HSM walls, together with the end shield walls, adequately protect the DSC against to rnado missiles and other adverse natural phenomena. The HSM wall thickness for individual modules and HSM

arrays are specified on the Appendix E drawings of the CSAR [2-3].

The HSM front opening for DSC access is covered by a thick steel and

concrete door that provides shielding and protection against tornado missiles.

The door assembly includes a solid conc rete core that acts as a combined gamma and neutron shield. The door is attached to the front wall using ten bolted clamps.

The HSM gap between modules is covered with a stainless steel wire bird screen to prevent pests or foreign mate rial from entering the HSM. A daily visual inspection of the HSM inlets and outlets is a required surveillance activity per TS [2-8].

The reinforced concrete components of the HSM are constr ucted of 5,000 psi compressive strength, normal weight concrete.

2.4.3 NUHOMS

- MP187 Transfer Cask The Rancho Seco ISFSI is provided with one onsite TC, designated as the NUHOMS-MP 187 cask, which is also certified for transport as a pressure retaining structure under 10 CFR Part 71 [2-12]. The MP187 TC has no remaining function during normal ISFSI storage operations under 10 CFR 72 since all nuclear fuel at Rancho Seco has been placed into interim storage. It was used to load and transfer the DSCs to the HSMs and will not be used

again until a DSC is to be retrieved from the HSM for offsite shipment. The TC is currently in storage at the Rancho Seco site.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-15 The cask is fabricated primarily of stainless steel. Non-stainless steel members include the cast lead shielding between the containment boundary inner shell and the structural shell, the O-ring seals, the cementitious neutron shield material and the carbon steel closure bolts. Socket head cap screws (bolts) are used to secure the top closure plate to the cask body and the ram-access closure plate to the bottom of the cask. The body of the cask is constructed of a 1.25-inch, 68-inch in side diameter stainless steel inner (containment) shell and a 2.5-inch thick, 83.5-inch outside diameter stainless steel structural shell, which sandwich the 4-inch thick cast lead shielding material. The cask containment boundary consists of the inner shell, an 8-inch

thick bottom plate with a 17-inch diameter , 5-inch thick ram access closure, a top closure plate end forging ring, a 6.5-inch thick top closure plate (lid) and double O-ring seals for each of the lids with closure bolts, and vent and drain port closure bolts. A 68-inch diameter by 187-inch long cavity is provided. The neutron shield assembly consists of an outer jacket, a series of support angles, top and bottom support rings, and t he cementitious neutron shielding material. The neutron shield support angles provide support for the outer jacket, which is the confinement boundary for placement of the neutron shield material. The neutron shield support rings provide closure for the neutron shield and attachment support for the impact limiters.

The overall external dimensions of the cask are 201.5 inches long and 92.5 inches in diameter. The weight of the cask body is approximately 158,500 pounds. There are four trunnion sockets on the cask (two at the top and two at the bottom). They receive removable trunnions for handling and lifting of the cask. These trunnion sockets are attached to t he structural she ll. The bottom two trunnion sockets are covered by the lower impact limiter during transport. The upper two trunnions have covers that contain neutron shielding material. 2.4.4 Spent Fuel Assemblies The FO/FC DSC is designed to store intact 24 B&W 15x15 SFAs with

characteristics as listed in Table 2-

2. The FF DSC is designed to store 13 intact or damaged B&W 15x15 SFAs with char acteristics as listed in Table 2-2.

Damaged SFAs are as defined in Section 1.1 of Rancho Seco Technical Specifications [2-8].

Amendment 3 to Rancho Seco ISFSI license [2-7] approved the retrospective re-classification of six intact SFAs previously stored in five FC DSCs as damaged fuel. The reason for this classification change is due to the evolution

to a more restrictive definition of dam aged fuel (defects gr eater than hairline cracks or pinhole leaks) from an earlier less stringent definition after these six SFAs had already been loaded. Technica l Specification 2.1.1 was amended to allow storage of these six dam aged SFAs in FC DSCs.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-16 The intended functions of the SFAs include criticality control, structural integrity, and heat transfer.

The geometry of the SFAs is a factor in the proper conduction and convection of heat to the DS C surface and in criticality control.

The fuel cladding provides a fission product barrier, and its structural integrity is necessary to maintain a favorable geometry, and for DSC retrieval operations. The following subcomponents are applicable to the SFAs currently

in storage at the Rancho Seco ISFSI: Fuel Rods (Cladding, End Caps/Plugs) Guide tubes Instrumentation Tube Assembly Spacer Grid Assemblies Lower End Fitting (and related subcomponents) Upper End Fitting (and related subcomponents These subcomponents are further descr ibed in the following paragraphs: 2.4.4.1 Fuel Rods (Cladding, End Caps/Plugs)

The fuel rods consist of enriched UO2 pellets inserted into the cladding tubes.

Plug-type end caps are seal welded to eac h end. The material of construction for the fuel rods (cladding and end caps) is Zircaloy-4. The cladding and end caps confine the fuel pellets and fission pr oducts. Each fuel rod is pressurized with helium during fabrication. 2.4.4.2 Guide Tubes The guide tubes are mechanically atta ched and secured to the top and bottom end fittings. The material of constructi on for the guide tubes is Zircaloy-4. 2.4.4.3 Instrumentation Tube Assembly The instrumentation tube assembly consists of the instrument tube, a retainer, and seven spacer sleeves. The instrumentation tube is restrained by a sleeve in the lower end fitting. The spacer sleeves fit around the instrument tube

between the spacer grid assemblies and position the spacer grid assemblies.

The material of construction for the in strument tubes, retainers, and spacer sleeves is Zircaloy-4. 2.4.4.4 Spacer Grid Assemblies Each SFA includes a spacer grid assembly located at the top and six

intermediate locations along the lengt h of the SFA. The spacer grid assemblies provide support for the fuel rods and maintain correct rod-to-rod spacing. The spacer grid assemblies ar e made of Inconel. The spacer grid assemblies are fabricated from strips that are slotted and fitted together in "egg crate" fashion.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-17 2.4.4.5 Lower End Fitting (and related subcomponents)

The lower end fitting is a square, box-like structure that is mechanically connected to the guide tubes with connecto rs. It positions the guide tube array and functions as the bottom structural element of a fuel assembly. The material of the lower end fitting and connectors is stainless steel. 2.4.4.6 Upper End Fitting (and related subcomponents)

The upper end fitting is a square, box-lik e structure that is mechanically connected to the guide tubes with connec tors. It maintains the guide tube array and functions as the top structural element of a fuel assembly. It also interfaces with the fuel assembly grapple as the lifting point for the SFA during

insertion or removal from the DSC.

The material of the upper end fitting and connectors is stainless steel.

The upper end fitting also contains a hol ddown spring and holddown retainer.

The material for the holddown spring is Inconel or Alloy 718. The material for the holddown retainer is stainless steel. 2.4.5 ISFSI Basemat The HSMs are installed on a reinforced concrete basemat approximately 140 feet long, 40 feet wide, and 2 feet thick. The basemat was built in accordance with applicable commercial grade c odes and standards. There are no structural connections or means to transfer shear between the HSM base unit module and the concrete basemat.

The basemat is classified as NITS as it is not relied upon to provide any safety function. However, as discussed in Se ction 2.3.1, since settlement of the basemat may affect retrievability of the DSC, the basemat is included within the scope of renewal (monitoring for basemat settlement). 2.4.6 Approach Slab The approach slab is a reinforced concre te slab, designed and constructed to Rancho Seco site conditions. It provi des access to the HSM and supports the DSC transfer system.

The approach slab is classified as NITS, as it is not relied upon to provide any safety function.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-18 References 2.52-1 U.S. Nuclear Regulatory Commission, NUREG-1927, Revision 1, "Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel," June 2016. 2-2 Rancho Seco Independent Spent Fuel Stor age Installation Final Safety Analysis Report (IFSAR), Revision 6, August 2016 (Docket 72-11). 2-3 Vectra Technologies, Inc., "NUH-003, Certified Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, Revision 4A," Docket No. 72-1004, June 1996. 2-4 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510, including Techni cal Specifications and Safety Evaluation Report, Amendment 0, June 2000 (Docket 72-11). 2-5 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510, including Techni cal Specifications and Safety Evaluation Report, Amendment 1, March 2005 (Docket 72-11). 2-6 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510, including Techni cal Specifications and Safety Evaluation Report, Amendment 2, April 2005 (Docket 72-11). 2-7 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510, including Techni cal Specifications and Safety Evaluation Report, Amendment 3, August 2009 (Docket 72-11). 2-8 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510, including Techni cal Specifications and Safety Evaluation Report, Amendment 4, November 2017 (Docket 72-11). 2-9 U.S. Nuclear Regulatory Commission, "Certificate of Compliance for Spent Fuel Storage Casks," Certificate No. 1004, Re vision 0, January 23, 1995 (Docket 72-1004). 2-10 Exemption from the Requirement of 10 CFR 72.72(d)

Regarding the Storage of Spent Fuel Records, March 2001. 2-11 Exemption from the Requirement to Submit an Annual Radioactive Effluent Report Pursuant to 72.44(d)(3), March 2005. 2-12 U.S. Nuclear Regulatory Commission, Ce rtificate of Compliance for Radioactive Material Packages, Certificate Number 9255, Revision 13, issued to TN Americas LLC, NUHOMS MP187 Multi-Purpose Cask, approved January 30, 2017. 2-13 MPC&D 02-051, Letter from Steve R edeker (SMUD) to U.S. NRC Document Control Desk, "Rancho Seco ISFSI Bi ennial Report," May 23, 2002 (Docket 72-11). 2-14 Interim Staff Guidance, ISG-2, Revision 0, "Fuel Retrievability," U.S. Nuclear Regulatory Commission, Spent F uel Project Office, May 1999.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-19 2-15 Interim Staff Guidance, ISG-2, Revision 1, "Fuel Retrievability," U.S. Nuclear Regulatory Commission, Spent F uel Project Office, February 2010.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-20 Table 2-1 Scoping Evaluation of Ra ncho Seco ISFSI SSCs SSC Criterion 1 Criterion 2 In-Scope Dry Shielded Canister (DSC)

(1) Yes N/A Yes HSM (2) Yes N/A Yes Transfer Cask (TC)

(3) Yes N/A Yes Transfer Cask Lifting Yoke (4) No N/A No Spent Fuel Assemblies (5) Yes N/A Yes ISFSI Basemat (6) No Yes Yes ISFSI Approach Slab No No No Other Transfer Equipment (7) No No No Auxiliary Equipment (8) No No No Miscellaneous Equipment (9) No No No GTCC Waste No No No Notes: (1) The DSC includes (but is not limited to) the DSC shell confinement boundary assembly and the internal basket assembly, siphon and vent block, support ring, lifting lugs. There are three types of DSCs and one GTCC canister licensed for Rancho Seco ISFSI: NUHOMS FO-DSC, NUHOMS FC-DSC, NUHOMS FF-DSC and NUHOMS GTCC DSC. (2) The HSM includes (but is not limited to) the HSM reinforced concrete walls, roof, and end/rear shield walls; DSC steel structure support assembly; HSM accessories (DSC seismic retainer, heat shield panels, shielded door assemblies and door supports); associated attachment/installation hardware (tie rods, bolts, nuts, washers, embedment assemblies, mechanical splices); ventilation inlet vent openings and bird screens, ventilation outlet vent openings and bird screens, and outlet vent reinforced concrete covers. (3) Transfer Cask includes (but is not limited to) the MP187 cask structural shell assembly, cask inner liner, upper and lower trunnion assemblies, lead gamma shielding, neutron shield panel, solid neutron shielding, top cover assembly, ram access penetration, bottom cover assembly. (4) The TC lifting yoke was used for handling of the TC within the fuel/reactor building and was designed and procured as a "safety-related" component by the licensee under 10 CFR Part 50. The yoke will not be used again since all spent fuel has been transferred into DSCs and, therefore, the yoke is out of scope. (5) Spent Fuel Assemblies - SFA cladding and assembly hardware listed in Table 2-9 are included in-scope. (6) ISFSI Basemat - See discussion in Section 2.3.1. (7) Other transfer equipment includes a hydraulic ram system, a prime mover for towing, a transfer trailer, a ram support assembly, a cask support skid, auxiliary equipment mounted on the skid, and a skid positioning system. (8) Auxiliary equipment to facilitate canister loading, draining, drying, inerting, and sealing operations includes (but is not limited to) the following five systems: a vacuum drying system, an automatic welding system, the waste processing system, the security system, and the temperature monitoring system. (9) Miscellaneous equipment includes (but is not limited to) ISFSI security fence and gate(s), lighting, lightning protection, communications, monitoring, and alarm systems.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-21 N/A: Not Applicable.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-22 Table 2-2 B&W 15x15 Mark B SFA Characteristics Allowed for Storage at Rancho Seco ISFSI DSC Type DSC Design Basis Heat Load (kW)(1) Max. Assembly Initial Enrichment (wt % U-235)

(2) Max. Burnup (GWd/MTU)(2) Total Assembly Only Weight (2) Cladding Type(2) Damaged Fuel FO & FC 13.5 3.43 38.268 1530 lbs Zircaloy-4 Yes (3) FF 9.93 3.43 38.268 1530 lbs Zircaloy-4 Yes Notes: (1) The source of this information is Sect. 3.1.1.2 of the Rancho Seco ISFSI FSAR (Reference 2-2). (2) The source of this information is Table 3-1 of the Rancho Seco ISFSI FSAR (Reference 2-2). (3) Six fuel assemblies originally classified as "intact fuel" and later reclassified as "damaged fuel" are stored in five FC-DSCs as authorized by Amendment 3 to Materials License SNM-2510.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-23 Table 2-3 Summary of Contents Allowed for Storage in GTCC Canister Storage System Canister Design Basis Heat Load (kW)(1) Design Life (years)(2) Min/Max Ambient Temperatures (°F)(3) Payload(1) Total Payload Weight (lb)(1) GTCC (1) 0.725 predicted 50 -20 °F/+117 °F In-core support structures; Misc. RV internal parts; In-core components and instrumentation 25,000 Notes: (1) The Greater Than Class C (GTCC) canister with characteristics as defined in Section 3.1.1, Appendix C of the Rancho Seco ISFSI FSAR [2-2]. (2) The source of this information is Section 1.1, Volume I of the Rancho Seco ISFSI FSAR [2-2]. (3) The source of this information is Table 3-12, Volume 1 of the Rancho Seco ISFSI FSAR[2-2].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-24 Table 2-4 Listing of Amendments to Ranc ho Seco Materials License SNM-2510 and Rancho Seco ISFSI Active Exemptions Amendment/ Exemption Approval Date Amendment/Exemption Summary Impact on License Renewal Amendment 1 March 2005 Deleted Technical Specification 5.5.2, Item d to keep Rancho Seco Technical Specifications consistent with issuance of Exemption 72.44(d) (3) listed below. No impact; affects annual effluent reporting requirement at Rancho Seco site. Amendment 2 April 2005 Authorized Storage of Greater than Class C (GTCC) Waste at Rancho Seco ISFSI. Appendix C is added to the Rancho Seco ISFSI FSAR to reflect the addition of the GTCC Canister and supporting safety analysis. Yes; addressed in the renewal scope. Amendment 3 August 2009 Revised Technical Specification 2.1.1 to add a footnote, which allows six damaged fuel assemblies to be stored in FC DSCs. These six fuel assemblies had been previously loaded in five FC DSCs based on the old definition of intact fuel. However, based on the current definition of intact fuel (defects greater than hairline cracks or pinhole leaks), they are now classified as damaged fuel. Yes; addressed in the renewal scope. Amendment 4 November 2017 Revised Part 72 license conditions to transfer one radioactive byproduct source (Sr90) used for calibration and standardization purposes from Part 50 to Part 72 license. No impact; added a radioactive source to the authorized possession limits. Exemption 10 CFR 72.72(d) March 2001 Exemption from the requirement of 10 CFR 72.72(d) regarding duplicate storage of special nuclear material records. No impact; affects record keeping requirements.

Exemption !0 CFR 72.44(d)(3) March 2005 Exemption from the requirement to submit an annual radioactive effluent report pursuant to 72.44(d)(3). No impact (See Amendment 1 above).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-25 Table 2-5 Listing of Rancho Seco ISFSI 10 CFR 72.48 Evaluations for the Period 2000-2002 [2-13]

72.48 Screening/Evaluation Number Approval Date Evaluation Summary 72-1593 7/16/2001 This change adds a chamfer to the keyway in the MP187 Cask bottom-end closure to improve the DSC/ Cask shear key interface. The shear key and keyway are not analyzed in the ISFSI FSAR. The addition of chamfer does not affect any load or load cases. 72-1622 8/17/2001 This change revises the Pressure Test for the FO/FC/FF DSC from a range of 11-12 psig to 11-14 psig to prevent violation of the maximum test pressure due to heat up of the test medium. This change does not result in Code allowable stresses. 72-1605 6/7/2001 This change deletes Diamond Note 4 and the dimension from the top of the FO/FC DSC shell to the top of the support ring shown in the SAR drawing NUH-05-4004. This dimension is not analyzed in the ISFSI FSAR and does not affect any load cases. It is irrelevant for fit-up purposes (double dimensioning). 72-1607 Rev. 2 10/22/2001 This change implements several modifications to the FC DSC procurement drawings to enhance the fabricability of the DSC.

Supporting calculations were originated, which demonstrate that the change can be implemented without an amendment to Materials License SNM-2510. 72-1641 9/6/2001 For the FO/FC DSC, a note is added to the shear key to grapple ring support weld callout to clarify that no weld is required at the drain hole location. The SAR structural analysis does not take credit for this 0.25-inch weld and, thus, it is acceptable to implement this change. 72-1613 5/8/2002 This change implements several editorial, clarification, fabricability and design changes to the FF DSC. Updated calculations demonstrate that these changes may be implemented without an amendment to Materials License SNM-2510. 72-1659 11/28/2001 This change modifies the design of the top lid of failed fuel can of the FF DSC to improve the interface of the failed fuel can with the fuel handling equipment.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-26 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-38 Table 2-9 Scoping Evaluation Results for SFAs Subcomponent Intended Function Confinement Shielding Criticality Structural Thermal Retrievability Fuel Pellets None Fuel Cladding (2) Yes (1) No Yes Yes Yes Note 3 Spacer Grid Assemblies No No Yes Yes No Note 3 Upper End Fitting/Nozzle (and related subcomponents No No No Yes No Note 3 Lower End Fitting/Nozzle (and related subcomponents) No No No Yes No Note 3 Guide Tubes No No No Yes No Note 3 Hold Down Spring and Upper End Plugs None Control Components None Notes: (1) Though fuel cladding is the first barrier for confinement of radioactive materials, no credit for confinement of radioactive material is taken for the fuel cladding in the SMUD ISFSI design and licensing basis. The DSC pressure boundary is the only credited confinement boundary. (2) Zircaloy-4 for Rancho Seco.

(3) The licensing basis for retrievability with respect to the Rancho-Seco ISFSI is defined on a canister basis, consistent with ISG-2 Revision 0, as described in ISFSI FSAR Section 4.2.2.1.12. The NRC has accepted this approach as documented in SER Section 4.3.7.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-39 Table 2-10 List of Rancho Seco ISFSI Drawings Component Drawing No./Rev. Subcomponent List of Drawings for the NUHOMS Storage System-DSCs NUHOMS-FO & FC-DSC NUH-05-4004/R-16 Main Assembly NUHOMS-FF DSC NUH-05-4005/R-14 Main Assembly GTCC Canister 13302-1005/R-0 Main Assembly GTCC Canister 13302-1007/R-0 Main Assembly GTCC Canister 11221-1000/R-1 Basket GTCC Canister 11221-1002/R-0 Basket List of Drawings for the NUHOMS Storage System-HSMs HSM80 VEC-NUH-03-6008/R-5 General Arrangement HSM80 VEC-NUH-03-6009/R-4 Main Assembly HSM80 VEC-NUH-03-6010/R-1 Base Unit Assembly HSM80 VEC-NUH-03-6014/R-5 Base Unit HSM80 VEC-NUH-03-6015/R-4 Roof Slab Assembly HSM80 VEC-NUH-03-6016/R-3 DSC Support Structure HSM80 VEC-NUH-03-6017-01/R-4 Module Accessories HSM80 VEC-NUH-03-6018/R-5 Shield Walls Plans &

Details HSM80 VEC-NUH-03-6024/R-1 Module Erection Hardware List of Drawings for the NUHOMS Storage System-TC MP187 NUH-05-4001/R-15 Main Assembly MP187 NUH-05-4003/R-10 On-Site Transfer Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 2 - Scoping Evaluation Page 2-40 Table 2-11 Loading Overview at Rancho Seco Nuclear Generating Station DSC Serial No. HSM No. Date Loaded Vacuum Drying/ Blow-down Gas Used Total DSC Heat Load (kW) Minimum Cooling time (years) Highest FA Enrichment (wt. % U-235) Highest FA Burnup at time of loading (GWd/MTU) FO24P-P01 20 4/19/2001 Helium 9.005 5.0 3.21 35.20 FO24P-P02 12 10/10/2001 Helium 8.774 5.0 3.26 37.55 FC24P-P03 18 7/19/2001 Helium 8.145 5.0 3.43 37.91 FC24P-P04 16 8/28/2001 Helium 8.268 5.0 3.43 36.29 FC24P-P05 14 9/26/2001 Helium 8.149 5.0 3.43 37.91 FC24P-P06 10 11/20/2001 Helium 8.152 5.0 3.43 36.70 FC24P-P07 8 12/12/2001 Helium 8.161 5.0 3.43 37.91 FC24P-P08 6 1/7/2002 Helium 8.151 5.0 3.43 36.70 FC24P-P09 4 1/23/2002 Helium 8.146 5.0 3.43 38.26 FC24P-P10 2 2/6/2002 Helium 8.137 5.0 3.43 38.26 FC24P-P11 1 2/27/2002 Helium 8.139 5.0 3.43 38.26 FC24P-P12 3 3/13/2002 Helium 8.162 5.0 3.43 37.82 FC24P-P13 5 4/3/2002 Helium 8.157 5.0 3.43 37.91 FC24P-P14 7 4/17/2002 Helium 8.139 5.0 3.43 37.91 FC24P-P15 9 5/8/2002 Helium 8.147 5.0 3.43 36.70 FC24P-P16 11 5/22/2002 Helium 8.156 5.0 3.43 36.29 FC24P-P17 13 6/12/2002 Helium 8.132 5.0 3.43 36.29 FC24P-P18 15 6/26/2002 Helium 8.141 5.0 3.43 37.91 FC24P-P19 17 7/17/2002 Helium 8.144 5.0 3.43 37.55 FC24P-P20 19 7/31/2002 Helium 8.127 5.0 3.43 37.82 FF13P-P21 21 8/21/2002 Helium 4.642 5.0 3.43 34.40 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-i CHAPTER 3 AGING MANAGEMENT REVIEW CONTENTS 3.1Introduction

...................................................................................................... 3-13.2Operating Experience Review ........................................................................ 3-33.2.1Operating Experience Review Proc ess................................................... 3-33.2.2NUHOMS System Operating Experience

.............................................. 3-53.2.2.1CoC 1004 NUHOMS System Operating Experience ............... 3-53.2.2.2Rancho Seco ISFSI Oper ating Experience ............................... 3-73.2.3Generic Industry Experience

................................................................. 3-123.2.3.1INPO Database ....................................................................... 3-123.2.3.2NRC Information No tices ......................................................... 3-123.2.3.3NRC Bulletins .......................................................................... 3-143.2.3.4NRC Inspections of Ranc ho Seco ISFSI ................................. 3-143.2.3.5NRC Inspections of Ot her ISFSIs ............................................ 3-163.2.4Rancho Seco ISFSI Pre-Appl ication Ins pection .................................... 3-173.2.4.1Inspection Equipment and Methodology

.................................. 3-173.2.4.2HSM-20 Interior and DSC Exterior Inspection Results ............ 3-193.2.4.3HSM-20 Array Exterior In spection Results .............................. 3-203.2.4.4Chloride Sample Anal ysis Results ........................................... 3-213.2.4.5Conclusions ............................................................................. 3-223.2.5Summary of Pre-Application In spections at Other ISFSIs Using NUHOMS Storage Technology ................................................. 3-233.2.5.1Calvert Cliffs Nuclear Power Plant ISFSI, Material License No. SNM-2505 ......................................................................... 3-233.2.5.2Oconee Nuclear Station ISFSI, Material License No. SNM-2503 ........................................................................................ 3-243.2.5.3H.B. Robinson Steam Electric Plant ISFSI, Material License No.

SNM-2502 ........................................................... 3-253.2.5.4Environmental Fact ors Review ................................................ 3-263.2.6Operating Experience Review Results Summary and Conclusions .......................................................................................... 3-273.3Aging Management Review Methodology ................................................... 3-57 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-ii 3.3.1Identification of Materi als and Envir onments ........................................ 3-573.3.1.1Materials .................................................................................. 3-583.3.1.2Environments .......................................................................... 3-583.3.2Identification of Aging Effe cts Requiring Management ......................... 3-603.3.3Identification of the Activities Required to Manage the Effects of Aging ................................................................................................. 3-603.4Aging Management Review Results - DSCs ............................................. 3-623.4.1Description of DSC Subcomponents .................................................... 3-623.4.2DSC Materials Evaluated

...................................................................... 3-623.4.3Environments for the DSC .................................................................... 3-623.4.4Aging Effects Requiring Management for the DSCs ............................. 3-643.4.4.1Materials .................................................................................. 3-643.4.4.2Discussion of Agi ng Mechanisms ............................................ 3-643.4.4.3Neutron Absorber Materials Evaluation ................................... 3-743.4.4.4Coating Evaluation .................................................................. 3-753.4.4.5Temporary Attachment Evaluation .......................................... 3-753.4.4.6Summary of Applicable Aging Effects Requiring Management for DSCs ............................................................ 3-763.4.5Aging Management Activiti es for DSCs ................................................ 3-773.4.5.1DSC TLAAs ............................................................................ 3-773.4.5.2DSC Aging Management Programs ........................................ 3-773.4.6Summary of the AMR Resu lts for the DSCs ......................................... 3-783.5Aging Management Review Results - HSM ................................................ 3-893.5.1Description of HSM Subcomponent s .................................................... 3-893.5.1.1Excluded Subcom ponents ....................................................... 3-913.5.2HSM Materials Evaluated

..................................................................... 3-923.5.3Environments for the HSMs .................................................................. 3-923.5.4Aging Effects Requiring Management for the HSMs ............................. 3-933.5.4.1Concrete .................................................................................. 3-933.5.4.2Discussion of Agi ng Mechanisms ............................................ 3-943.5.4.3Steels and Other Metals ........................................................ 3-1023.5.4.4Discussion of Aging Mechanisms

.......................................... 3-1033.5.4.5Coatings Evaluation .............................................................. 3-107 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-iii 3.5.4.6Summary of Aging Effects Requiring Management ............... 3-1083.5.5Aging Management Activities for the HSMs ........................................ 3-1093.5.5.1HSM TLAAs

........................................................................... 3-1093.5.5.2HSM Aging Management Programs ...................................... 3-1093.5.5.3Summary of the AMR Result s for the HSMs ......................... 3-1093.6Aging Management Review Results - Concrete Basemat (Storage Pad) ............................................................................................... 3-1103.6.1Description .......................................................................................... 3-1103.6.2Basemat Materials Evaluated

............................................................. 3-1103.6.3Environments for t he Basemat

............................................................ 3-1103.6.4Summary of Aging Effects Requiring Management ............................ 3-1103.6.5Aging Management Activities fo r the Rancho Seco ISFSI Basemat .............................................................................................. 3-1113.7Aging Management Review Results - Transfer Cask .............................. 3-1163.7.1Description of Transfer Cask Subcomponents

.................................... 3-1163.7.2Transfer Cask Material s Evaluated ..................................................... 3-1183.7.3Environments for the Transfer Cask ................................................... 3-1183.7.4Aging Effects Requiring Management for the Transfer Cask .............. 3-1183.7.4.1Steels and Other Metals ........................................................ 3-1183.7.4.2Discussion of Aging Mechanisms

.......................................... 3-1193.7.4.3Other Materials ...................................................................... 3-1233.7.4.4Coating Evaluation ................................................................ 3-1243.7.4.5Summary of Aging Effects Requiring Management ............... 3-1243.7.5Aging Management Activities for the NUHOMS MP187 Transfer Cask (T C) ............................................................................. 3-1253.7.5.1TC Time-Limited Agin g Analysis .......................................... 3-1253.7.5.2TC Aging Management Programs ......................................... 3-1253.7.5.3Summary of the AMR Resu lts for the TC .............................. 3-1253.8Aging Management Review Result s - Spent Fuel Assemblies ............... 3-1323.8.1Description of Spent Fuel Assembly Subcomponents ........................ 3-1323.8.2Spent Fuel Assemblies Ma terials Evaluated ....................................... 3-1323.8.3Environments for the Spent Fuel Assemblies ..................................... 3-1333.8.4Aging Effects Requiring Manage ment for the Spent Fuel Assemblies ......................................................................................... 3-134 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-iv 3.8.5Aging Management Activities for t he Spent Fuel Assemblies ............. 3-1373.8.5.1Aging Management Program ................................................. 3-1373.9Periodic Tollgate Assessment

.................................................................... 3-1383.10Conclusions ................................................................................................. 3-1403.11References ................................................................................................... 3-141 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-v LIST OF TABLES Table 3-1 Operating Experience Documentat ion of Potential Age-Related Degradation .......................................................................................... 3-28Table 3-2 FO, FC FF and GTCC DSC Materials

................................................... 3-79Table 3-3 Rancho Seco FO-DSC Intended F unctions and AMR Results ............. 3-80Table 3-4 Rancho Seco FC-DSC Intended Functions and AMR Results

.............. 3-82Table 3-5 Rancho Seco FF-DSC Intended Func tions and AMR Results .............. 3-85Table 3-6 Rancho Seco GTCC DSC Intended Functions and AMR Results ........ 3-88Table 3-7 HSM Materials .................................................................................... 3-112Table 3-8 Rancho Seco HSM Intended Functi ons and AMR Results ................. 3-113Table 3-9 Transfer Cask Materials ...................................................................... 3-126Table 3-10 MP187 TC Intended Functions and AMR Results .............................. 3-127Table 3-11 Rancho Seco ISFSI Tollgates

............................................................. 3-139 LIST OF FIGURES Figure 3-1 Floor at HSM Interior Northw est Corner, Looking North ....................... 3-44Figure 3-2 Northwest Corner .................................................................................. 3-45Figure 3-3 Ceiling, South Ea st Corner ................................................................... 3-46Figure 3-4 Scrape on DSC Bottom

......................................................................... 3-47Figure 3-5 DSC Bottom Scrape at No rthern Terminus ........................................... 3-48Figure 3-6 DSC Bottom and Support Rail, Ea st Side, between Support #2 and Support #3

............................................................................................ 3-49Figure 3-7 HSM-20 Front Face .............................................................................. 3-50Figure 3-8 HSM-20 Roof ........................................................................................ 3-52Figure 3-9 West End Shield Wall South Panel ....................................................... 3-53Figure 3-10 End Shield Walls East Side .................................................................. 3-54Figure 3-11 Basemat East Side Facing South ......................................................... 3-55Figure 3-12 HSM-16 Spall at Roof Left Corner ........................................................ 3-56 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-1 3.1 Introduction This chapter addresses the aging managem ent review (AMR) of the Rancho Seco independent spent fuel storage in stallation (ISFSI) dry storage system. As stated in NUREG-1927 Revision 1, Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance

[3-1], the purpose of the AMR is to assess the proposed aging management activities (AMAs) of structures, sy stems, and components (SSCs) determined to be within the scope of renewal. The AMR addresses aging mechanisms and effects that could adversely affect the ability of the SSCs (and associated subcomponents) from performing their intended functions during the period of extended operat ion (PEO). Section 3.2 presents a summary of the NUHOMS dry storage system operating experience (OE), representing about 20 y ears of fabrication, installation, and available OE of the storage system deployed across nineteen

sites in the United States. This secti on also includes relevant U.S. Nuclear Regulatory Commission (NRC) generic communications and research results (e.g., Electric Power Research Institute (EPRI) inspections).

Section 3.3 describes the AMR methodology, which follows the guidance and the processes of NUREG-1927 [3-1]. This section addresses each of the major steps of the AMR process: Section 3.3.1: Identification of materials and environment, Section 3.3.2: Identification of aging mechanisms and effects requiring management, and Section 3.3.3: Identification of time-limited aging analysis (TLAAs), if applicable, supplemental evaluations and aging management programs (AMPs) fo r managing the effects of aging. Evaluations, which do not meet the six criteria of a TLAA, as specified in NUREG-1927 [3-1], are defined as supplementary evaluations. These supplementary evaluations are used to pr eclude the need for an AMP.

Sections 3.4, 3.5, 3.6, 3.7 and 3.8, provide the AMR results for the dry shielded canister (DSC), horizontal storage module (HSM) the concrete basemat, transfer cask (TC) and spent f uel assemblies (SFAs), respectively.

Each of these sections provides a de scription of the component, the materials of construction, the environment(s), and the evaluation of the potential aging effects and the associated aging mechanisms.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-2 The aging effects and associated aging mechanisms that could cause degradation resulting in loss of intended function are evaluated for each component. These evaluations result in t he identification of all applicable aging effects requiring management, and the required AMAs (either TLAAs or AMPs). The identified TLAAs and other supplemental/support evaluations are presented in Appendix A. These TLAAs are prepared to assess SSCs that have a time-dependent operating life to dem onstrate that the existing licensing basis remains valid and that the int ended functions of the SSCs in scope of renewal are maintained during the PE O. Time dependency may entail fatigue life (cycles), change in a mechanical property such as fracture toughness or strength of materials due to irradiation, or time-limited operation of a subcomponent.

As appropriate, an AMP is created and implemented for those in-scope SSCs that do not have a TLAA or a supplem entary evaluation. The AMPs credited for managing the effects of aging degradat ion are presented in Appendix B.

Section 3.9 describes the proposed tollgates for the Rancho Seco ISFSI as recommended in NEI 14-03, Revision 2, Format, Content and Implementation Guidance for Dry Storage Operations-Based Aging Management [3-19]. Sacramento Municipal Utility District (SMUD) will create and implement the tollgate process described in Section 3.

9 as part of the overall program for managing the ISFSI throughout the PEO.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-3 3.2 Operating Experience Review 3.2.1 Operating Experience Review Process This section summarizes the Operating Experience (OE) information for the NUHOMS storage system installed at the Rancho Seco ISFSI. As described in Chapter 1 of Ranc ho Seco Independent Spent Fuel Storage Installation Final Safety Analysis Report (ISFSI FSAR

), Revision 6, August 2016 (Docket 72-11), Volume 1 [3-15], the Rancho Seco HSM design is based on the Standardized NUHOMS HSM Model 80 described in the NUH-003, Certified Safety Analysis Repor t for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fu el, Revision 4A [3-7]. The Rancho Seco DSCs and the NUHOMS MP187 Transfer Cask (MP187 TC) are a modified version of the NUHOMS Standardized 24P DSC and Standardized Transfer Cask described in the CSAR [3-7], with design enhancements to meet 10 CFR Part 71 transportation requirements. Accordingly, the OE

information described in this section was primarily obtained from documented corrective action reports (CARs) and non-conformance reports (NCRs) databases generated during the NUHOMS System fabrication and installation, or from licensee condition reports (CRs) or action reports (ARs) generated during in-service operations. These databases comprise

approximately 20 years of storage system history and document the

identification and resolution of relevant issues encountered during fabrication, installation and operation of the Standardized NUHOMS System components. Also, a review was performed of the SMUD originated potential deviations from quality (PDQs) and devia tions from quality (DQs) that resulted from findings during Rancho Seco ISFS I installation or ISFSI inspections during the last 20 years. This OE is described in Section 3.2.2.2 and summarized in Table 3-1.

Review and evaluation of these sources of informati on provided insights on the various forms of potential aging-rela ted degradation that could affect the ability of the system components to perform their intended function.

In addition, relevant generic industry information was reviewed, including relevant industry OE of dry ca sk storage systems, and relevant NRC Information Notices, NRC Inspection Reports, and NRC Bulletins. These

reports were reviewed for any conditions that could be analogous to the aging of the Rancho Seco ISFSI and its components. The generic industry OE is discussed in Section 3.2.3.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-4 A pre-application inspection was perform ed at the Rancho Seco ISFSI in May 2017, Rancho Seco Independent Spent Fuel Storage Installation Pre-Application Inspection Report, [3-8] to document and evaluate the condition of the storage system components since the beginning of storage. A summary discussion of this Rancho Seco ISFSI pre-application inspection is presented in Section 3.2.4. Finally, information from the pre-applicat ion inspection reports from similar NUHOMS-based specific ISFSI renewal applications, were reviewed as part of the AMR process to identify actual or potential aging effects and associated aging mechanisms applicable to the Rancho Seco ISFSI SSCs. These include the specific renewal application inspection reports for Calvert Cliffs Nuclear Power Plant ISFSI, see references [3-2, 3-37, 3-38]; and Oconee Nuclear

Station ISFSI, reference [3-3], and H.B.

Robinson Steam Electric Plant ISFSI, reference [3-4 and 3-5]. These pre-applic ation inspection reports and baseline inspections are considered relevant because their ISFSIs are based on similar NUHOMS-based storage system design. A brief summary of these pre-application inspections is pr ovided in Section 3.2.5.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-5 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-7 3.2.2.2 Rancho Seco ISFSI Operating Experience A review of Rancho Seco's database of PDQs and DQs was performed to identify issues relevant to aging and age-related degradation. Most of the PDQs/DQs listed below are representat ive of the non-conformances due to fabrication, construction or operational issues and do not relate to age-related degradation.

PDQ 00-0038 HSM - Grout patches on HSM No. 1 and No. 14 are falling out.

The grout patches are on the bottom cor ners of the HSMs as they sit on the storage slab. The corners were damaged and repaired during construction.

There are no signs that the patch failure s were caused by mechanical means.

There is no visible sign of rebar corro sion. Most likely cause is from poor bonding between the patch material and the base material. The accessible grout patches have been repaired and no additional preventative actions were noted to be required. The applicable aging effect/mechanism for this condition (loss of material/corrosion) is evaluated in the HSM AMR and will be included in the acceptance criteria of the HSM AMP.

PDQ 02-0027 MP187 TC - The Helicoil Backed Out of the MP187 TC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-8 Helicoils backing out has been documented previously in several additional PDQs. The top lid inserts are the only helicoi ls that have shown a tendency to back out. As a part of remedial action, helicoils that have backed out were removed and new coils inserted.

The conditions described herein are event-driven that resulted during handling of the TC. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

DQ 01-0052 MP187 TC - Scratches and gouges noticed on TC after inserting DSC into HSM. After insertion of DSC FO24P-P01 in to HSM #20 scratches and a deep gouge were noted at approximat ely the 180 degree position of the TC. The most likely causes for the interferences were design, foreign material intrusion, and fabrications controls. In addition to the scrape at the bottom of the cask, there is also evidence of light scraping which occurred on the rails. Based on the fabrication records, the clearance fo r this DSC and the TC was found to be very tight and likely caused the scraping to occur. Operations provided training to personnel on the importance of cask cleanliness and foreign material for the pr evention of reoccurring of scratches and gouging. The following actions were taken as preventive actions in order to eliminate gouging in the future: Remove all raised metal, polish surfaces where contact area is rough, Apply lubricant (N-5000 or equivalent) to the bottom of cask for future loadings, Carefully review cylindrical measurements from fabrication record for locations of protrusions, Accept 0.005-inch weld reinforcement limitations of Engineering Change Notice (ECN) 01-84, Remind personnel of the importance of cleanliness and foreign material exclusion. The extent of the gouge was limited to the TC and the DSC. The work order was listed in the DQ for the repair of the TC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-9 As part of this investigation, the DSC was remotely inspected to see if any damage was visible on the lower surface of the canister, corresponding to the area of contact with the gouge on the TC and documented findings in the DQ. A video inspection of the DSC bottom reveal ed comparable scratches on the bottom half of FO24P-P01. This scratch on FO24P-P01 was also confirmed in Rancho Seco ISFSI Pre-Application Inspection results (see Figure 3-4 , Section 3.2.4).

The conditions described herein were ev ent-driven that resulted during handling of the DSC. Theref ore, there is no applicabl e aging effect that needs to be evaluated in the AMR.

PDQ 01-0123 Metal deposit and potential raised me tal on the MP187 Transfer Cask.

The PDQ concerns gouging of the MP 187 TC during transfer operations due to contact between the cask and canist er. The probable cause for the issue was that the repeated loading activities at Rancho Seco have produced wear on the rails. During these loadings, there has been no noticeable effect on the ram operation during transfer, so the mechanism causing gouging does not add significant resistance. Trans Nuclear We st (TNW) first evaluated this issue in TNW NCR 01.041, which resulted in minor rework of the cask to remove any gouges. There was no minimum wall thickne ss violation in either the cask or canister. TNW took mitigating action by issuing a design change, wherein the crowns on certain exterior canist er welds are reduced. TNW also recommended that SMUD liberally c oat the mating surfaces with an appropriate lubricant to further mini mize the potential for scratching. The conditions described herein are event-driven and resulted during the handling of the DSC. Theref ore, there is no applicabl e aging effect that needs to be evaluated in the AMR.

PDQ 02-0003 Scratch on TC rail after inserting DSC No. 8.

During insertion of DSC No. 8 into HSM No. 6, one of the internal rails of the TC was scratched, leaving material depos ited at the end of the rail. A work order was completed to remove the raised material and Quality Control verified the surface finish was su fficient in the worked areas.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-10 PDQ 02-0003 does not list any drawings as being affected, nor does it list any potentially reportable condition or technical specification violation. This was an issue found during loading operations.

Therefore, there is reasonable assurance that the DSC shell minimum th ickness (0.5 inch) requirements from Drawing NUH05-4004 were not violated as part of this PDQ since it was not mentioned in the disposition and this was considered to be a one-time, event-driven condition. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

DQ 06-0004 Greater than Class C (GTCC) basket lid does not fit into the basket Appropriate corrective actions were im plemented to resolve the interference and verify proper GTCC lid and basket fit.

The conditions described herein are event-driven and there is no applicable aging effect that needs to be evaluated in the AMR.

DQ 01-0001 Peeling of Paint from thermal shields on HSM No. 2 and No.6.

Construction of the ISFSI was completed in 1996, but fuel was not placed in storage until 2001. As part of preparation of the HSMs for loading, an inspection was performed in 2001. During this inspection, it was observed that the paint on the heat shields on two of the HSMs, No. 2 and No. 6 had peeled and there was a residue under the peeling paint. The cause of the peeling paint was believed to be either flawed mate rial or faulty wo rkmanship (e.g., the paint was unsatisfactory or the heat shield may not have received adequate preparation). Regardless of the cause, the resolution of the condition (i.e., cleaning off the flaking paint and resi due) was unaffected. Note that the condition was bounded by the therma l analysis performed in 1997, which showed that all acceptance criteria were met for all conditions of the paint, including no paint on the heat shield.

Since the condition occurred before any spent fuel was placed in storage and is believed to be caused by flawed mate rial or faulty workmanship, it is considered to be event driven and no applicable aging effect that needs to be evaluated in the AMR.

PDQ 05-0022 GTCC Basket contaminated with organic material.

The GTCC basket was potentially contami nated with organic material due to hydraulic leaks and hose breaks in the fuel transfer canal.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-11 Based on the information evaluated, t he metal surfaces of concern to segmentation activities show no visible evidence of oily residue. No oily residue is believed to be present on the metal surfaces associated with the GTCC basket and contents.

This issue has been evaluated for safety concerns and it was concluded that the GTCC DSC is acceptable as-is. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

DQ 00-0098 DSC surface defects

The surface defects included arc strikes on the outer surface of the canister, surface porosity defects, linear indication of about 2 inches long on weld, and a linear (crack appearance) indication observed on the base metal surface of the upper shell. The above-stated conditions were repair ed or removed through work orders by plant procedures, as part of the a bove-listed DQ resolu tion, and documented under work requests in response to the DQ. This also included verification of the minimum wall thickness of the shell.

Based on the above discussion, these defects have been corrected and there is no applicable aging effe ct that needs to be ev aluated in the AMR.

DQ 00-0111 Rancho Seco Technical Specification (T S) 4.3.4, Rancho Seco Independent Spent Fuel Storage Installation Ma terials License SNM-2510 including Technical Specifications

[3-17] requires that the TC and DSC be fabricated to American Society of Mechanical Engineers (ASME) Code with alternatives as

allowed by Appendix A of the ISFSI FSAR [3-15]. C ontrary to this, the TC and DSC were fabricated and accepted with additional code exceptions. A DSC pneumatic test was performed in lieu of t he hydrostatic test, which contradicts NB-6612.1(a). The other exception was bas ed on 125% of operating pressure rather than design pressure, which c ontradicts NB-6221. Welding of large attachments was performed on the structural shell after pressure test of the cask which contradicts NB-4436.

These additional exceptions to the Am erican Society of Me chanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code were submitted to the NRC for approval. The NRC approved additional code exceptions in March 2001.

Considering the nature of the issue, there is no app licable aging effect that needs to be evaluated in the AMR.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-12 3.2.3 Generic Industry Experience 3.2.3.1 INPO Database The INPO database was queried to i dentify reported aging-related OE associated with dry storage systems. The following OE reports were identified: OE28124-Untimely Corrective Actions for Blocked Vents in HI-STORM Spent Fuel Storage Cask. This event pertained to failure to adequately clear the intake vents for the cooling air after a snowstorm.

The above OE reports were evaluated fo r age-related degradation relevance and were determined to be not applicable or event-driven, and therefore not age-related degradation issues

[ ] occurred early, but could contribute to later age-related degradation. It is adequately addressed by the HSM AMP for internal and external surfaces, ou tlined in Appendix B.4. 3.2.3.2 NRC Information Notices The following NRC information notices (INs) were found to be directly related

to the dry fuel storage systems. NRC Information Notice 2011-20: Concrete Degradation by Alkali-Silica Reaction, [3-9]

This information notice (IN) addresses t he occurrence of alkali-silica reaction (ASR)-induced concrete degradation on Seismic Category I structures at a nuclear power plant. Because TN Americ as LLC Inc. generates a CAR for INs that have a bearing on the Standardized NUHOMS System, this IN is summarized and addressed in Table 3-1.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-13 NRC Information Notice 2012-20: Potential Chloride-Induced Stress Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System Canisters [3-10]

Several failures in austenitic stainl ess steels have been attributed to CISCC.

The components that have failed at nucl ear power plants because of this failure mechanism are made from the same types of austenitic stainless steels typically used to fabricate dry cask storage system canisters. As described in the IN, this failure mechanism is r eproducible in Type 304 and 304L stainless steels, as well as in 316L stainless steels. Accordingly, the NRC expects that all types of austenitic stainless steels typically used to fabricate dry cask storage system canisters (304, 304L, 316 and 316L) are susceptible to this failure mechanism.

All of the failures mentioned in the IN at nuclear power plants occurred in components located near a saltwater body. Section 3.4.4.2 provides justification as to why CI SCC of austenitic stainless steel at the Rancho Seco ISFSI is not an applicable aging mechanism. NRC Information Notice 2013-07: Premature Degradation of Spent Fuel Storage Cask Structures and Components from Environmental Moisture [3-11]

This IN concerns OE on environm ental moisture causing premature degradation of structures and components important-t o-safety (ITS) during spent nuclear fuel storage operations.

The instances described in this IN illustrate how the intrusion of water can potentially decrease t he effective life of both the structures and components of a spent fuel storage system.

In one instance, the presence of water not only caused ch emical degradation through oxidation of one metal, but it also facilitated the formation of a galvanic cell between two dissimilar metals, whic h contributed to the degradation of the secondary confinement barrier of the storage system. The specific conditions cited in this case apply only to casks with bolted lids and mechanical seals, but visual inspections of the canister, HS M support structure, HSM interior, and HSM exterior as specified by the AM Ps in Appendices B.3 and B.4 would detect signs of water damage or corrosion in the NUHOMS System as well.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-14 In another instance, water contributed to an accelerated aging process of the concrete structures of the spent fuel storage system at the Three Mile Island, Unit 2 (TMI-2) ISFSI at the Idaho Nati onal Laboratory site. Essentially, this began as the same condition as that

[ ] discussed above. Water entered roof bolt through-holes in the HSMs and when subjected to freezing temperatures, generated mec hanical forces that produced cracks in the concrete. These cracks provi ded additional and larger pathways for water to enter the interior of the concrete, which resulted in larger cracks from subsequent freezing temperatures and pr omoted efflorescence. If remedial actions had not been taken, this accelerated aging process could have

inhibited the ability of the HSM conc rete structure to perform its design function of protecting the c anister system containing the radioactive material, as well as protecting personnel from ionizing radiation, during normal and accident conditions. Table 3-1 contains a more detailed description of this second occurrence and the actions taken by the licensee to ensure the HSMs

continue to perform their safety function. Lessons learned have been incorporated into the "HSM Agin g Management Program for External and Internal Surfaces," described in Appendix B.4. 3.2.3.3 NRC Bulletins NRC Bulletin 96-04, "Chemical, Galvanic or other Reactions in Spent Fuel Storage and Transportation Casks," [3-73] addresses the generation of hydrogen due to the reaction of internal materials with spent fuel pool water during loading. This does not affect the aging of the DSC since all components are dry within the sealed canister. Ther efore, no AMP is required to address this industry experience. 3.2.3.4 NRC Inspections of Rancho Seco ISFSI NRC INSPECTION REPORT, Region IV; 71-0011/95-01; April 17-21, 1995.

Inspection of the horizontal dry spent fuel storage module and the pad for an independent spent fuel storage installation.

There were several observations/deficiencies made as follows:

A review of Concrete Specification NUH-03-114 for the HSMs determined that the minimum field-cured cylinder strength for lifting of the roof slabs was 1000 psi. The inspectors were informed by VECTRA personnel that the form work

was removed after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of curing time. The inspectors questioned whether the concrete had attained the required st rength to be lifted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A review of records by the inspectors dete rmined that the concrete test cylinders met the required strength; therefore, the inspectors had no technical concerns.

This is considered as a "Testing-Pr ogrammatic Issue," not as an aging management issue.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-15 Weaknesses were identified in concrete testing activities involving the failure to perform slump testing prior to c oncrete placement, and the failure to generate corrective action documentation upon notification of the deficiency, and the failure to record concrete wate r content. This is considered as a "Programmatic Issue," not as an aging management issue. The above issues were not related to aging management. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

NRC INSPECTION REPORT, Region IV; 50-312/97-01; 72-11/97-01; during February 24-27, 1997 Design change package R91-0001 AC 50.59 , Revision 2, "Horizontal Storage Module Temperature Moni toring System," was reviewed and found in compliance with applicable NRC regulations.

There were two issues discussed in the report, which dealt with (a) the thickness of the lead shielding between t he inner and outer steel shells of the overpack and, (b) the potential for hydrogen generation in the canister. The report discusses VECTRA's plan to address all outstanding MP187 TC design issues and submit a revised SAR on the cask to the NRC.

The above issues are not related to aging management. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

NRC INSPECTION REPORT, Region IV

72-11/10-01; 50-312/10-01;dated 05-11-2010; inspection dur ing March 16-17, 2010 There were 32 safety screenings and eleven 72.48/50.59 evaluations performed by SMUD since the last ins pection in October 2007. All safety screenings and evaluations had been performed in accordance with plant procedures. This is not an aging-related issue/discussion.

Review of selected 2008 and 2009 reco rds for temperature monitoring and visual inspections of the HSM storage modules demonstrated that temperature levels have remained within required per formance limits established in TS. This is not an aging-related issue/discussion.

In 2006, SMUD notified the NRC that six potentially failed fuel assemblies had been loaded in storage canisters during the cask loading campaign in 2001 and 2002 that were not designed for st orage of failed fuel. The loading of failed fuel in canisters other than failed fuel canisters in 2001 and 2002 was a violation of the licensee's TS. This issue has been resolved with the issuance of Amendment 3 to SNM-2510 license [3-16] on August 11, 2009. This is not an aging-related issue.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-16 NRC INSPECTION REPORT, Region IV; 50-312/00-05; dated 12-05-2000; inspection during November 13-16, 2000 An NRC inspector attended a commitment management review group meeting during the inspection. The meeting addressed a PDQ that identified a procedure that did not differentiate bet ween the training cask and the MP187 TC multi-purpose cask. The fuel team leaders were briefed and understood the problem. The commitment management review group determined that the item was a PDQ and assigned the dispositi on to the operations group. This is not an aging-related issue/discussion. NRC INSPECTION REPORT, Region IV; 50-312/2002-03; 72-11/2002-02; dated 09-18-2002; inspection during August 12-22, 2002 PDQ 02-0068 was initiated to follow up a corrective action that the dose rate at 3 feet from the HSM surface was not the maximum dose rate and the wrong data may have been recorded during loading operation of HSM No. 21. The highest dose rate was observed above t he bird screens on th e roof of the HSM. This would not create HSM concre te concerns and t herefore is not an aging-related issue.

NRC INSPECTION REPORT, Region IV; 50-312/06-001; inspection during Feb 6-9, 2006 During installation, the licensee found t hat the vendor had not fabricated the basket to the design drawings in that the four lifting lugs were placed 90 degrees apart as opposed to 80/100/80/100 degr ees that the design specified. The licensee modified the basket lid to pe rmit access to the lifting lugs in the basket. The modification of basket lid is not an aging-related issue. 3.2.3.5 NRC Inspections of Other ISFSIs The most relevant NRC ISFSI inspection, as it relates to aging degradation of ISFSI SSCs, is the NRC inspection of the TMI-2 ISFSI in Idaho. This was covered under NRC Inspection Report (072-020/2011-001) issued to the U.S.

Department of Energy (DOE), and is addr essed as OE ID Number 1 in Table 3-1.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-17 3.2.4 Rancho Seco ISFSI Pr e-Application Inspection The Rancho Seco pre-application inspection [3-8] was performed on May 24, 2017, which included direct visual inspec tion of the HSM doors (exterior), roofs and exterior concrete surfaces as well as the above ground basemat concrete surfaces.

The remote visual inspection was per formed using a camera mounted on a remote controlled crawler. The scope of the remote visual inspection included: DSC shell, lower half, HSM heat shields, HSM side walls, floor (all interior) and, HSM steel support structure.

Note: The HSM roof heat shields prev ent access to the upper half of the DSC shell via the air outlet vent s; therefore, the upper hal f of the DSC shell is not addressed in this remote visual inspection.

Ranch Seco determined that HSM-20 and DSC- FO24P-P01 are representative and bounding for the remaining HSMs and DSCs at the Rancho

Seco ISFSI based on the following:

Table 2-11 provides an overview of the SFAs loaded at Rancho Seco Nuclear Generating Station. The DSC with the longest time in service is DSC Serial No FO24P-P01, which was loaded in HSM No. 20 on April 19, 2001. This DSC has been in service for over 15 years and had an initial decay heat of 9.005 kW. From the pool of DSCs loaded at the Rancho Seco ISFSI, DSC Serial No. FF13P-P21 has the lowest heat load of 4.642 kW. However, this was the last loaded DSC with a loading date of August 21, 2002. This was about 16 months later from the first loaded DSC at the ISFSI. Although the initial heat load for DSC Serial No. FO24P-P01 was amongst the highest from the pool of DSCs loaded at the ISFSI, the heat load was lower than the design basis for the FO & FC DSC type that have a design basis heat load of 13.5 kW. This low heat load results in low DSC shell surface temperatures and continues to lower the DSC shell temperatures over the 15-year operating period, thus increasing relative humidity insi de the HSM and potentially promoting incubation of ambi ent contaminants. 3.2.4.1 Inspection Equipment and Methodology Remote inspection of the HSM-20 inte rior was performed using a remote controlled MaggHDŽ crawler. A tether cable attached the crawler to the controller and transmitted videos, photogr aphs and temperature data to a computer.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-18 The southeast inlet vent was used to access the HSM-20 interior using the crawler. The crawler was equipped with a camera module that is capable of

displaying and recording of photographs and videos having VT-3 quality

resolution. Four LED lights of adjustabl e intensity are also mounted on the crawler camera module to provide adequate illumination for the VT-3-level inspection of the interior of HSM-20.

An infrared sensor capable of measuring surface temperature was also mounted on the camera module. Thermographic accuracy of the infrared sensor was verified by using a contact pyrometer. A picture of the crawler is shown below:

Crawler with the Camera module The camera module could be articulat ed through 120 degrees, which allowed the crawler to record footage in front, directly overhead, and slightly to the rear. The crawler video camera was ve rified to be VT-3-capable on the day of

the inspection just prior to HSM entry.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-19 3.2.4.2 HSM-20 Interior and DSC Exterior Inspection Results The inspection team included a lead inspector, a VT-3-qualified inspector, and a crawler operator. The lead inspector directed the crawler operator to maneuver the crawler via pre-planned paths and take videos and photographs

of the side of HSM-20. Using a secondary monitor (32-inch TV), the inspector monitored the images closely in real-t ime looking for anomalies. If an anomaly was noted, the inspector informed the oper ator to zoom in the area in question and record the anomaly via photographs.

Figure 3-1 through Figure 3-6 present a summary of the overall HSM-20 interior inspection results. After more t han 15 years of service, the surfaces of the HSM walls, floor, roof, heat shields, DSC support structure, and DSC shell lower half do not show any age-related degradation effects.

As noted in Figure 3-4 and Figure 3-5, a continuous, axial scrape extends along the bottom centerline of the DSC.

The scrape extends approximately 6 inches from the south side (HSM door end) to about the middle of the DSC length. This scrape was identified prev iously in 2001 and documented in DQ 01-0052. DSC P01 had received a scrape along the bottom due to contact with the transfer cask duri ng its dual insertions test performance in 2001. This scrape is clearly evident in these figur es. There was no visible rust in the

scrape, nor were there any sharp ra ised metal surfaces along the edges observed. Figure 3-6 shows discoloration streaks along the DSC that appear to be rail lubricant carried by rainwater intrusion.

The streaks appear to be dry with no indication of active water intrusion. The figure also shows paint blisters on the support rails.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-20 3.2.4.3 HSM-20 Array Exterior Inspection Results The HSM array exterior inspec tion was performed by an HSM fabrication/concrete expert who visually inspected the cond ition of the HSM exterior walls, roofs, bi rd screens, fasteners, etc.

The pictures in Figure 3-7 through Fi gure 3-11 present a summary of the overall exterior HSM array inspection re sults. After more than 15 years of service, the exterior surfaces of the HSM front walls, side walls, roofs, doors, bird screens, and basemat do not show any age-related degradation effects.

The HSM-16 exterior had a minor spall at the upper left corner as shown in Figure 3-12. The spall likely occurr ed during transport and assembly of the HSMs. The spall did not appear to be associated with active deterioration.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-21 3.2.4.4 Chloride Sample Analysis Results As part of the pre-application inspec tion, SMUD also performed surrogate chloride sampling to determine the susceptibility of chloride aerosols deposition on the horizontal metal surfaces over the PEO at the Rancho Seco site. The samples were collected in May of 2017 and consist of pieces of metal (one piece was part of a door frame fr om within the Auxi liary Building and other was a bracket from a structural column from within the Turbine Building).

These buildings have been decommissioned and essentially closed to staff since 2008. The buildings have not been sealed and no environmental maintenance has been performed since t hey were decommissioned. While the Auxiliary Building walls and ceilings are still intact, the Turbine Building walls are very open with the large equi pment openings covered with expanded metal grates to restrict access. Because the samples were horizontal su rfaces, the chloride amounts in the lab report are expected to bound the chlo ride concentrations on the surfaces of the DSCs with different orientations (vertical and lower bottom). Considering the proximity of the Au xiliary Building and the IS FSI and similarity of environmental conditions (i.e. both are open to atmosphere, but not exposed to rain and snow), it is reasonable to conclude that the chloride amounts from the surrogates are representative of the chloride deposition on the DSC surface at the Rancho Seco ISFSI.

Plant Rancho Seco Calvert Cliffs

[3-66] Hope Creek

[3-67] Chloride amount (mg/m 2) 18.5 84 (max) 60 on the top (horizontal)

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-22 3.2.4.5 Conclusions The Rancho Seco ISFSI site is a fundamentally beni gn environment for potential degradation of meta l and concrete since it is not near a source of salt water, or operating cooling towers. It is located in a region of low humidity, with no snow/ice management activities to create airborne chlorides. The Rancho Seco pre-inspection c onfirms that the HSM, DSC Support Structure and DSC subc omponents do not show any age-related degradation and are in very good condition after more than 15 years of service.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-23 3.2.5 Summary of Pre-Application Ins pections at Other ISFSIs Using NUHOMS Storage Technology Information from the lead canister and bas eline inspection reports from similar NUHOMS-based specific ISFSI license renewal applications were evaluated as part of the AMR process. These incl ude the specific r enewal applications inspection reports for Calvert Cliffs Nuclear Power Plant IS FSI [3-2], Oconee Nuclear Station ISFSI, License Renewal Application for the Site-Specific Independent Spent Fuel Storage Installation (ISFSI) - Response to Requests for Additional Information [3-3], and H.B.

Robinson Steam Electric Plant ISFSI

[3-4, 3-5]. These inspections reports are considered relevant because their ISFSIs are based on NUHOMS

-based storage system design similar to the Rancho Seco ISFSI design.

A summary of the inspections is provided below: 3.2.5.1 Calvert Cliffs Nuclear Power Plant ISFSI, Material License No. SNM-2505 The Calvert Cliffs Nuclear Power Plant ISFSI was originally licensed with the NUHOMS-24P dry storage system in Novem ber 1992. The 20-year license expired on November 30, 2012, was r enewed for forty years on October 23, 2014 and expires November 30, 2052. T he principal components are an HSM composed of concrete and structural st eel, and a stainless steel DSC with an internal basket that holds the spent fuel. The exterior walls and roof of the HSM are 3 feet thick, and the interior walls are 2 feet thick.

On June 27th and 28th, 2012, Calvert Cli ffs performed an inspection of the interior of two HSMs, and the exterior of the DSCs contained therein. The inspection was conducted in accordance with Calvert Cliffs Nuclear Power

Plant Engineering Test Procedur e, "Aging Management and Marine Environment Effects Inspection of ISFS I Horizontal Storage Module and Dry Storage Canisters." The first module examined was HSM-15, which was loaded in November 1996 and contained the "lead canister" DSC for the purpose of meeting the NUREG-1927 Appendix E guidance. The second module inspected was HSM-1, which wa s loaded in November 1993 (the first loading) and represents one of the lowest heat load canisters presently loaded (estimated at 4.2 kW). This canister was added as part of the EPRI research efforts on evaluating stress corrosion cracki ng of stainless steel canisters used for dry storage. This inspection included salt concentration measurements on

the upper shell of the DSC, collection of samples of the deposits on the upper shell of the DSC for offsite analysis, and surface temperature measurements via contact thermocouple for the pur pose of benchmarking best-estimate thermal models.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-24 The visual inspection was conducted in both HSM-15 and HSM-1 by remote and direct means. The remote inspection was performed by lowering a remote controlled, high definiti on pan-tilt-zoom (PTZ) came ra system with a 100 mm head camera inserted through the rear out let vent, which allowed viewing of the majority of the DSC, its support stru cture, and the interior surfaces of the HSM. The direct inspection was perfo rmed through the parti ally open door by mounting the camera on a pole. This al lowed for views of the bottom end of the DSC, the seismic restraint, HS M doorway opening, and the backside of the HSM door. Varying levels of camera magnification were utilized to highlight various areas of interest during the inspection.

Based on the visual examinations descri bed above, it was concluded that the Calvert Cliffs baseline inspection of HSM and DSC structures were performing as expected. The inspection did not indicate any aging-related deficiencies

with the DSC components. Some minor degradation on HSM external concrete surfaces have been noted. There was evidence of localized water intrusion to the interior of the HSM in the vicinity of the rear outlet vents. A coating of dust and dirt was present on the floors of each HSM but no debris or standing water was observed. Ther e was some general surface corrosion noted on the carbon steel surf ace and bolting hardware.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-25

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-27 3.2.6 Operating Experience Review Results Summary and Conclusions The review of available documentation of conditions found in NUHOMS ISFSIs shows that the aging-related condi tions can be classified in three areas of interest. The first is the degradati on of the concrete, which is readily monitored visually, and is corrected wit h proper repair programs. The second area of interest is the degr adation of the coatings resulting in some corrosion to the HSM interior steel. The third ar ea of interest is t he environment of the DSCs and potential CISCC of the she ll surfaces and assembly welds.

Rancho Seco Pre-Application Inspection The Rancho Seco ISFSI site is a fundamentally beni gn environment for potential degradation of metal and concrete since it is not near a source of salt water, or operating cooling towers. It is located in a region of low humidity, with no snow/ice management activities to create airborne chlorides.

The Rancho Seco pre-inspection conf irms that the HSM, DSC Support Structure and DSC subcom ponents do not show any age-related degradation and are in very good condition after more than 15 years of service.

Conclusion In conclusion, OE from fabrication and installation coupled with the Rancho Seco and other existing site-specific ISFSI inspection results provide a sufficient basis for developing adequat e AMPs for the Rancho Seco SNM-2510 renewal application.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-28 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-31 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 4 NRC IN 2011-20 addresses the occurrence of alkali silica reaction (ASR)-induced concrete degradation on seismic Category 1 structures at Seabrook Station. ASR is one type of alkali-aggregate reaction that can degrade concrete structures. ASR is a slow chemical process in which alkalis, usually predominantly from the cement, react with certain types of silica (e.g.,

chert, quartzite, opal and strained quartz crystals) in the aggregate, when moisture is present. This reaction produces an alkali-silica gel that can absorb water and expand to cause micro-cracking of the concrete. In order for ASR to occur, three conditions must be present: a sufficient amount of reactive silica in the aggregate, adequate alkali content in the concrete and sufficient moisture. To prevent ASR, the American Society for Testing and Materials (ASTM) has issued standards for testing concrete aggregate during construction to verify that only non-reactive aggregates are used. Seabrook used these standards (ASTM C289 and ASTM C295); however, ASR degradation still occurred.

Cause: ASR Loss of compressive strength, modulus of elasticity due to cracking [ ] Relevance to Rancho Seco LRA renewal: Although the potential for alkali reactivity in the HSM concrete is low, it is considered to potentially exist during the extended storage period. Therefore, signs of ASR are an inspection attribute in the HSM AMP.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-32 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 5 NRC IN 2012-20 addresses the potential chloride induced stress corrosion cracking (CISCC) of austenitic stainless steels typically used to fabricate dry cask storage canisters.

As described in the IN, this failure mechanism is reproduced in Type 304, 304L and 316L stainless steels. All of the failures mentioned in the IN occurred in components at nuclear plants located near a saltwater body.

Cause: CISCC Loss of material due to CISCC of austenitic stainless steels. Initiation of CISCC for austenitic steels is affected by parameters including DSC surface temperature, relative humidity and chloride salt concentration deposited on the DSC surface. Relevance to Rancho Seco LRA renewal: The potential for CISCC at Rancho Seco site is remote due to the location of Rancho Seco ISFSI away from a saltwater body. Additional justification has been provided in Section 3.4.4.2 as to why CISCC of austenitic steel is not a credible aging mechanism at Rancho Seco ISFSI. Rancho Seco evaluation.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-33 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-34 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 7 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: The conditions described herein are event-driven that resulted from improper storage of DSC components. The appropriate corrective actions were taken. They are not related to aging or age-related degradation because the components once installed will be in a sealed and inert environment. Therefore, there is no applicable aging effect that needs to be evaluated in the AMR.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-35 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 8 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: The settlement of the basemat noted in this OE occurred following the initial placement of the modules during installation. This is distinct from the settlement of a concrete basemat over a long term. The settlement of the basemat over a long term is an applicable aging effect and an inspection attribute in the AMP and monitoring inspections.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-36 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-38 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 11 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: Leaching of concrete and water stains on metal components are included in the acceptance criteria of the HSM AMP for external and internal surfaces. 12 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: None, since the vent screens are monitored daily per Rancho Seco Tech Specification 5.5.3.3.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-39 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 13 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: Inspection for indications of corrosion of the HSM internals is an attribute in the HSM AMP. 14 [ ] [ ] [ ]. Relevance to Rancho Seco LRA renewal: Visual inspection of the DSC exterior for corrosion products is included in the DSC AMP Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-40 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 15 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: None for DSC internal parts because of the dry inert internal environment during storage. 16 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: Indications of concrete flaking, peeling, and indentations (voids) are inspection attributes in the HSM AMP for external and internal surfaces.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-41 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 17 At an operating ISFSI, HSM roof has surface cracking, which appears to align with the underlying reinforcing steel. Other roof modules also have similar surface cracking. See INPO OE27586.

Cause: Conditioning of the concrete surface during fabrication.

Loss of material (cracking & spalling);

cracking/freeze-thaw

[ ] well above the design requirement of 5,000 psi. The evaluations concluded that the type of crack observed is not structural and is limited to the outer layer of the concrete cover. The overall HSM and HSM array continues to be capable of fully performing the intended function/performance requirements, both structurally and radiologically. As a mitigating measure, TN recommended sealing the concrete surface with concrete sealant to prevent moisture intrusion.

Relevance to Rancho Seco LRA renewal: Applicable aging effect included in the HSM AMP for external and internal surfaces.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-42 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 18 [ ] [ ] [ ] Relevance to Rancho Seco LRA renewal: Loss of concrete material is addressed by the HSM AMP for external and internal surfaces. 19 [ ] [ ][ ] Relevance to Rancho Seco LRA renewal: Corrosion is addressed by the HSM AMP for external and internal surfaces. 20 Scratch /Gouge on the Rancho Seco MP187 TC.

Cause: Event driven during DSC handling.

Loss of material The scratches/gouges were repaired and evaluated in accordance with Rancho Seco site procedures as part of the resolution. The conditions described herein are event-driven that resulted during handling of the DSC. The appropriate corrective actions were taken.

Relevance to Rancho Seco LRA renewal: They are not aging or age-related degradation. Therefore, there is no applicable aging effect that needs to be evaluated in the aging management review.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-43 Table 3-1 Operating Experience Documentation of Potential Age-Related Degradation (16 Pages)

OE ID Number Brief Description/Cause Potential Aging Effect & MechanismDisposition/LRA Renewal Relevance 21 Paint peeling off the HSM Heat Shields at Rancho Seco ISFSI.

Cause: Poor workmanship.

Loss of Paint This was discovered during NRC inspection of the Rancho Seco HSMs. Calculation NUH004.0421 Rev. 3 (1997) bounds the condition including no paint on the heat shield. The affected area of the HSM # 2 and #6 were cleaned per work order.

Relevance to Rancho Seco LRA renewal: This issue was considered as bad workmanship and not aging or age-related degradation. Therefore, there is no applicable aging effect that needs to be evaluated in the aging management review.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-44 Figure 3-1 Floor at HSM Interior Northwest Corner, Looking North No anomalies noted.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-45 Figure 3-2 Northwest Corner Shown in the picture are the left and upper heat shields and DSC (dark gray) at right. The DSC support rail is at the far right. No anomalies noted.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-46 Figure 3-3 Ceiling, South East Corner The bolts shown in the middle left of the photo are fasteners attached to the east wall. The camera is looking south with support post #1 in view. No degradation of the bolts, supports, support rail, support welds, heat shield, or DSC was observed. There are circular shaped shiny and dark spots on the right of the support rail. The shiny spot is the glare of the crawler's lights.

The "dark" spot appears to be a burnish mark on the DSC, which appears to be darker than the surrounding. It does not appear to be a result of degradation.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-47 Figure 3-4 Scrape on DSC Bottom This photo was taken approximately 4 feet from the south (plug) wall and in the middle of the HSM. Note: The scrape extends from approximately 6 inches from the south HSM door to the middle of the DSC along an axial line. No indication of deterioration is observed. As noted in DQ No. 01-0052, DSC P01 had received a scrape along the bottom due to contact with the TC during its insertion test performance in 2001. As shown, this scrape is clearly evident.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-48 Figure 3-5 DSC Bottom Scrape at Northern Terminus This picture shows a zoomed-in view of the scrape. There is no visible rust in the scrape observed. There are no sharp raised metal surfaces along the edges observed. The scrape terminus is about 7 feet north of the interior face of the front wall. The middle crossbeam is at the lower portion of the picture. East rail flange is along the left portion of the picture.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-49 Figure 3-6 DSC Bottom and Support Rail, East Side, between Support #2 and Support #3 Note discoloration streaks can be seen on the DSC that appear to be rail lubricant carried by rainwater intrusion. The streaks appear to be dry with no indication of active water intrusion. Paint blisters were also observed on the Support Rail

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-50 Figure 3-7 HSM-20 Front Face Minor cracks in the concrete as defined in this report are crack widths of up to 0.013 inch on exterior surfaces, which is acceptable per ACI 224 [3-40]. Random hairline shrinkage or tensile cracks may occur in the cement film on the surface of modules. Roof - Front Face The front face of the roof is attached to the base with shear keys in the interior and through rods. Conduit runs along the top of the array and attaches to the thermocouple at the face of the module. An extra thermowell is plugged with a fastener. The surface is free of spalls or cracks.

Door The door is comprised of an 8-inch thick hollow steel plate filled with concrete. The door is attached by 10 clamps and four welds at the door ring embed located close to the vertical Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-51 centerline of the door. The door is coated with Carbo Zinc 11 primer and Carboguard 890 topcoat. The top coat is intact and protecting the carbon steel.

Base - Roof Side Walls The module side walls were inspected from the front as observed through the 6-inch gap. The walls appear to have their original finish with no signs of spalls or structural cracks.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-52 Figure 3-8 HSM-20 Roof The HSM roof surface has the original finish with no indications of map cracking, scale, or abrasion. The four grout patches that fill the lift embeds are sound and free of deleterious cracks. Bird Screen The bird screens are stainless steel mesh and welded frame that is attached to the concrete with Hilti post installed anchors. The bird screens are intact and performing the function as designed. There are no warped sections that would indicate movement. There is no indication of corrosion or deterioration.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-53 Figure 3-9 West End Shield Wall South Panel The end shield walls consist of four vertical slabs attached to the end modules with through-studs at the bottom and metal straps at the top. The concrete surface has minor superficial map cracking that is not deleterious. There are no spalls. The grout patches for filling the lifting embeds are sound. The light discolorations are superficial and appear to be part of the original construction.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-54 Figure 3-10 End Shield Walls East Side The east shield walls are identical to the west panels. There are two shear keys reinforced with galvanized angles at the corners. The shear keys are intact. There are no spalls and the visible cracks are typical and minor. The grout patches for filling the lifting embeds are sound. The light discolorations are superficial and appear to be part of the original construction. The east shield wall has the conduit for the temperature monitoring system. The junction box has corrosion on the outer cover. The temperature system quality class is not important-to-safety (NITS).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-55 Figure 3-11 Basemat East Side Facing South The basemat is a 2-foot thick slab for the HSM assembly. The basemat extends beyond the front face of the east and west end wall. The basemat has superficial discoloration around the edges. The joint between the basemat and apron is intact. The construction joint between the apron and basemat is level with random wear at the edges.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-56 Figure 3-12 HSM-16 Spall at Roof Left Corner HSM-16 had a spall at the upper left corner. The spall likely occurred during transport and assembly of the HSMs. The spall did not appear to be associated with active deterioration.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-57 3.3 Aging Management Review Methodology The AMR follows the methodology re commended in NUREG-1927 [3-1] and NEI 14-03 [3-19]. The AMR provides an a ssessment of the aging effects that could adversely affect the ability of the SSCs to perform their intended functions during the period of extended operation. The guidance in the draft Managing Aging Processes in Storage (MAPS) Report [3-68] was also considered, to the extent possible, given that the LRA was being written concurrent with the development of the draft MAPS Report.

The AMR process involves the following major steps: Identification of materials and environments; Identification of aging effects and mechanisms requiring management; Determination of the activities required to manage the effects and mechanisms of aging. This involves t he identification of TLAAs or AMPs for managing the effects of aging; Evaluation of spent fuel (canister) retrievability during the period of extended operation.

The scoping evaluation, documented in Chapter 2, identifies the in-scope SSCs for which potential aging effects must be identified and evaluated. The identification of materials and env ironments for the in-scope SSCs is presented in Section 3.3.1. For each SSC , the material of construction and the environment to which each SSC is exposed are determined. The component environments are determined based on the location of the component within the storage system. Once the component material/environment combinations are determined, potential aging effect s requiring management are determined (Section 3.3.2). Engineering literatur e, related research and industry information, and existing OE are re viewed to identify expected aging degradation mechanisms for different materials and environments. After the expected aging effects are identified, it is determined whether the effects can be addressed by TLAA, or will require an AMP (Section 3.3.3). 3.3.1 Identification of Materials and Environments The first step in the AMR process is to identify the materials of construction for each subcomponent of the in-scope SSCs and the environments to which those materials are exposed during normal storage conditions. The

combinations of materials and environm ents are used to identify the potential aging effects that require management during the PEO, as discussed in Section 3.3.2.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-58 3.3.1.1 Materials The Rancho Seco ISFSI SSCs and associated subcomponent materials of construction are summarized in tables pr esented in Chapter 2, Table 2-6 (for DSCs), Table 2-7 (for HSMs), Table 2-8 (for TC) and Table 2-9 (for SFAs) on a component-by-component basis. The materials of construction were

identified through a review of the drawi ngs listed in Table 2-10 and included in the ISFSI FSAR along with other pertinent design information.

In this LRA, coatings (or paints) ar e treated as materials rather than as a separate subcomponent that would otherwise have been subject to scoping evaluation. Various in-scope subcomponents of major components are coated.

In all cases, the coatings are considered not-important-to-safety. Coatings are discussed for each in-scope component, as applicable in the AMR discussions that follow under the subsection en titled "Aging Effects Requiring Management." As appropriate, the AMRs ev aluate the impact of the failure of coatings on the ability of associated in-scope subcomponents (or those

located nearby) to perform their intended functions.

3.3.1.2 Environments The environments to which SSCs and associated subcomponents are exposed play a critical role in the det ermination of potential aging effects and mechanisms. The configuration of the Rancho Seco ISFSI, consisting of an

array of individual HS M storage modules, provides an effective means of protection against extreme seasonal we ather conditions, including heavy precipitation, drifting snow, ice flows, lightning strikes, strong winds, wind driven missiles, and blowing dust [3-15]. The Rancho Seco ISFSI has been designed for a bounding seasonal norma l ambient operating temperature

range of 0 °F to 101 °F, and an off-norma l range of -20 °F to 117 °F with concurrent extreme insolation.

The environments to which the Rancho Seco SSCs are exposed are affected by the characteristics of the ISFSI site environment, as well as by the component location within the storage system. There are five basic environments that apply for t he Rancho Seco ISFSI SSCs. Note: The five environments listed below are consistent with the environments listed in Table 3-1 of the draft MAPS Report [3-68]. (MAPS designations are shown in parentheses). Inert Gas (HE) - Inert helium env ironment inside the DSC cavity. The spent fuel assemblies (SFAs), the DS C internal basket assembly, and the inside surfaces of the DSC shell and interior shell assembly subcomponents (e.g., inner top and bo ttom cover plates and top shield plugs) are exposed to the inert gas (helium) environment inside the shell assembly cavity. These components are exposed to significant neutron and gamma radiation. See FO/FC/FF DSC cavity helium temperatures Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-59 and pressures presented in ISFSI FSAR Volume I [3-15], Tables 8-2a and 8-2b, for normal and off-normal conditi ons. Both temperature and pressure are expected to continue decreasi ng over the period of extended operation. Sheltered (SH) - Protected environment, such as HSM interior or TC stored indoors in an uncontrolled envir onment. A sheltered environment is a protected environment with no direct exposure to sun, wind, or precipitation. A shelter ed environment may contain moisture and salts or other contaminants from the external ambient air. The temperature inside the HSM depends on the ambient air tem perature and the heat load of the loaded canister. It may range from ambient air te mperature to about 382 °F at the beginning of storage (from Table 8-4 of ISFSI FSAR Volume II

[3-15], based on DSC shell maximu m temperature for the maximum design basis heat load of 13.5 kW and 117 °F ambient conditions

temperature). The corresponding maximum concrete temperature is about 241 °F (from Table 8-4 of ISFSI FSAR Volume II [3-15]). Components exposed to the HSM sheltered envir onment (interior side of the HSM walls, HSM steel, and DSC external shell assembly components) are exposed to neutron and gamma radiation to a lesser extent than those of the interior cavity of the DSC. Te mperatures and radiation sources are expected to decrease over the PEO. Embedded or Encased (E-C, E-M, E-NS , FE) - This environment applies for materials that are embedded or encased (sealed) inside another

material (e.g., concrete, metal, or neutron shielding). These include rebar and anchorage embedded in the HSM concrete, DSC bottom shield plug

encased between the inner and outer co ver plates, NS-3 solid neutron shielding material encased in the TC lids and between the TC neutron

shield jacket and the structural shell, and the lead encased between the inner liner and the structural shel l of the TC. Embedded or encased environments are exposed to radiation. The radiation source is expected

to decrease over the period of extended operation. External (OD) - During storage, t he exterior surfaces of the HSM are exposed to all weather conditions, incl uding insolation, wind, rain, snow, and plant-specific ambient air conditions, including moist atmospheric air, ambient temperatur es, and humidity. Underground (GW) - At the Rancho Seco ISFSI, the HSMs are installed on a reinforced concrete basemat, which is constructed on compacted, engineered fill. As discussed in C hapter 2, the concrete basemat accessible areas above-grade and inaccessible areas below-grade are

within the scope of Rancho Seco ISFS I renewal. The ISFSI basemat that is located below grade could be exposed to a groundwater/soil environment.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-60 The environments considered in the AMR are the environments that the Rancho Seco SSCs and associated s ubcomponents normally experience.

Environmental stressors that are conditions not normally experienced (such as extreme cold), or that may be caused by a design or fabrication condition, are considered event-driven and are not aging-related. Such event-driven situations would be evaluated and correct ive actions, if any, implemented at the time of the event.

3.3.2 Identification

of Aging Effects Requiring Management After the component material/environment combinations are determined, potential aging management effects are determined. E ngineering lit erature is reviewed to identify expected aging degradation mechanisms for different materials and environments.

Aging effects are the m anifestation of aging me chanisms. In order to effectively manage an aging effect, it is necessary to determine the aging mechanisms that are potentially at work for a given material and environment combination. Therefore, the AMR process identifies both the aging effects and the associated aging mechanisms that cause them. Some aging mechanisms are only applicable at certain conditions such as high temperature or moisture. Each identified aging mechanism is c haracterized by a set of applicable conditions that must be met for the mechanism to occu

r. Given this evaluation process, each subcomponent that was subjected to AMR was evaluated to determine if the potential aging e ffects and mechanisms were credible considering the various materi al/environment combinations.

The potential aging effects and mechanisms that were considered for the Rancho Seco ISFSI SSCs were based on a nalysis tools and reports provided by EPRI reports, NUREG/CRs, Standardized NUHOMS System-specific operating experience, Rancho Seco specific operating experience and industry operating experience. 3.3.3 Identification of t he Activities Required to Manage the Effects of Aging TLAAs are prepared to assess SSCs that have a time-dependent operating life to demonstrate that the existing licens ing basis remains valid and that the intended functions of the SSCs in the scope of renewal are maintained during the period of extended operation. Time dependency may entail fatigue life (cycles), change in a mechanical property such as fracture toughness or strength of materials due to irradiation, or time-limited operation of a subcomponent. The TLAAs and other suppl emental evaluations are presented in Appendix A.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-61 AMPs are developed for managing the e ffects of aging. As appropriate, an AMP was created to summarize the activi ties or procedures implemented to monitor and manage the aging effects.

The AMPs credited for managing the effects of aging degradation are presented in Appendix B.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-62 3.4 Aging Management Review Results - DSCs This section summarizes the resu lts of the AMR for the in-scope subcomponents of Rancho Seco DSCs (FO, FC, FF and the GTCC DSC). The in-scope DSC subcomponents and their int ended functions are summarized in the scoping evaluation Chapter 2, Table 2-6. (MAPS designations in parentheses, if different).

The DSC performs the following intended functions: CC (CR) Provides critical ity control of spent fuel HT (TH) Provides heat transfer PB (CO) Directly or indirectly maintains a pressure boundary (confinement) SH Provides radiation shielding SS (SR) Provides structural support (structural integrity) RE Provides retrievability of SFAs The GTCC DSC is designed to store greater than Class C waste and thus criticality is not an intended function for the GTCC DSC. 3.4.1 Description of DSC Subcomponents The Rancho Seco DSCs consist of two main subcomponents: the shell assembly and the internal basket assembly. A description of the three DSC types and the GTCC DSC is provided in Section 2.4 of Chapter 2.

The following DSC subcomponents are excluded from further AMR because either they were scoped out or they do not support t he intended function of the DSC during the PEO: Dry film lubricant on the exterior sliding surfaces of the DSCs/GTCC Quick-connect fittings for siphon and vent ports Siphon tubing Electroless nickel coating on carbon steel subcomponents Thread lubricant, tape, or sealant Non-structural stainless steel plugs or bolts 3.4.2 DSC Materials Evaluated The materials of construction for the subcomponents of the DSCs are presented in Chapter 2, Table 2-6 and summarized in Table 3-2. 3.4.3 Environments for the DSC The environments that affect the DSC subcomponents, bot h externally and internally, are those that are norma lly (continuously) experienced and are described below:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-63 External Each DSC is positioned for long-term storage inside an HSM. As such, the external surfaces of the DSC (shell, top and bottom outer cover plates, grapple assembly, and associated welds) are exposed to the HSM interior (i.e., sheltered) environment. This is a pr otected environment with no direct exposure to sun, wind, or precipitation. The internal HSM environment may contain moisture and salts or other contaminants from the external ambient air. The maximum initial DSC shell assembly temperatures (at the beginning of

storage) for normal conditions of stor age inside the HSM are summarized in Rancho Seco ISFSI FSAR, Volume II, T able 8-5 [3-15]. Using 70 °F ambient conditions for the long-term normal conditions, the maximum DSC shell temperature is calculated to be 305 °F in the FO and FC DSC, which bounds

the FF DSC and GTCC. These surface temperatures continuously decrease

from the beginning of storage into the PEO. The DSC shell assembly components are exposed to neutron and gamma

radiation. Appendix A documents t he analyses performed to evaluate the effects of neutron fluence and gamma r adiation on the mechanical properties

of the DSC subcomponents. The evaluati on takes credit for source strength decay over a total service (storage) life of 100 years, and the energy deposition is integrated over the same period. The maximum neutron fluence on the DSC shell assembly is reported in Table A.2 of Appendix A. This maximum value is well below the leve l of concern for embrittlement of stainless steel of 1 x 10 18 neutrons/cm 2 per EPRI Report 1015078, Plant Support Engineering: Aging Effects for Structures and Structural Components (Structural Tools) [3-33].

Internal The internal components of the DSC (basket assembly, other shell assembly subcomponents, such as inner top and bottom cover plates, shield plugs, siphon and vent block and cover plates, and associated welds) are exposed to the inert gas (helium) environment insi de the DSC cavity. The average helium temperature in the DSC cavity reaches 524 °F at the beginning of storage (ISFSI FSAR, Volume I, Table 8-2a, [3-15]) for the F O/FC DSC at 70 °F ambient under normal storage conditions. Al so, the helium gas pressure is 3.9 psig at the beginning of storage (ISFSI FSAR, Volume I, Table 8-2a, [3-15]) for the FO/FC DSC at 70 °F ambient under normal storage conditions. The FO/FC DSC thermal analysis result s bound the FF and GTCC DSC results.

The helium gas temperature and pre ssure decreases over the PEO. The DSC internal components are exposed to significant neutron and gamma

radiation. The maximum neutron fluence in the basket assembly center fuel compartments is reported in Table A.2 of Appendix A. This maximum value is well below the level of concern for embr ittlement of stainless steel of 1 x 10 18 neutrons/cm 2 [3-33].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-64 3.4.4 Aging Effects Requiring Management for the DSCs 3.4.4.1 Materials The materials of construction for the DSC subcomponents that are subject to further AMR include stainl ess steel and carbon steel. This section describes the potential aging effects that could, if left unmanaged, cause degradation of DSC subcomponents and result in loss of the component intended function(s). The potentia l aging effects that could cause loss of intended function(s) are: Loss of Material Cracking Change in Material Properties Aging mechanism(s) that could lead to aging effect(s) for steel components were determined using technical publications, NUREG/CRs, and EPRI reports.

Aging mechanism(s) were evaluated to determine if the mechanism(s) could lead to an aging effect requiring management. Loss of Material Aging Effects Assessment Loss of Material due to general corrosion - carbon steel Loss of Material due to crevice co rrosion - carbon steel and stainless steel Loss of Material due to pitting corro sion - carbon steel and stainless steel Loss of Material due to galvani c corrosion - dissimilar metals Cracking Aging Effects Assessment Cracking due to Stress Corrosion Cracking (SCC) - stainless steel Cracking due to thermal fatigue -

carbon steel and stainless steel Change in Material Properties Aging Effects Assessment Change in material properties du e to thermal aging -carbon steel and stainless steel Change in material properties due to irradiation embrittlement-carbon steel and stainless steel 3.4.4.2 Discussion of Aging Mechanisms General Corrosion Carbon steel surfaces in contact with mo ist air or water are subject to general corrosion. The rate of general corrosion is governed by several factors, such as the moisture of the air, the salinity level of the ai r, the temperature of the metal surface.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-65 The carbon steel subcomponents of t he DSC include the top and bottom shield plugs and other top shield plug assembly parts (e.g., casing plates, stiffeners, etc., for DSCs with lead-encased shield pl ugs). These carbon steel parts are completely enclosed within the DSC cavity in an inert gas environment and will, therefore, not be s ubjected to general corrosion. Thus, loss of material due to general corrosi on is not an aging effect requiring management for the DSC.

Crevice Corrosion Crevice corrosion is localized corrosion within crevices or shielded areas. It occurs most frequently in connections, lap joints, splice plates, bolt threads, under bolt heads, or points of contact between metals and non-metals, and it is associated with a stagnant or low flow solution (an electrolyte). To function as a corrosion site, the crevice must be wide enough to permit liquid entry and

narrow enough to maintain a stagnant zone, typically a few thousandths of an

inch or less [3-33].

Crevice corrosion is strongly dependent on the presence of dissolved oxygen. Any surface exposed to atmospheric c onditions will be saturated in oxygen above the threshold levels for crevice corrosion to occur (0.1 parts per million (ppm)). This form of corrosion, as t he name implies, requires a crevice in which contaminants and corrosion products can concentrate. In addition to

oxygen, moisture is required for t he mechanism to operate. Typically, atmospheric pollutants and contaminants, both indoors and outdoors, are insufficient to concentrate and thereby promote crevice corrosion. Alternating wetting and drying is particularly harmful because this leads to a concentration of atmospheric pollutant s and contaminants [3-33]. The DSC is located within the shelter ed environment of the HSM interior, and DSC decay heat will heat the air preventing the accumulation or condensation of moisture inside the HSM. However, since the DSC decay heat will progressively decrease during the period of extended operati on, the presence of moist air cannot be ruled out. Air with enough moisture can facilitate the loss of material in steel caused by crevice corrosion. Moist air in the absence

of condensation also is potentially aggressive. Therefore, this aging mechanism is potentially operative on the external surface of the stainless steel DSC shell assembly around the support rail areas. For this reason, loss of material due to crevice corrosion in stainless steel is an aging effect requiring management. DSC steel subcomponents located inside the DSC

cavity are in an inert environment and ar e not subject to crevice corrosion.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-66 Pitting Corrosion Pitting corrosion is a localized corrosi ve attack in aqueous environments containing dissolved oxygen and chlorides. When passivity breaks down at a spot on a metal surface, an electrolytic cell is formed with the anode at the minute area of active metal and the ca thode at the cons iderable area of passive metal. The large electric potential difference between the two areas accounts for considerable flow of curr ent with rapid corrosion at the anode. The anode does not spread because it is surrounded by passive metal, and as

the mechanism continues, it penetrates deeper into the metal, forming a pit. Pitting corrosion is more common with passi ve materials, such as austenitic (300 Series) stainless steels than with non-passive materials, such as carbon steels [3-33].

Oxygen is required for pitting initiation. Areas in which aggressive species can concentrate, that is, locations of frequent or prolonged wetting or of alternate wetting and drying, are particularly suscept ible to pitting. Most pitting is the result of halide contamination, with chlorides, bromides, and hypochlorites being prevalent [3-33].

The DSC is located within the shelter ed environment of the HSM interior and DSC decay heat will heat the air, limiting the accumu lation or condensation of moisture inside the HSM. However, because the DSC decay heat will progressively decrease during the period of extended operati on, the presence of moisture on the DSC service cannot be ruled out. Air with enough moisture can facilitate the loss of material in steel caused by pitting corrosion. Moist air

in the absence of condensation also is pot entially aggressive. Therefore, this aging mechanism is potentially operativ e on the external surface of the stainless steel DSC shell assembly; henc e, loss of material due to pitting corrosion in stainless steel is an aging effect requiring management. The DSC steel subcomponents located inside the DSC cavity are in an inert environment and are not subj ect to pitting corrosion.

Galvanic Corrosion Galvanic corrosion occurs when two or more metals of differing electrochemical potential are in electr ical contact in a conductive fluid (the

presence of an electrolyte). Under thes e conditions, an electrolytic cell is formed transmitting an electrical current between an anode and a cathode.

Loss of material occurs when ions of the metal with the lower potential, the anode, are being depleted and deposited on to the more noble metal, the cathode. Galvanic corrosion will not occu r in a dry environment; an electrolyte must be present and remain liquid. The ratio between surface areas of the metals in contact is of significant importance. Corrosion rates increase when the more noble metal has a greater surf ace area than the more active metal in the presence of moisture and water [3-33].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-67 One instance of the DSC components coming in contact with dissimilar materials that are exposed to the shelte red environment inside the HSM is the graphite lubricant used on the DSC suppor t structure rail faces. Because the graphite lubricant is noble relative to t he rail face and the canister shell, this could induce galvanic corrosion of the DSC shell. Even though there is no reported operating experience of stainless steel degradation where a graphite lubricant film causes galvanic corrosi on, loss of material due to galvanic corrosion of the DSC stainless steel shell is an aging effect requiring management in a sheltered environment. Stress Corrosion Cracking SCC is a localized non-ductile cracking failure resulting from an unfavorable combination of sustained tensile stre sses, material condition, and the presence of a corrosive environment.

SCC is a phenomenon that occurs in austenitic stainless steels, but becomes significant only if tensile stress and a corrosive environment exist. In most cases, SCC involves crack initiation, subcritical crack growth, and failure when the crack reaches a critical size and the tensile strength of t he remaining material is exceeded. In terms of corrosive environment, dissolved oxygen, sulfates, fluorides, and chlorides can provide the necessary environment for SCC to occur [3-33]. Based on the NUHOMS System OE history and other generic industry experience presented in Section 3.2, objective evidence does not exist to exclude SCC as an active aging mechanism. Therefore, this aging mechanism is potentially operative on the external su rface of the stainless steel DSC shell assembly; hence, loss of material due to SCC in stainless steel is an aging effect requiring management.

Note: SCC, when initiated by chlorides as the corrosive environment, or CISCC, is a site-specific aging mechanism, which has been evaluated separately for the Rancho Seco ISFSI in the next section.

Chloride Induced Stress Corrosion Cracking Operating experience, documented in NR C Information Notice 2012-20 [3-10], has shown that austenitic stainless st eels under tensile stresses are known to be susceptible to SCC when exposed to chlorides in the environment. A literature survey revealed failures attribut ed to CISCC in the types of austenitic stainless steels typically used in dry cask storage canisters when these

materials are exposed to atmospheric conditions near saltwater bodies. This phenomenon is of concern at temperature and relative humidity combinations that allow the chloride compounds to de liquesce. It is under stood that airborne salts could deposit on the material surface, then form chloride-rich

deliquescent brines in conditions of high relative humid ity. Laboratory data suggest that CISCC is of particular concern as the canister surface temperature decreases to the level where salt will deliquesce.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-68 Airborne chloride salts (from the seawater or other ch loride sources, such as salted-roads due to use of deicing salts or effluents from cooling tower water) may enter the HSM interior, via the HSM external vents, and deposit and accumulate on the canister surface.

The moisture or aqueous environment required to support the electrochemical reactions associated with CISCC can result from deliquescence of the salts, wherein dry sa lt absorbs moisture from the air to form a saturated solution. ISFSIs located in coastal regions near the ocean may be subjected to airborne chloride salts generated by the surf action (splashing water) on the sea shore and/or by the whitecaps on the open sea and transported inland by wind action.

Initiation of CISCC for austenitic stainl ess steels is affected by three major environmental parameters, including canist er surface temperature, relative humidity, and chloride salt concentrati on deposited on the cani ster surface. A susceptibility evaluation, Calculati on 502917-AMR03, Revision 0, "Rancho Seco ISFSI Site Chloride-Induced Stress Corrosion Cracking Susceptibility Ranking" [3-63], has been performed for the Rancho Seco ISFSI in accordance with the methodology described in EPRI Report 3002005371, Susceptibility Assessment Criteria for Chloride-Induced Stress Corrosion Cracking (CISCC) of Welded Stainless Steel Canisters for Dry Cask Storage Systems [3-62] to determine the CISCC susceptibilit y ranking at the Rancho Seco site.

The results of this susceptibility evaluat ion show that the Rancho Seco ISFSI has a CISCC susceptibility ranking of "2." This is a relatively low ranking on the scale of 1-10, with "10" being the most susceptible to CISCC affects. This low ranking means that the potential for deposition of chloride aerosols on the DSC surface at the Rancho Seco ISFSI is very low. This conclusion is further supported by the laboratory results of surrogate Cl

- samples taken from the Auxiliary and Turbine buildings descri bed in Section 3.2.4.4. In addition, no evidence of aging-related degradati on was observed during the pre-application inspection of a HSM interi or as discussed in Section 3.2.4.2.

Based on the results of the susceptibilit y evaluation [3-63], the potential for CISCC on the external surface of the Rancho Seco DSC shell assembly is minimal. Therefore, cracking due to CISCC is not an aging effect requiring management.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-69 Gamma Radiation Effects on Canister Corrosion The interaction of gamma radiation wit h the water adsorbed in the hygroscopic salts on the canister surface can generate radiolytic oxidizi ng products (e.g., hydrogen peroxide, nitric acid) via radi olysis of the water and moisture. As radiolytic products are generally oxidiz ing in electrochemistry, the corrosion process of the stainless st eel canister could be affected by gamma radiation.

Of more importance with stainless steel could be the possibility of radiation-induced localized corrosion including pitting corrosion, crevice corrosion, and SCC of the stainless steel canister during storage.

[ ] As a result, gamma radiolysis of water on the canister surf ace and its effect on canister SCC and crevice corrosion will be m anaged by managing the aging effects due to pitting corrosion, crevice corrosion, and SCC.

Thermal Fatigue Thermal fatigue is the progressive and lo calized structural damage that occurs when a material is subjected to cyclic loading associated with thermal cycling. The only source of potential thermal fa tigue of the DSC is ambient seasonal and daily temperature fluctuation. T he DSC does not experience the full amplitude of ambient temperat ure cycles, and a gradual, long-term temperature decrease occurs during the c ourse of storage. The seasonal and daily variations in ambient conditions are ameliorated by the thermal mass of the HSM.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-70 Appendix A documents the evaluation of the DSC pressure boundary subcomponents for pressure and temperat ure fluctuations in accordance with the provisions of NB 3222.

4(d) of the ASM E B&PV Code,Section III, Division 1, 1992 Edition, with Addenda through 1993

[3-14]. As provided by NB 3222.4(d) of the ASME B&PV Code, fatigue effects need not be specifically evaluated provided the six cr iteria in NB 3222.4(d) are met. This TLAA is performed considering a 60-year serv ice life using maximum initial DSC pressures (bounding for all DSC types) and temperatures at the beginning of storage, and assumes that the maximum pressures and temperatures do not decrease over time, but may fluctuate due to ambient condition changes. The TLAA shows that all the six criteria of NB 3222.4(d) are met. Therefore, cracking of the DSC pressure boundary subcomponents due to thermal fatigue is an aging effect managed via a TLAA. Thermal Aging The maximum temperatures of the DS C internals (basket components) are limited by the cladding tem perature limit at the beginn ing of storage (e.g., 379 °C (714 °F) [3-15]). The DSC subcom ponent initial material temperatures for normal conditions of storage were shown to be within the temperature

limits allowed by the ASME B&PV Code (for Code materials) or were

evaluated to show they can perform their safety function (for non-Code materials, such as neutr on absorber materials).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-71 The maximu m basket temperature in t he Rancho Seco ISFSI FSAR, at the beginning of storage, for normal conditions of storage is 714 °F (379 °C) [3-15, Volume II, Table 8-5).

[ ] the basket stainless steel welds have adequate fracture toughness with sufficient margin and remain within the range required for ferritic materials by the ASME B&PV Code. Furthermore, basket component stresses are not affected by thermal aging because, as reported in the above references, thermal aging has little or no change on tensile strength properties.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-72 NUREG/CR-6745, Dry Cask Storage Char acterization Project-Phase 1:

CASTOR V/21 Cask Opening and Examin ation [3-42] provides additional substantiation of the performance of stainless steel we lds subjected to thermal aging. NUREG/CR-6745 [3-42] documents results of inspection of the CASTOR V/21 cask interior, including the internal basket. The CASTOR V/21 basket is fabricated from welded st ainless steel. The purpose of the examination was to inspect for evi dence of basket degradation caused by

long-term storage (from 1985 to 1999). The peak cladding temperature at the

beginning of long-term storage was 344

°C (651 °F) and reached 415 °C (779 °F) for a short time period during the in itial heat transfer performance tests.

The 1999 inspections performed after long-term storage found no evidence of welds degradation due to thermal aging.

Based on the above justifications, thermal aging embrittlement of the fuel basket welds is not expected to affect the safety function or performance of the basket structure.

As noted in the table below, the boundi ng maximum temperature of the DSC shell is 423 °F (217 °C) at the beginning of storage.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-73 DSC Type Ambient Temp (°F)

DSC Shell Temp (°F)

ISFSI FSAR, Volume II [3-15] 24P (FO & FC-DSCs)(1) 70 305 Table 8-5 117 423 Table 8-5 (1) The FF-DSC and the GTCC DSC have much lower decay heats than FO/FC DSCs and will therefore have lower temperatures than the values shown above. This temperature is significantly below the embrittlement saturation temperature of 400 °C (752 °F) in NUREG/CR-6428 [3-46]. It is also below the lower 335 °C (635 °F) temperature in the "Low temperature thermal aging embrittlement of austenitic stainless steel welds and its electrochemical assessment," [3-47] and "Low temperat ure thermal aging embrittlement of austenitic stainless steel welds," [3-48] tests. Also, in accordance with

NUREG-1801, Revision 2, Final Repor t - Generic Aging Lessons Learned (GALL) [3-12], austenitic steels with service temperature below 482 °F (250 °C) are not susceptible to therma l aging embrittlement. This threshold essentially corresponds to the maximu m DSC shell temper ature of 423 °F (217 °C).

Therefore, change in material properties due to thermal aging (loss of fracture toughness due to thermal aging embrittlement) is not an aging effect requiring management in the PEO for the DSC shell steel components.

Irradiation Embrittlement High neutron radiation c an cause loss of fracture toughness in steel (i.e., increases in the nil-ductility temperat ure). However, as demonstrated in the supplemental analysis in Appendix A, the neutron fluence seen by the metal components of dry fuel storage systems is generally orders of magnitude lower than that required to produce any significant effect. Hence, neutron radiation is unlikely to be a significant aging effect for th e steel components.

Gamma radiation does not have any significant impact on the properties of steel. Therefore, change in material proper ties due to irradiation embrittlement is not an aging effect requiring management in the PEO for the DSC carbon and stainless steel components.

Creep Creep is a time-dependent st rain (deformation) in metals occurring under constant load at constant temperature. There are three stages of creep during which the shear and elastic moduli of t he material decrease and the Poisson

ratio increases. An increase in either stress or temperature accelerates creep.

If stress or temperature is increased beyond certain levels, the increased

deformation can eventually result in failure.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-74 Metallic materials are generally considered to be subject to creep under conditions of extended exposure to stress and temperature in excess of a

homologous temperature of 0.4T m , where T m is melting point in degree Kelvin.

For steel, with a melting point of 1516 °C (2760 °F) or 1789 K, temperatures of at least 716 K or 443 °C (829 °F) are requi red to initiate creep. For austenitic stainless steel, with a melting point of 1425 °C (2597 °F) or 1698 K, temperatures of at least 679 K or 406

°C (763 °F) are required to initiate creep. The maximum temperatures of the DSC basket components are limited by the cladding temperature limit at the beginning of storage (e.g., 379 °C (714 °F) [3-1]. Hence, creep is not an aging mechanism requiring management for the steel and stainless steel subcomponents in the DSC during the PEO. For aluminum (Al) alloys, this transla tes to a temperature of approximately 100 °C (212 °F). Hence, the only materi al of interest for assessment of degradation due to creep is aluminum. The DSC assembly does not contain any aluminum subcomponent s, other than BORAL neutron absorber plates, which are provided for crit icality control. BORAL consists of a core of uniformly distributed boron carbide and aluminum alloy particles sandwiched between a surface cladding of aluminum al loy on both sides of the core. As discussed in Section 3.4.2.5 of the MAPS Report [3-68], since the neutron poison plates do not serve a structural function and are not expected to be under loads other than their own weigh

t. Hence, the impact of creep on the criticality control function of BORAL is not credible, so creep is not an aging effect requiring managem ent for the DSC. 3.4.4.3 Neutron Absorber Materials Evaluation Only the Rancho Seco FO and FC DSCs contain fixed BORAL neutron absorber plates, per Rancho Seco ISFSI FSAR, Volume I, Chapter 3 [3-15].

The safety analyses do not rely upon the mechanical strength of the neutron absorber materials. The performanc e of the neutron absorber's design function is ensured only by the pres ence of B-10 and the uniformity of its distribution, which are verified with te sting requirements specific to each

material.

Appendix A determines the amount of B-10 depleted in the poison plates due to neutron irradiation during 100 year s of storage. Alt hough the license renewal period is 40 years, this evaluat ion takes into account the initial 20 years and an additional 80 years of stor age, for a total of 100 years. The evaluation considers a bounding neutron irradiation rate with the least amount of B-10 content available in poison pl ates and computes the reaction rate density. The evaluation shows that a negligible amount of B-10 in the poison plates is depleted after 100 years of i rradiation. The result of this TLAA demonstrates that the ability of the BORAL neutron absorber plates to maintain sub-criticality remains una ffected over the desired duration of storage. Therefore, loss of criticality control due to boron depletion is an aging effect managed via a TLAA.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-75 3.4.4.4 Coating Evaluation There are no coatings applied to the DSC shell assembly external surfaces (exposed to the HSM sheltered envi ronment). Carbon steel subcomponents that are part of the DSC shell assembly (e.g., A36 shield plugs, lead shield plug casing plates and the spacer discs) that are not sealed by other materials

are coated with electroless nickel. Th is coating was intended to mitigate corrosion during loading/unl oading operations when the DSC is in the spent fuel pool. The nickel coating limited rust contamination of the pool water, but does not perform any important to safe ty dry storage function. While the DSC is in storage within an HSM, the electroless nickel coat ings are not exposed to water. Therefore, the nickel is not subj ect to a corrosive environment during the PEO and no aging management is required for the electroless nickel coatings within the DSC. 3.4.4.5 Temporary Attachment Evaluation DSC fabrication is in accordance with ASME B&PV Code Section III NB-4000

[3-14]. Welding of any temporary a ttachments and their removal is per

NB-4435, which requires exam ination of the base meta l by liquid penetrant or magnetic particle method in accordanc e with NB-5110 after the temporary attachment is removed. The accept ance criteria of NB-5340 or NB-5350, whichever is applicable, ensure that the restored surface is free of any relevant indications.

The concern about temporary attachment welds is attributed to thermal sensitization and residual stresses resu lting from initia l welding of the temporary attachment and high local surf ace temperatures that can occur at the abrasive-to-surface interface during removal of the temporary attachments via grinding. Although the lo cal temperature can be above the sensitization range at the location of the weld, the heat affected zone (HAZ) is limited to approximately a 0.125-inch depth, which is much less than the seam welds

that extend through the thickness. T hus, when the seam welds are determined to be acceptable, the suitability of all temporary attachments also is demonstrated.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-76 Regarding the effects of gri nding as compared to welding, the relatively low peak heat input limits the opportunity for carbide precipitation to occur. The depth of the grinding HAZ, generally less th an 0.03 inch [3-55] is substantially less than the temporary attachment weld and relative to the nominal thickness of the DSC shell (0.625 inch). The tens ile stress field required to promote SCC would result from the h eat of welding and/or gri nding, causing brief local compressive yielding of the substrate at and immediately beneath the component's surface, which would revert to tensile stress once the material returns to ambient temper ature. These tensile stre sses would be confined to a very narrow near-surface region of the DSC shell thickness. Even considering that crack initiation could occur, any lo cal cracking would be arrested at a very shallow depth.

Since the welding and removal of temporary attachments is performed per the provisions of the ASME B&PV Code, which inclu des examinations to demonstrate no relevant indications on the shell surface, and because such cracking, if it did occur, would not propagate to sufficient depth to compromise the performance of the confinement boundary, there is a low risk that SCC of significant depth will occu r at these locations.

Furthermore, ASME B&PV Code,Section XI excludes temporary atta chments from periodic inspection, as specified in Table IWE-2500-1.

Therefore, it is not necessary to search for temporary attachment locations specifically for inspection. 3.4.4.6 Summary of Applicable Aging Effects Requiring Management for DSCs The following aging effects and mechanisms are applicable for DSC steel components:

Loss of Material Loss of material due to crev ice corrosion - stainless steel Loss of material due to pitti ng corrosion - stainless steel Loss of material due to galvanic corrosion - Nitronic 60 rail plate and graphite lubricant Cracking Cracking due to radiation induced stress corrosion cracking - stainless steel Cracking due to thermal fatigue - stainless steel DSC pressure boundary Loss of Criticality Control Loss of criticality control due to boron depletion - Boral

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-77 3.4.5 Aging Management Activities for DSCs This section describes the AMAs result ing from the AMR. Those areas of the AMR that can be addressed by TLAAs are addressed in Section 3.4.5.1.

Section 3.4.5.2 describes the AMPs that are focused on the examination of the external surfaces of th e DSC. The basket internal components are not subject to degradation as they are maintained in an inert gas environment. This was confirmed by a demonstration projec t documented in NUREG/CR-6745 [3-42]

and EPRI Report 1002882, Dry Cask Storage Characterization Project, Final Report, Electric Power Research Institute [3-34], which was conducted to

provide the basis for ensuring that the internals are not degrading to unacceptable levels during t he extended stor age period. 3.4.5.1 DSC TLAAs The following are summary descriptions of the TLAAs that were identified and prepared based on the AMR of the DSC: A. Fatigue Evaluation of t he DSCs (see Appendix A)

This TLAA documents the evaluation of the DSC pressure boundary subcomponents for pressure and temper ature fluctuations in accordance with the provisions of NB 3222.4(d) of the ASME B&PV Code [3-14]. As provided by NB 3222.4(d) of the ASME B&PV Code, fatigue effects need not be specifically evaluated provided t he six criteria in NB 3222.4(d) are met. This evaluation is performed considering a 60-year service life using maximum bounding initial DSC pre ssures and temperatures (at the beginning of storage). This evaluation s hows that the six criteria of NB 3222.4(d) are met. B. Boron Depletion This TLAA is performed to determine t he amount of boron depletion in the FO and FC DSC poison plates during the PEO. Although the license renewal period is for 40 years, this evaluation takes into account the initial 20 years of storage period and an addi tional 80 years of storage period, for a total of 100 years.

The evaluation considers a bounding neutro n irradiation rate with the least amount of B-10 content available in the poison plates and computes the reaction rate density. The evaluation shows that the de pleted amount of B-10 is negligible. 3.4.5.2 DSC Aging Management Programs The DSC External Surfaces AMP, descri bed in Appendix B.3, is employed to manage the aging effects and mechanisms for the DSC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-78 The scope of the DSC AMP, parameters to be monito red and the criteria for selecting a DSC for the AMP are descri bed in Appendix B.3, Section B.3.5.

Rancho Seco will implement the first (baseline) DSC inspections under this AMP on the selected DSCs in accor dance with the program schedule as

described in Appendix B.3, Section B.3.5. 3.4.6 Summary of the AMR Results for the DSCs Table 3-3, Table 3-4, Table 3-5 and Table 3-6 summarize the results of the AMR for the FO, FC, FF and GTCC DSC respectively.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-79 Table 3-2 FO, FC FF and GTCC DSC Materials SSC DSC Shell Assembly Subcomponents Material FO, FC and FF DSC Cylindrical shell, inner and outer top cover plates, inner and outer bottom cover plates, grapple ring, grapple ring support, siphon and vent block, siphon and vent cover plates, support ring, lifting lugs, reinforcing pads, and other miscellaneous parts. Stainless steel FO DSC Top and bottom shield plugs Carbon steel (coated with electroless nickel, unless encased) FC DSC Top and bottom shield plug assemblies Lead shield plug with stainless steel casing (bottom shield plug assembly) Lead shield plug with carbon steel casing (top shield plug assembly) SSC Basket Assembly Subcomponents Material FO, FC, and FF DSC Spacer discs, support rods, support plates Carbon steel coated with electroless nickel Guidesleeves, oversleeves, spacer sleeves, FF Can Stainless steel Neutron absorber plates Boral (Except FF-DSC) SSC GTCC Shell Assembly Subcomponents Material GTCC DSC Cylindrical shell, outer top and bottom cover plate, bottom shield plug, grapple ring and grapple ring support. Stainless steel siphon and vent port cover plates, top shield plug Carbon steel (coated with electroless nickel) Basket Assembly Subcomponents Material Perforated basket shell, lifting lugs, siphon tube Carbon steel (coated with electroless nickel)

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-80 Table 3-3 Rancho Seco FO-DSC Intende d Functions and AMR Results (2 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Cylindrical Shell PB, SH, SS, HT, RE Inert Gas / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Outer Bottom Cover SH, SS, RE Sheltered / Embedded Loss of Material, Cracking AMP Main Assembly Grapple Ring SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Grapple Ring Support SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Inner Bottom Cover PB, SH, SS Inert Gas / Embedded Cracking TLAA Main Assembly Spacer Discs (Type "A" "B" and Type "C") CC, SS Inert Gas None Identified None Required Main Assembly Guide sleeve CC, SS, HT Inert Gas None Identified None Required Main Assembly Oversleeve CC, SS, HT Inert Gas None Identified None Required Main Assembly Neutron Absorber Sheet CC, HT Inert Gas Loss of Criticality Control TLAA Main Assembly Support Rod CC, SS Inert Gas None Identified None Required Main Assembly Shear Key SS, RE Inert Gas None Identified None Required Main Assembly Extension Plate CC, SS, HT Inert Gas None Identified None Required Main Assembly Key SS Inert Gas None Identified None Required Main Assembly Siphon & Vent Block PB, SH, SS Inert Gas Cracking TLAA Main Assembly Lifting Lug SS Inert Gas None Identified None Required Main Assembly Support Ring SS Inert Gas None Identified None Required Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-81 Table 3-3 Rancho Seco FO-DSC Intende d Functions and AMR Results (2 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Top Shield Plug SH, SS Inert Gas None Identified None Required Main Assembly Bottom Shield Plug SH, SS Embedded None Identified None Required Main Assembly Inner Top Cover Plate PB, SH, SS Embedded / Inert Gas Cracking TLAA Main Assembly Outer Top Cover Plate PB, SH, SS, RE Embedded / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Siphon & Vent Port Cover Plate PB, SH, SS, HT Inert Gas /

Embedded Cracking TLAA Main Assembly Top and Bottom End Spacer Sleeve CC, SS Inert Gas None Identified None Required Main Assembly Spacer Sleeves (Type 1, 2, 3, 4, 5, 6) CC, SS Inert Gas None Identified None Required Main Assembly Stop Plate SS Inert Gas None Identified None Required Main Assembly Plate 0.085 Thk SS Inert Gas None Identified None Required Notes: (1) Abbreviations for Intended Function Column: PB - Directly or indirectly maintains a pressure boundary (confinement) SH - Provides radiation shielding CC - Provides criticality control of spent fuel SS - Provides structural support HT - Provides heat transfer RE - Retrievability (2) Only in-scope subcomponents from Chapter 2, Table 2-6 are listed in this table.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-82 Table 3-4 Rancho Seco FC-DSC Intende d Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Cylindrical Shell PB, SH, SS, HT, RE Inert Gas / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Outer Bottom Cover SH, SS, RE Sheltered / Embedded Loss of Material, Cracking AMP Main Assembly Lead Shielding SH Embedded /

Encased None Identified None Required Main Assembly Grapple Ring SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Grapple Ring Support SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Inner Bottom Cover PB, SH, SS Inert Gas / Embedded Cracking TLAA Main Assembly Bottom Plug Post SS Inert Gas None Identified None Required Main Assembly Spacer Discs (Type "A" "B" and Type "C") CC, SS Inert Gas None Identified None Required Main Assembly Guide sleeve CC, SS, HT Inert Gas None Identified None Required Main Assembly Oversleeve CC, SS, HT Inert Gas None Identified None Required Main Assembly Neutron Absorber Sheet CC, HT Inert Gas Loss of Criticality Control TLAA Main Assembly Support Rod CC, SS Inert Gas None Identified None Required Main Assembly Shear Key SS, RE Inert Gas None Identified None Required Main Assembly Extension Plate CC, SS, HT Inert Gas None Identified None Required Main Assembly Key SS Inert Gas None Identified None Required Main Assembly Siphon & Vent Block PB, SH, SS Inert Gas Cracking TLAA Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-83 Table 3-4 Rancho Seco FC-DSC Intende d Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Lifting Lug SS Inert Gas None Identified None Required Main Assembly Support Ring SS Inert Gas None Identified None Required Main Assembly Inner Top Cover Plate PB, SH, SS Embedded / Inert Gas Cracking TLAA Main Assembly Outer Top Cover Plate PB, SH, SS, RE Embedded / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Siphon & Vent Port Cover Plate PB, SH, SS, HT Inert Gas /

Embedded Cracking TLAA Main Assembly Top Shield Plug Casing SH, SS Inert Gas / Embedded None Identified None Required Main Assembly Top Shield Plug Post SS Embedded None Identified None Required Main Assembly Plate Stiffening SS Embedded None Identified None Required Main Assembly Top and Bottom End Spacer Sleeve CC, SS Inert Gas None Identified None Required Main Assembly Spacer Sleeves (Type 1, 2, 3, 4, 5, 6) CC, SS Inert Gas None Identified None Required Main Assembly Angle, 1-1/4 x 1-1/4 x 1/4 SS Inert Gas None Identified None Required Main Assembly Plate 1.25x1.25 x 1/4 SS Inert Gas None Identified None Required Main Assembly Stop Plate SS Inert Gas None Identified None Required Main Assembly Plate 0.085 Thk SS Inert Gas None Identified None Required Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-84 Table 3-4 Rancho Seco FC-DSC Intende d Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Bottom Plug Top and Side Casing SH, SS Embedded None Identified None Required Main Assembly Plate Stiffening SS Embedded None Identified None Required Notes: (1) Abbreviations for Intended Function Column: PB - Directly or indirectly maintains a pressure boundary (confinement) SH - Provides radiation shielding CC - Provides criticality control of spent fuel SS - Provides structural support HT - Provides heat transfer RE - Retrievability (2) Only in-scope subcomponents from Chapter 2, Table 2-6 are listed in this table.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-85 Table 3-5 Rancho Seco FF-DSC Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Cylindrical Shell PB, SH, SS, HT, RE Inert Gas / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Outer Bottom Cover SH, SS, RE Sheltered / Embedded Loss of Material, Cracking AMP Main Assembly Key SS Inert Gas None Identified None Required Main Assembly Grapple Ring SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Grapple Ring Support SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Inner Bottom Cover PB, SH, SS Inert Gas / Embedded Cracking TLAA Main Assembly Spacer Discs CC, SS Inert Gas None Identified None Required Main Assembly Inner and Outer Support Plate SS Inert Gas None Identified None Required Main Assembly Lead Shielding SH Embedded /

Encased None Identified None Required Main Assembly Bottom Plug Post SS Embedded None Identified None Required Main Assembly Siphon & Vent Block PB, SH, SS, HT Inert Gas Cracking TLAA Main Assembly Lifting Lug SS Inert Gas None Identified None Required Main Assembly Support Ring SS Inert Gas None Identified None Required Main Assembly Inner Top Cover Plate PB, SH, SS Embedded / Inert Gas Cracking TLAA Main Assembly Outer Top Cover Plate PB, SH, SS, RE Embedded / Sheltered Loss of Material, Cracking AMP, TLAA Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-86 Table 3-5 Rancho Seco FF-DSC Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Siphon & Vent Port Cover Plate PB, SH, SS, HT Inert Gas / Embedded Cracking TLAA Main Assembly Top Shield Plug Casing SH, SS Inert Gas Embedded None Identified None Required Main Assembly Top Shield Plug Post SS Embedded None Identified None Required Main Assembly Liner PB, SS Inert Gas None Identified None Required Main Assembly Flange Plate PB, SS Inert Gas None Identified None Required Main Assembly Shear Key SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Top Lid Cover Plate PB, SS Inert Gas None Identified None Required Main Assembly Bottom Lid Adapter Plate PB, SS Inert Gas None Identified None Required Main Assembly Top Lid Lifting Pintle SS Inert Gas None Identified None Required Main Assembly Mesh, 6x6 SS Inert Gas None Identified None Required Main Assembly Washer Plate SS Inert Gas None Identified None Required Main Assembly Spacer Bar SS Inert Gas None Identified None Required Main Assembly Cover Plate SS Inert Gas None Identified None Required Main Assembly Side Lid Plate SS Inert Gas None Identified None Required Main Assembly Bottom Plug Top and Side Casing SH, SS Embedded None Identified None Required Main Assembly Plate Stiffening SS Embedded None Identified None Required Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-87 Table 3-5 Rancho Seco FF-DSC Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Plate Stiffening SS Embedded None Identified None Required Notes: (1) Abbreviations for Intended Function Column: PB - Directly or indirectly maintains a pressure boundary (confinement) SH - Provides radiation shielding CC - Provides criticality control of spent fuel SS - Provides structural support HT - Provides heat transfer RE - Retrievability (2) Only in-scope subcomponents from Chapter 2, Table 2-6 are listed in this table.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-88 Table 3-6 Rancho Seco GTCC DSC Intended Functions and AMR Results Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Environment Aging Effects Requiring Management Aging Management Activity Main Assembly Cylindrical Shell PB, SH, SS, RE Inert Gas / Sheltered Loss of Material, Cracking AMP, TLAA Main Assembly Bottom Shield Plug SH Embedded / Inert Gas /

Sheltered Loss of Material, Cracking AMP Main Assembly Grapple Ring SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Grapple Ring Support SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly Top Shield Plug SH Embedded (Inert Gas None Identified None Required Main Assembly Outer Top Cover Plate PB, SH, SS, RE Sheltered /

Embedded Loss of Material, Cracking AMP Main Assembly Outer Bottom Cover Plate SH, SS, RE Sheltered / Embedded Loss of Material, Cracking AMP Main Assembly Siphon & Vent Port Cover Plate PB, SH, SS Inert Gas /

Embedded Cracking TLAA Notes: (1) Abbreviations for Intended Function Column: PB - Directly or indirectly maintains a pressure boundary (confinement) SH - Provides radiation shielding CC - Provides criticality control of spent fuel SS - Provides structural support HT - Provides heat transfer RE - Retrievability (2) Only in-scope subcomponents from Chapter 2, Table 2-6 are listed in this table.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-89 3.5 Aging Management Review Results - HSM This section summarizes the result s of the AMR of the in-scope subcomponents of the Rancho Seco HSMs. The in-scope HSM subcomponents and their int ended functions are summar ized in the scoping evaluation Table 2-7, Chapter 2.

The evaluation boundary for the HSM includes the entire HSM concrete structure and the steel support struct ure for the DSCs which perform the following intended functions (MAPS designati ons in parentheses, if different): HT (TH) Provides heat transfer SH Provides radiation shielding SS (SR) Provides structural support (structural integrity) RE Provides retrievability of the DSCs 3.5.1 Description of HSM Subcomponents The HSM is a prefabricated, modular, reinforced concrete structure whose primary functions are to provide a means for spent fuel decay heat removal, to provide structural support and environment al protection to the loaded DSC, and to provide radiation shielding protection.

At the Rancho Seco ISFSI, the HSMs are installed in a double side-by-side and back-to-back array, which eliminates the need for the rear shield walls.

The HSM consists of two separate reinforc ed concrete units (a base and roof), and an internal steel structure assembly t hat is used to slide the DSC into and out of the HSM, which also supports the DSC during storage. Other HSM subcomponents include the door, heat shie lds, axial retainer, and the vent screens. Thick shield walls placed at t he end of the HSM array for additional shielding and environmental protection complete the HSM installed configuration.

The base of the HSM has a bottom floor integral with walls to form the base unit. The DSC support structure is a steel frame structure anchored to the side walls and to the bottom floor of the HSM. The inlet and outlet vents are located

in each side of the HSM, at the botto m and top of the base unit, respectively.

The HSMs are installed adjacent to each other with a 6-inch space between them to permit ventilation air flow. The HSM is licensed to store DSCs with

heat loads up to 13.5 kW.

A general description of the HSM subcomponents follows:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-90 Concrete Walls and Roof The HSM is a reinforced concrete stru cture consisting of a base unit and a roof unit. The base unit, which resists loads by frame and shear wall action, and the roof, which is keyed to and c onnected to the base unit, form the load-resisting structural system. The end shie ld walls provide additional impact resistance. The HSM walls, roof slab, and end shield wall thicknesses are established on the basis of radiological shielding requirements.

DSC Support Structure Assembly Structural support of the loaded DSC is provided by a DSC support structure assembly composed of two longitudinal support beam s that extend approximately the full length of the HSM module. For the HSM, the longitudinal beams are supported on the front, rear and mid-span by a steel frame structure that includes th ree crossbeams and six support legs anchored to the floor slab and to the side walls of the HSM. The steel support structure is made of ASTM A36 and ASTM A500 Gr ade B carbon steel coated with an inorganic zinc-rich primer and a hi gh build epoxy enamel finish. Stainless steel rail faces (Nitronic

60) are welded to the longitudinal support beams to provide a sliding su rface for the DSC. Nitronic 60 is selected for its galvanic compatibility with the DSC shell material, and for its resistance to galling. The sliding surface of the DSC support rails is coated with a dry film graphite lubricant.

Heat Shields Metal sheets are provided between the DS C and the HSM concrete to mitigate high concrete temperatures and prevent concrete degradation due to design basis thermal conditions. The heat shields are anchored to the HSM ceiling and interior side walls.

The heat shields are fabricated from hot-dipped galvanized carbon steel. The heat shield is composed of formed and slotted sheets, which are mounted to the ceiling and interior side walls wit h stand-off embedment anchors.

Ventilation System Heat removal is achieved by a comb ination of radiation, conduction and convection. Ambient air enters the interi or of the HSM through two ventilation inlet openings located in the lower region of each side wall and circulates in the interior HSM cavity around the DSC.

Air exits through two outlet openings located in the top regions of each HSM side wall. The HSM gap between the adjacent modules is covered with stainl ess steel wire screens to prevent pests or other foreign material from entering the HSM. This passive system provides an effective means for spent fuel decay heat removal. Thermal monitoring and visual inspection is used to provide indication of a blocked vent condition.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-91 HSM Door Each HSM has an access opening in the fr ont wall to accommodate transfer of DSCs from and into the TC. The access opening is covered by a thick shielded access door.

Cask Restraint System Cask restraint attachment threads ar e embedded in the front face of each HSM to provide restraint of the TC during DSC insertion and retrieval operations.

DSC Axial Retainer Assembly A DSC Axial Retainer Assembly restricts axial sliding of the DSC during seismic events. After insertion of the DSC, a removable DSC Axial Retainer Assembly consisting of a rod is insta lled through a hole in the HSM door. The rod is welded to a plate, which is bolted onto the HSM door exterior. Anchorage and Embedments Anchorages and embedments ar e the steel members, studs, etc., that are embedded in concrete. These anchors also have an exposed surface above

the concrete. 3.5.1.1 Exclude d Subcomponents Dry Lubricant The DSC support rails are coated with a dry film graphite lubricant. A low coefficient of friction minimizes the amount of force applied to the DSC, thus minimizing the possibility of damage to the DSC during insertion and withdrawal. During storage, the lubricant performs no function. The dry film lubricant (categorized as a consumable) is NITS and is not within the scope of renewal.

Thermowells and Temperature Monitoring System Pursuant to Rancho Seco Technical Specifications 5.5.3 [3-17], the licensee must monitor the HSM to identify and corre ct blockage of the vents that would affect the convective removal of heat from the DSC. For Rancho Seco ISFSI, this is accomplished by visual surveill ance and by monitoring the temperature at thermowells embedded in the lower portion of the roof. The calibration and functional verification of the temperature sensors, readouts, and alarms is part of the routine maintenance, and is not in the scope of the renewal.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-92 Lightning Protection Systems Section 8.2.6 of the CSAR [3-7] demonstr ates that lightning strike on the HSM would have no effect on the performance of the Standardized NUHOMS System. Therefore, any lightning protection embedments in the HSM, or lightning protection equipment installed by the licensee, is out of the scope of renewal. This applies to the Rancho Seco ISFSI as well.

Cask Alignment Targets Before sliding a DSC into or out of an HSM, the TC must be aligned with the DSC support structure rails. This alignm ent is accomplished by sights on the TC and alignment targets on the front face of the HSM, and on the ground in front of the HSM. The alignment targets are NI TS, and perform no function during storage. They are, therefore, out of t he scope of the renewal.

Bird Screen Assemblies These assemblies consist of a stainle ss steel screen supported by a stainless steel frame, which is attached to the HSM concrete. The assemblies prevent the entry of debris and animals into t he HSM interior. They are installed to bridge the space between adjacent HSMs.

These items are pa rt of routine surveillance by the licensee in accordance with Technical Specification 5.5.3.3

[3-17], and are, therefore, out of scope of the renewal. 3.5.2 HSM Materials Evaluated The materials of construction fo r the subcomponents of the HSM are presented in Chapter 2, Table 2-7 and summarized in Table 3-7. 3.5.3 Environments for the HSMs The environments that are exper ienced by HSM subcomponents are described as follows:

The HSMs are located outdoor

s. Therefore, the exteri or surfaces of the HSM are exposed to all weather conditions, in cluding insolation, wind, rain, snow, and plant-specific ambient temperature, humidity, and airbor ne contamination.

The Rancho Seco ISFSI is located in an environment that is considered as dry and remote from chloride sources, industrial areas, or areas near the seashore.

The temperature environment for the HSMs is bounded by the temperatures due to design basis heat load of 13.5 kW at the normal ambient temperature range of 0 °F to 101 °F and the off-normal ambient temperature range of -20 °F to 117 °F.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-93 Inside each HSM, considered to be a sheltered environment, subcomponents are protected from outdoor effects (e.g., precipitation), but experience higher

temperatures and radiati on in an air environment.

The HSM interior components are exposed to neutron fluence and gamma radiation. Appendix A documents t he analyses performed to evaluate the effects of neutron fluence and gamma ex posure on the mechanical properties of reinforced concrete components.

Appendix A determines the neutron and gamma fluence on the HSM concrete walls.

The maximum predicted temperatures in the HSM concrete at the beginning of storage, presented in Table 8-4, ISFSI FSAR Volume II [3-15], are 164 °F and 241 °F for normal and off-normal conditi ons, respectively. These initial temperatures are below the temperatur e limit of 300 °F per Section 3.0 of "Safety Evaluation Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradi ated Nuclear Fuel," [3-39] and Section 3.5.1.2 (i)(2)(b) of NUREG-1801 [3-12]. 3.5.4 Aging Effects Requiring Management for the HSMs 3.5.4.1 Concrete This section describes the potential aging effects that could, if left unmanaged, cause degradation of HSM concrete components including reinforcing steel and could result in loss of the HSM concrete component intended functions.

The potential aging effects that could cause loss of intended functions are: Loss of Material Cracking Change in Material Properties Aging mechanism(s) that could lead to aging effect(s) for concrete components were determined using technical literature, related industry

research, and existing OE. Aging mechanism(s) were evaluated to determine

if the mechanism(s) could lead to an aging effect requiring management. Loss of Material Aging Effects Assessment Loss of material in conc rete components is manifested as scaling, spalling, pitting, and erosion. Scaling, spalling, pitting, and erosion are described in ACI 201.1, Guide for Conducting a Visual Inspec tion of Concrete in Service [3-22].

Potential aging mechanisms that can lead to loss of material include: Freeze-thaw Abrasion and cavitation Thermal aging Aggressive chemical attack, includ ing microbiological chemical attack Corrosion of embedded steel (embedments, rebar)

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-94 Delayed ettringite formation (DEF)

Cracking Aging Effects Assessment Cracking is manifested in concrete co mponents as a complete or incomplete separation of the concrete into two or more parts. ACI 201.1 [3-22] provides a description and illustrations of cracking.

Potential aging mechanisms that can lead to concrete cracking are: Freeze-thaw Reactions with aggregates Shrinkage Thermal aging Fatigue Irradiation embrittlement Creep Corrosion of embedded steel (embedments, rebar)

Change in Material Properties Aging Effects Assessment The change in material properties aging effect is manifested in concrete components as increased permeability, increased porosity, reduction in pH, reduction in tensile strength, reduction in compressive strength, reduction in modulus of elasticity, and reduction in bond strength. Potential aging mechanisms that can lead to changes in material properties include: Leaching of calcium hydroxide Thermal aging Aggressive chemical attack, includ ing microbiological chemical attack Irradiation embrittlement Fatigue 3.5.4.2 Discussion of Aging Mechanisms Freeze-thaw Repeated freezing and thawing can cause degradation of concrete, characterized by scaling, cracking, and spalling. The cause is water freezing within the pores of the concrete, creating hydraulic pressure resulting in freeze-thaw degradation. Concrete structures or components loca ted in areas that experience numerous freeze-thaw cycles with significant winter rainfall are more likely to exhibit damage than areas in m ilder climates.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-95 American Society for Testing and Materials (ASTM) C216, Standard Specification for Facing Brick (Solid Ma sonry Units Made from Clay or Shale) [3-18] provides a quantitative measure of the weathering index for various regions of the USA. For Northern California region, the weathering index is less than 50 day-in/yr. Consistent with Section 3.5.1.1 of the MAPS Report

[3-68], for regions with weathering index less than 100 day-in/yr, freeze-thaw degradation is not considered to be significant. Furthermore, Rancho Seco pre-application inspection results show that that even after 15 years of service, the HSM concrete surfaces do not show any visible degradation from freeze-thaw aging effects. Ther efore, freeze-thaw of HSM concrete is not an applicable aging mechanism at Rancho Seco ISFSI.

Abrasion and Cavitation HSM concrete is not subjected to flowing water, which is a requirement for this aging mechanism. Therefore, abrasi on and cavitation are not applicable concrete aging mechanisms.

Thermal Aging The following temperature criteria ar e used for the HSM concrete per the Safety Evaluation Report for the Standardized NUHOMS Horizontal Modular Storage System [3-39]. If concrete temperatures of general or local areas do not exceed 93.3 °C (200 °F) in normal or off-normal condi tions or occurrences, no tests or reduction of concrete strength in the design analysis are required. If concrete temperatures of general or local areas exceed 93.3 °C (200 °F) but would not exceed 149 °C (300 °F), no tests or reduction of concrete strength are required if Type II cement is used and aggregates are selected that are acceptable for concre te in this temperature range. The staff has accepted the following criteria for aggregates (fine and coarse), which are considered suitable:

Satisfy ASTM C33, Standard Specif ication for Concrete Aggregates

[3-27] requirements and other requ irements as referenced in ACI 349, Evaluation of Existing Nuclear Sa fety-Related Concrete Structures

[3-20] for aggregates. Have demonstrated a coefficient of thermal expansion (tangent in temperature range of 21 °C to 37.8

°C (70 °F to 100 °F)) no greater than 1x10-5 cm/cm/°C (6x10

-6 in/in/°F) or be one of the following minerals: limestone, dolomite, marble, basalt, granite, gabbro or rhyolite.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-96 The above criteria do not extend above 149 °C (300 °F) for normal or off-normal temperatures and do not modify the ACI requirements for accident situations. Use of any Portland cement concrete, where normal or off-normal temperatures may exceed 149 °C (300 °F), or where "accident" temperatures may exceed 177 °C (350 °F), requires te sts on the exact concrete mix (cement type, additives, water-cement ratio, aggregates, proportions), which is to be used. The above temperature criteria are consistent with the thermal criteria described in NUREG-1536, Section 3.5.1.2(i), Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility

- Final Report, [3-13].

Under normal conditions of storage, the concrete temperatures will experience a gradual decrease over the service life of the HSM with only daily or seasonal fluctuations due to the ambient conditions. Therefore, thermal aging is not an applicable concrete aging mechanism. Aggressive Chemicals Continued or frequent cyclic exposure to the following aggressive chemical environments is necessary to cause significant degradation: [3-12] Acidic solutions with pH < 5.5 Chloride solutions > 500 ppm Sulfate solutions > 1500 ppm Because the HSMs are installed abov e-grade on a concrete basemat, the HSM concrete is not normally subject to aggressive chemical attack due to prolonged wetting. ISFSI basemats are designed to preclude flooding and are installed above the site's design flood elevation. However, ISFSIs may be located in areas where the exposed surfaces of HSM can be subject to sulfur-based acid-rain degradation. No exp licit acid rain data are available for the Rancho Seco ISFSI from the National Atmospheric Deposition Program/National Trends Ne twork. Therefore, as not ed in Section 3.5.1.5 of the MAPS Report [3-68], aggressive chemical attack is an applicable concrete aging mechanism.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-97 Corrosion of Embedded Steel Corrosion is an electrochemical process involving metal, oxygen, and an electrolyte that results in the formation of ferric oxide, that is, rust. The oxide product, which has a significantly greater volume than the original metal can result in tensile stresses and eventually cause hairline cracking, followed by rust staining, spalling and more cra cking in the concrete surrounding the embedded steel. Typically, the high alkalini ty (pH > 12.5) nature of concrete provides an environment around embedded st eel and steel reinforcement that protects them from corrosion. If the pH is lowered (f or example, pH < 10) due to leaching of alkaline products through cra cks, intrusion of acidic materials, or carbonation, corrosion may occur, ASTM C1562-10, Standard Guide for Evaluation of Materials Used in Extende d Service of Interim Spent Nuclear Fuel Dry Storage Systems [3-32]. Carbonation results from the chemical reaction between the hydrated cement components (mainly calcium hydroxide and calcium-silicate hydrate) and atmospheric carbon dioxide. The reaction

lowers the pH of the concrete pore wa ter to a level where passivity of the embedded steel surface is no l onger supported, leading to initiation of rebar corrosion and subsequent concrete degradation, NUREG/CR-7116, Materials

Aging Issues and Aging Managem ent for Extended Storage and Transportation of Spent Nuclear Fuel [3-50]. Chlorides could also be present in constituent materials of the conc rete mix (that is, cement, aggregates, admixtures, and water), or they may be introduced environmentally, ASTM C1562-10 [3-32].

Corrosion of embedded steel can be an aging degradation mechanism for concrete structures. If the concrete is degraded by other aging mechanisms, which may reduce the protective cover of the steel, corrosion may occur at a significantly higher rate.

The HSMs installed at the Rancho Seco ISFSI are placed contiguous to each other, separated by a 6-inch gap. The HSM side walls are protected by a 2 feet-thick end shield walls, which are inst alled at both ends of the HSM array.

These shield walls provide environmental protection to the HSMs proper. The HSM rear walls are also protected sinc e the Rancho Seco ISFSI is configured in two back to back HSM rows. Thus, only the external surfac e of the roof and the front wall are directly exposed to ambient weather cond itions. The front wall and roof are designed as very thick components due to shielding considerations. Roof thickness is 3 feet , front wall thickness is 2.5 feet, and the minimum rebar cover is approximat ely 1 inch. These design features mitigate cracking, and thereby provide enhanced corrosion protection.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-98 Furthermore, the HSM concrete mix desi gn is in accordance with Section 4.3 of ACI 318-83, Building Code Requirements for Reinforc ed Concrete [3-21] (or Section 5.3 of ACI 318-95 [3-21]).

[ ] These stringent requirements ensure good-quality concrete that is resistant to chemical attack and, together with adequate concrete cover, makes the reinforcing steel less susceptible to

corrosion.

The OE described in Section 3.2 contains cases where spalling of concrete cover with exposed rebar was observ ed. Although all observed cases were repaired, environmental degradation of the HSM concrete due to rebar corrosion is considered an aging effect requiring management for the HSM.

Therefore, corrosion of embedded steel including reinforcing steel is an applicable concrete aging mechanism.

Reactions with Aggregates Chemical reactions may develop between certain mineral constituents of aggregates and alkalis that compose the Portland cement. These alkalis are largely introduced in the concrete by cement, but may also be present from improper admixtures and salt-contam inated aggregates. Seawater and solutions of deicing salt can also inject alkalis into concrete by action of penetration. Three types of chemical reactions may occur depending upon the composition of the aggregates: alkali-aggregate reaction, cement-aggregate

reaction, and alkali-carbonate reaction. T he alkali-silica reaction (ASR) can occur when aggregate containing silica is exposed to alkaline solutions. It can cause expansion and cracking of conc rete structures. The degree of vulnerability of the concrete to this e ffect is primarily a function of the aggregate that is used. The cement-aggregate reaction occurs between alkalis in the cement and silicates in the aggregates. It mainly occurs in environments that promote concrete shrinkage and alkali concentrations in the surface due to drying. The alkali carbonate reaction (between carbonate aggregates and alkalis) may produce expansion and cracking of the concrete. It often results in

map cracking on the concrete surface.

It has been known to occur for certain limestone aggregates.

The aging effect of the aggregate reaction degradation mechanisms is generally map or pattern cracking on t he concrete surface (more or less uniform spacing of cracks over the entire concrete surface) and possible presence of alkali-silica gel on the c oncrete surface, as discussed in ACI 221.1, State-of-the-Art Report on Alkali-Aggregate Reac tivity [3-24] and NRC Information Notice 2011-20 [3-9].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-99 Shrinkage Most of the concrete shrinkage has already occurred (91% in first year, 98% in five years and 100% in 20 years - ACI 209R-92 [3-23]). Twenty years will

have occurred by the end of the current license. Theref ore, concrete shrinkage is not an applicable concrete aging mechanism.

Leaching of Calcium Hydroxide Leaching of calcium hydroxide (Ca(OH)

2) due to water penetration can result in loss of concrete material, converti ng the cement into gels that have no strength. The significance of the effect is governed by water temperature and salt content as described in NUREG/CR-7116, Materials Aging Issues and Aging Management for Ext ended Storage and Transportation of Spent Nuclear Fuel [3-6]. Leaching over long periods of time can increase the permeability of concrete, making it more susceptible to other forms of aggressive attack and reducing strength. Leaching can also lower the pH of the concrete and affect the integrity of the pr otective oxide film of reinforcement steel.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-100 There is some OE indicating occurrences of leaching in the HSM concrete.

The most likely cause of Ca(OH) 2 leaching in the HSM concrete would be rainwater penetrating the surface laye

r. Therefore, leaching of Ca(OH) 2 is an applicable ISFSI concrete aging mechanism.

Irradiation Embrittlement In dry storage systems, the level of irradiation over the ex tended operation is not expected to reach a level that is su fficient to cause strength reduction of concrete; therefore, the irradiation effect is not considered to be a significant aging degradation mechanism as described in ASTM C1562-10 [3-32].

The HSM interior components are exposed to neutron fluence and gamma exposure radiation. The supplemental analysis in Appendix A determines that there is no credible degradation in the strength of the HSM components due to the neutron fluence and gamma exposure. T herefore, irradiation embrittlement is not an applicable concrete aging mechanism.

Creep Creep is the time-dependent increase of strain in hardened concrete that has been subjected to sustained stress, pr imarily compressive. The sustained stress results from dead load, live load, pre-stress on the structure and from temperature effects. Creep deformation is a function of loading history, environment, and material properties of the concrete. The time-dependent

creep deformation of concrete under compre ssive load consists of cumulative strain resulting from progressive cracking at the aggregate-cement paste interface, from moisture exchange wit h the atmosphere, and from moisture movement within the concrete. Creep-induced concrete cracks are typically not large enough to result in concrete deterioration or in exposure of the reinforcing steel to environmental stressors. Cracks of this magnitude do not reduce the concrete's compressive strength. Creep is significant when new concrete is subjected to load and decreases exponentially with time, and therefore, any degradation is noticeable in the first fe w years. According to AC I 209R-92, Prediction of Creep, Shrinkage, and Temperature Effect s in Concrete Structures [3-23], 78% of creep occurs within the first year, 93% within 10 years, 95% within 20 years, and 96% within 30 y ears. Creep is not a significant aging degradation mechanism and was not identified during the OE review. Therefore, creep is not an applicable concrete aging mechanism.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-101 Fatigue The only source of thermal fatigue is daily and seasonal environmental temperature fluctuations. The maximum average daily fluctuation is 47 °F per Section 8.1.1.9 of the ISFSI FSAR [3

-15]. The high thermal mass of the HSM and low conductivity of the concrete material limit the magnitude of the thermal forces that could be developed due to th is temperature difference. Therefore, thermal fatigue is not an aging effect requiring management for the HSM. Delayed Ettringite Formation Ettringite is the mineral name for calcium sulfoaluminate, which is normally found in Portland cement concretes. Ca lcium sulfate sources (e.g., gypsum) are intentionally added to the cement to regulate early hydration reactions, improve strength development, and reduce drying shrinkage. Sulfate and aluminate are also present in supplementary cementitious materials and admixtures. These compounds react in t he cement to form primary ettringite within the first few hours a fter mixing with water. Delayed ettringite formation (DEF) is t he potential deleterious reformation of ettringite in moist concrete after destruction of primary ettringite by high early-age temperatures from heat treatment, or in extreme cases, from internal heat of hydration. Heat treatment temperatures above about 70 °C (158 °F) are most often cited to cause deleterious volume expansion due to DEF, "Ettringite Formation and the Performance of Concrete

[3-56]. The conditions necessary for the occurrence of DEF are excessi ve temperatures (above about 70 °C (158 °F)) during concrete casting and curing, the presence of internal sulfates, and a moist environment. The principal effect of DEF is volume expansion, which leads to cracking and spalling. It can also increase other forms of

degradation such as freeze/thaw and rein forcement corrosion. The use of supplementary cementitious materials and air entrainment has been shown to reduce the potential for deleterious expansion due to DEF as described in "Expert Panel Workshop on Concrete D egradation in Spent Nuclear Fuel Dry Cask storage Systems -Summary Report" [3-57].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-102 The HSM fabrication specification require s the concrete temperature of plastic concrete, as placed during casting, to be limited

[ ] Cement type is Type II meeting the requirement s of ASTM C150 [3-28] with moderate heat of hydration and moderate sulfate resistance. Specified air content of the concrete, determined in accordance wit h ASTM C231, Standard Test Method for Air Content of Freshly Mixed Concrete by the Pressure Test Method [3-71], is 4% to 7%. Supplementary cementitious materials (e.g., slag) conforming to the requirements of ASTM C989, Standard Specification for Slag Cement for

Use in Concrete and Mortars [3-72] may be used for blending with cement up to 50% by weight of tota l cementitious material. T he HSMs are fabricated in accordance with the ACI 318 Code [3-21]. The HSM fabrication specification requires the concrete to be cured and pr otected in accordance with the curing provisions of Section 5.5 of the ACI 318 Code [3-21]. Thus, concrete degradation of the HSMs due to DEF is not likel y during the period of extended operation.

Microbiological Degradation or Microbiological Chemical Attack Microbiological degradation or microbiological chemical attack of concrete structures is a potential aging mechanism caused by live organisms that grow in environments that offe r favorable conditions (e.g., available moisture, neutral pH, presence of nutrients, etc.), which facilitate the colonization of microbes on concrete surfaces. Conducive environments may have elevated relative humidity (i.e., between 60% and 98%), long cycles of humidification and drying, freezing and defrosting, high ca rbon dioxide concentrations (e.g., carbonation), high concentrations of chlo ride ions or other salts or high concentrations of sulfates and small amounts of acids, "Microbiologically Induced Deterioration of Concrete

- A Review," [3-58]. Under these conditions, microorganisms can affect the concrete mainly by contributing to the deterioration of the exposed concre te surface, reducing the protective cover depth, increasing concrete poros ity, and increasing the transport of degrading substances into the concrete that can accelerate cracking and spalling, [3-58]. Corrosion of the steel reinforcement from microbiological chemical attack is also possible where moisture stagnates on concrete

surfaces for an extended period of time , ACI 349.3R-02 [3-20]. Consistent with the guidance provided in the MAPS Report [3-68], microbiological chemical attack is an applicable concrete aging mechanism for Rancho Seco ISFSI. 3.5.4.3 Steels and Other Metals This section describes the potential aging effects that could, if left unmanaged, cause degradation of carbon steel and stainless steel HSM subcomponents and could result in loss of the com ponent's intended functi on(s). The potential aging effects that could cause loss of design function(s) are:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-103 Loss of material Cracking Change in material properties Aging mechanism(s) that could lead to aging effect(s) for steel and other metal components were determined by techni cal literature review. Aging mechanism(s) were evaluated to determine if the mechanism(s) could lead to an aging effect requiring management. Loss of Material Aging Effects Assessment Loss of material due to general corrosion - carbon steel Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Loss of material due to galvani c corrosion - dissimilar metals Cracking Aging Effects Assessment Cracking due to stress corrosion cracking - stainless steel Cracking due to stress corrosion cracking - bolting Cracking due to thermal fatigue -

carbon steel and stainless steel Change in Material Properties Aging Effects Assessment Change in material properties due to elevated temperature - carbon steel and stainless steel Change in material properties due to irradiation embrittlement - carbon steel and stainless steel 3.5.4.4 Discussion of Aging Mechanisms General Corrosion Metal surfaces in contact with moist air or water are subject to general corrosion. The rate of general corrosion is governed by several factors, such as the moisture of the air, the salinity level of the ai r, the temperature of the metal surface, and the specific type of metal involved. The atmosphere will be dependent on the site location and environm ent, typically benign in terms of corrosion inside the HSM modules. Although DSC decay heat will heat the air

preventing the accumulation or condensatio n of moisture inside the HSM, the decay heat will decline during the PEO. Thus, the presence of moist air cannot

be ruled out. Therefore, loss of material due to general corrosion is an aging effect requiring management for carbon steel and low alloy steel in outdoor and sheltered environments. Stainless steel is not susceptible to general corrosion.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-104 Crevice Corrosion Crevice corrosion is localized corrosion with in crevices or shielded areas. It most frequently occurs in connections, lap joints, splice plates, bolt threads, under bolt heads, or points of contact between metals and non-metals, and it is associated with a stagnant or low flow solution (an electrolyte). Per EPRI Report 1015078 [3-33], to function as a co rrosion site, the crevice must be wide enough to permit liquid entry and narrow enough to maintain a stagnant zone, typically a few thousandths of an inch or less.

Crevice corrosion is strongly dependent on the presence of dissolved oxygen. Any surface exposed to atmospheric c onditions will be saturated in oxygen

above the threshold levels for crevice co rrosion to occur (0.1 ppm). This form

of corrosion, as the name implies, r equires a crevice in which contaminants and corrosion products can concentrate. In addition to oxygen, moisture is required for the mechanism to operate. Typically, atmospheric pollutants and

contaminants, both indoors and outdoors, are insufficient to concentrate and thereby promote crevice corrosion.

Per EPRI Report 1015078 [3-33], alternating wetting and drying is particu larly harmful because this leads to a concentration of atmospheric pollutants and contaminants. Air with enough moisture can facilitate the loss of material in steel caused by crevice corrosion. Moist air in the absence of condensation is potentially aggressive (e.g., coastal locations, near salted roads and in the path of cooling tower drift). Although DSC decay heat will heat the air preventing the accumulation or condensation of moisture inside the HSM, the decay heat will decline during the PEO, thus the presence of moist air cannot be ruled out.

Carbon steel, low alloy steel and stainless steel are all susceptible to crevice corrosion. Therefore, loss of material due to crevice corrosion is an aging effect requiring management for these HSM metals.

Pitting Corrosion Pitting corrosion is a localized corrosi ve attack in aqueous environments containing dissolved oxygen and chlorides. When passivity breaks down at a

spot on a metal surface, an electrolytic cell is formed with the anode at the minute area of active metal and the ca thode at the cons iderable area of passive metal. The large electric potential difference between the two areas accounts for considerable flow of current with rapid corrosion at the anode. The anode does not spread because it is surrounded by passive metal, and as

the mechanism continues, it penetrates deeper into the metal, forming a pit. Pitting corrosion is more common with pa ssive materials such as austenitic (300 Series) stainless steels than with non-passive materials, such as carbon steels. However, all materials of interest are susceptible to pitting corrosion

under certain conditions, per EPRI Report 1015078 [3-33].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-105 Oxygen is required for pitting initiation. Areas in which aggressive species can concentrate, that is, locations of frequent or prolonged wetting or of alternate wetting and drying, are particularly su sceptible to pitting. Per EPRI Report 1015078 [3-33], most pitting is the result of halide c ontamination, with chlorides, bromides, and hypochlorites being prevalent.

Therefore, loss of material due to pitting corrosion is an aging effect requiring management for all HSM metals.

Galvanic Corrosion Galvanic corrosion occurs when two or more metals of differing electrochemical potential are in electr ical contact in a conducting environment (the presence of an electrolyte). Under these conditions an electrolytic cell is formed transmitting an electrical current between an anode and a cathode.

Loss of material occurs when ions of the metal with the lower potential, the anode, are being depleted and deposited on to the more noble metal, the cathode. Galvanic corrosion will not occu r in a dry environment; an electrolyte must be present and remain liquid. The ratio between surface areas of the metals in contact is of significant importance. Per EPRI Report 1015078

[3-33], corrosion rates increase when the more noble metal has a greater surface area than the more active metal in the presence of moisture and water. An instance in the HSM where dissimilar materials are in contact and, therefore, vulnerable to galvanic corrosion is at the contact area where graphite lubricant is used at the DSC support struct ure rail faces. Since the graphite lubricant used is noble relative to the rail face, it could induce galvanic

corrosion of the Nitronic 60 support structure rail plat

e. This loss of material due to galvanic corrosion of Nitronic 60 DSC support structur e rail plate is an aging effect previously addre ssed in Section 3.4.4.2. Stress Corrosion Cracking SCC is a localized, non-ductile cracking fa ilure resulting from the combination of a corrosive environment, a susceptible material, and tensile stresses. In most cases, SCC involves crack initiati on, subcritical crack growth, and failure when the crack reaches a critical size and the tensile strength of the remaining material is exceeded. Per EPRI Report 1015078 [3-33], in terms of corrosive

environment, dissolved oxygen, sulfates, fluorides, and chlorides can provide the necessary environment for SCC to o ccur. Austenitic stainless steels are susceptible to SCC. Residual stresses at the welds are likel y to be sufficient to initiate SCC at storage sites with sufficient chloride aeros ols. There are no weld joints in the heat shields. Therefore, SCC at the welds and heat affect ed zones of the welds of the Nitronic 60 rail face to carbon steel s upport structures is subject to aging management.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-106 Stress Corrosion Cracking Of High Strength Bolting Bolting fabricated from high-str ength (measured yield strength, Sy, 150 ksi) low-alloy steel is susceptible to stre ss corrosion cracking. Examples of high-strength alloy steels that comprise this category include ASTM A193 Grade B7, A540 Grade B23/24, A193 Grade B8, and Grade L43.

Structural component anchor age applications in the HSM include bolted joints and threaded connections, collectively referred to as bolted connections.

Bolted connections include bolts, studs, screws, nuts, washers, and member faying surfaces (i.e., mati ng surfaces) of a bolted jo int. Structural bolting materials used with Rancho Seco HSMs include ASTM A36, A193 Grade B7, A194 Grade 2H, A307, A325, A490, and A563 Grade A.

HSM structural component anchorages are installed snug-tight per HSM installation specifications. This is true for the installation of HSM shield wall connections, rail extensions, door attach ments, roof attach ments, and heat shields. These HSM structural com ponent anchorages do not have sufficiently high tensile stress to initiate SCC; therefore cracking of high strength bolts due to SCC is not an aging effect requiring management for HSM subcomponents.

Thermal Fatigue The only source of thermal fatigue is env ironmental temperat ure fluctuation. For HSM steel subcomponents located insi de the HSM, i.e., in a sheltered environment, the thermal fluctuations due to external ambient temperature fluctuations are significantly dampened by the HSM walls and roof and the DSC decay heat. Thermal cycling fatigue due to fluctuations in the ambient conditions is not an aging effect requiring management for HSM

subcomponents.

Thermal Aging The maximum temperature of the HSM steel subcomponents is 241 °F at the beginning of storage (ISFSI FSAR, Volume II, Table 8-4 [3-15]) for the off-normal conditions of storage (117 °F ambi ent temperature). This temperature is well within allowed tem perature limits for the structural metal components of the HSMs (e.g., maximum temperature limit is 700 °F and 800 °F, for carbon and stainless steels, respectively, per the ASME code).

Carbon steels are not suscept ible to embrittlement due to thermal aging, per EPRI Report 1015078 [3-33]. The maximum temperature of 241 °F is well below the embrittlement saturation temperature of 752 °F (400 °C) in, NUREG/CR-6428 [3-46]. It is also below the lower 635 °F (335 °C)

temperature in the tests r eported in [3-47] and [3-48] where embrittlement was observed for stainless steel welds. Also, per NUREG-1801 [3-12], austenitic steels with service temperature below 482

°F (250 °C) are not susceptible to thermal aging embrittlement. Therefore, change in material properties due to Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-107 thermal aging is not an aging effect requiring management for HSM metal subcomponents.

Irradiation Embrittlement High neutron radiation can cause loss of fracture toughness in steel. Previously, as addressed in Appendix 3E of CoC 1004 Renewal Application RAI Response [3-59], the neutron radiat ion seen by the metal components of dry fuel storage systems is orders of magnitude lower than that required to produce any effect, so neutron radiation is not a significant aging effect for the HSM steel subcomponents. Gamma radi ation does not have any significant impact on the properties of st eel. Therefore, irradiation embrittlement is not an aging effect requiring management for HSM steel subcomponents. 3.5.4.5 Coatings Evaluation For the carbon steel subcomponents, no cr edit is taken for coatings for the performance of intended functions. Coatings are treated as a "m aterial" rather than a "subcomponent"; ther efore, an AMR was performed on coating failure to determine if it could adversely affect the safety function of a safety-related SSC. Metallic subcomponents within the HSM are carbon steel. Carbon steel subcomponents are coated with inorganic coatings or are galvanized. Hence, all metallic materials are protected against corrosion. The coated steel within the HSM is in a warm, sheltered environment.

Table 3-7 lists the c oated HSM subcomponents. The NUHOMS HSM fabrication specifications require

[ ] These coating systems have excellent adhesion to carbon steel and resistance to alkalis, and are intended to provide protection for the carbon steel against corrosion in the harshest environments.

Hot-dip galvanizing is performed in a ccordance with the requirements of ASTM A123, Standard Specification for Zinc (Hot-Dip Galvanized) Coatings on Iron and Steel Products [3-26] with a minimum thickness Coating Grade of

100.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-108 The amount of applied coating within an HS M is limited; coating failure (e.g., blistering, cracking, flaking, peelin g) adversely affecting the thermal performance of the HSM is not credible because the HSM thermal analysis does not take credit for the coating emissivity. Therefore, coating failure does not prevent the HSM or the DSC from satisfactorily accomplishing its intended functions. Based on the evaluation provided above and the guidance provided in the MAPS Report [3-68], it is concluded that coatings are not relied upon to manage the effects of aging for the HSM subcomponents at the Rancho Seco ISFSI. Therefore coating failure is not in cluded as an inspection attribute within the HSM AMP.

The sliding surfaces of the DSC support rails of the HSM are coated with a dry film lubricant to minimize friction duri ng insertion and retrieval of the DSC. The dry film lubricant provides a thin, clean, dry layer of lubricating solids to reduce wear and prevent galling. Graphite lubricants are suitable for very high and cryogenic temperature applications. The l ubricant is not affected by water and is designed to be highly resistant to aggressive chemicals. The lubricant suffers no radiation effects because it consists entirely of graphite. The dry lubricants are treated as a "material

" rather than a "subcomponent." The coefficient of friction associated with t hese lubricants is below 0.05, while the design basis calculations employed a c oefficient of friction of 0.25. The mechanical system used for DSC transfer is capable of exerting an extraction force equal to the loaded weight of a DSC. An effective coefficient of friction of 100% (assuming no lubrication) has been used for these "jammed DSC analyses." The support structure is also designed for this loading. Therefore, dry lubricant deterioration is not an aging effect requiring aging management since the dry film lubricant is not relied upon for DSC retrievability. 3.5.4.6 Summary of Aging Effects Requiring Management The following aging effects and mechanisms for HSM concrete components are applicable:

Loss of Material Aggressive chemical attack, includ ing microbiological chemical attack Corrosion of embedded steel Cracking Reactions with aggregates Corrosion of embedded steel Change in Material Properties Leaching of Ca(OH) 2 Aggressive chemical attack Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-109 The following aging effects/mechanisms for HSM steel components are applicable:

Loss of Material Loss of material due to general corrosion - carbon steel Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Loss of material due to galvanic corrosion - Nitronic 60 DSC support rail plates Cracking Stress Corrosion Cracking - welds attaching Nitronic 60 rail plate 3.5.5 Aging Management Acti vities for the HSMs 3.5.5.1 HSM TLAAs No TLAAs are used to manage any expected aging effects of HSM components. 3.5.5.2 HSM Aging Management Programs The following program is employed to manage the aging effects and mechanisms for the HSM concrete and steel components: HSM Aging Management Program for External and Internal Surfaces (applicable to HSM, DSC support structures)

The scope of the HSM AMP, parameters to be monito red and the criteria for selecting an HSM for the AMP are described in Section B.4.5 of Appendix B.4.

Rancho Seco will implement the first (baseline) HSM inspections under this AMP on the selected HSM in accordance with the program schedule as described in Appendix B.4, Section B.4.5. 3.5.5.3 Summary of the AM R Results for the HSMs Table 3-8 summarizes the results of the AMR for the HSMs.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-110 3.6 Aging Management Review Results -

Concrete Basemat (Storage Pad) This section summarizes the results of the AMR for the Rancho Seco ISFSI concrete basemat. The basemat is a NITS reinforced concrete structure designed to support the HSMs and constructed to plant-specific site conditions. As discussed in Section 3.

5.4.2, long-term settlement of the ISFSI basemat is a credible aging mechanism. There are no other credible failure modes of the basemat that could prevent the HSM intended functions from being fulfilled.

The basemat is evaluated in suppor t of the following intended function: Provides HSM structural/functional support 3.6.1 Description The basemat is designed and constructed in accordance with codes and standards set by the site licensee. It is subject to site-specific foundation analyses and design considerations, incl uding licensee-specific HSM loading configurations. The basemat and under lying foundation are engineered, designed, and constructed to meet t he requirements for a heavy industrial facility (Section 2.6 of the Standardized NUHOMS CSAR [3-7]). 3.6.2 Basemat Materials Evaluated The material of construction for t he basemat is reinforced concrete. 3.6.3 Environments for the Basemat The basemat is located in an external environment; the exposed exterior surfaces of the basemat are exposed to all weather conditions, including insolation, wind, rain, snow, and plant-specific ambient temperature, humidity, and airborne contamination. The Rancho Seco HSM module is provided with its own concrete floor and the entire HS M assembly sits on the basemat. The areas of the concrete floor within the footprint of the installed HSM array are in a sheltered environment. These areas are protected from out door effects (e.g.

direct sunlight, precipitation, etc.) and experience temperat ures and radiation exposure levels that are bounded by those of the HSM concrete components discussed in Section 3.5.3.

The below-grade portions of the basem at are in an underground environment and could be exposed to a groundwater/soil environment. 3.6.4 Summary of Aging E ffects Requiring Management Based on the evaluations in Sections 3.5.4.1and 3.5.4.2, the following aging effects and mechanisms are applicab le for the concrete basemat:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-111 Loss of Material Aggressive chemical attack, includ ing microbiological chemical attack Corrosion of embedded steel Delayed Ettringite Formation (DEF)

Cracking Reactions with aggregates Settlement (aging mechanism described below)

Settlement of a structure may be due to c hanges in the site conditions (e.g., water table, soil). As noted in Sect ion 3.5.1.4 of the MAPS Report [3-68], differential settlement of concrete structures involves a combination of immediate settlement and progressive l ong-term settlement. Because of the potential aging effects that long-term se ttlement of the bas emat may have on the HSM intended functions, settlement is an applicable concrete aging mechanism for the basemat.

Change in Material Properties Leaching of Ca(OH) 2 Aggressive chemical attack, includ ing microbiological chemical attack 3.6.5 Aging Management Activities fo r the Rancho Seco ISFSI Basemat The Rancho Seco ISFSI Basemat AMP, described in Appendix B.6, is employed to manage the aging effects and mechanisms for the basemat concrete.

The scope of the basemat AMP and t he parameters to be monitored are described in Section B.6.5 of Appendix B.6. Rancho Seco will implement the first (baseline) basemat inspections under this AMP in accordance with the program schedule as described in Section B.6.5, Appendix B.6.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-112 Table 3-7 HSM Materials HSM Subcomponents Material HSM walls, roof, floor, end shield walls, rear shield walls and floor Reinforced concrete DSC support structure: structural beams and frames Carbon steel (coated) DSC support rail plate Nitronic 60 stainless steel Shielded access door encased core Plain Concrete Shielded access door: door steel plates Carbon steel (coated) Axial retainer assembly: tube steel, plate embedment, DSC axial retainer Carbon steel (coated) HSM Heat Shields Carbon steel (coated) HSM cask docking ring Carbon steel (coated) HSM roof attachment angles and stiffener plates Carbon steel (coated) Support frames for HSM inlet and outlet vent bird screens Stainless steel Anchorages (threaded fasteners include bolts, studs, screws, nuts, washers, and embedments) Carbon steel (coated) Stainless steel End shield walls-to-module connecting hardware Carbon steel (coated)

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-113 Table 3-8 Rancho Seco HSM Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Inte nde d Function (1) (2) Environment Aging Effects Requiring Management Aging Management Activity Base Unit Assembly HSM Base Walls & Floor Slab SH, SS, HT, RE External / Sheltered Loss of Material, Cracking, Change in Material Properties AMP Roof Slab Assembly HSM Roof Slab SH, SS, HT External / Sheltered Loss of Material, Cracking, Change in Material Properties AMP End/Rear Shield Walls End and Rear Shield Walls SH, SS, HT External / Sheltered Loss of Material, Cracking, Change in Material Properties AMP DSC Support Structure Assembly Support Rail Beams and Cross Beams SS, RE Sheltered Loss of Material AMP DSC Support Structure Assembly Support Rail Plate RE Sheltered Loss of Material /

Cracking AMP DSC Support Structure Assembly Support Structure Steel (Rail Extension Plate, DSC Stop Plates, Stiffener Plates, Gussets, Mounting Plates, Base Plates, Support Plate, Wall Attachment Channel and Angles SS, RE Sheltered Loss of Material AMP DSC Support Structure Assembly Tube Steel Leg Column SS Sheltered Loss of Material AMP DSC Support Structure Assembly Bolts SS Sheltered Loss of Material AMP DSC Support Structure Assembly Nuts SS Sheltered Loss of Material AMP DSC Support Structure Assembly Wall Attachment Hardware (Heavy Hex Bolt/Hardened Washer)

SS Sheltered Loss of Material AMP HSM Shielded Door Assembly Steel Plates (Various) SH, SS, RE External Loss of Material AMP Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-114 Table 3-8 Rancho Seco HSM Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Inte nde d Function (1) (2) Environment Aging Effects Requiring Management Aging Management Activity HSM Shielded Door Assembly Encased Concrete Core SH, RE Embedded /

Encased None Identified None Required HSM Shielded Door Assembly Door Bolt SS, RE External Loss of Material AMP Canister Axial Retainer Assembly Axial Retainer Rod/Mounting Plate /Bolts /Hardened Washer SS External Loss of Material AMP Cask Docking Ring Assembly Rings /Plates /Nelson Studs / Door Clamps /Hex Bolts SS, RE Embedded /

Encased / External Loss of Material AMP Heat Shield Assemblies Roof and Side Wall Mounted Heat Shields HT Sheltered Loss of Material AMP Heat Shield Assemblies ZEE Brackets (for the Roof Mounted Heat Shields) SS Sheltered Loss of Material AMP Heat Shield Assemblies Heat Shield Attachment Hardware (Rods, Nuts)

SS Sheltered Loss of Material AMP Heat Shield Assemblies Heat Shield Embedment Assemblies (Bolts/Sleeve Nuts) SS Embedded /

Encased Loss of Material AMP Cask Restraint Embedment Assembly Rods/Sleeve Nuts/Hexagonal Nuts SS, RE Embedded /

Encased / Sheltered Loss of Material AMP Wall & Floor Mounted Canister Support Structure Embedment Assembly Bolt/Sleeve Nut SS Embedded /

Encased / Sheltered Loss of Material AMP Roof Attachment Assembly Roof Attachment Angle/Stiffener Plate SS Sheltered Loss of Material AMP Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-115 Table 3-8 Rancho Seco HSM Intended Functions and AMR Results (3 pages) Subcomponent(2) Subcomponent Parts(2) Inte nde d Function (1) (2) Environment Aging Effects Requiring Management Aging Management Activity Roof Attachment Assembly Roof Mounted/Wall Mounted Attachment Assemblies (Sleeve Nut)

SS Sheltered Loss of Material AMP End and Rear Shield Wall Attachment Hardware Embedment Bolts/Sleeve Nuts SS Embedded /

Encased / Sheltered Loss of Material AMP End Shield Wall Attachment Hardware Embedment Bolts/Sleeve Nuts SS Embedded /

Encased / Sheltered Loss of Material AMP End and Rear Shield Wall Attachment Hardware Cast-In Place Bolts/Nuts SS External Loss of Material AMP End & Rear Shield Wall Attachment Hardware Tie Plate SS External Loss of Material AMP HSM-to-HSM Spacer Channels Spacer Channels SS External Loss of Material AMP End and Rear Shield Wall Support Bolt Assembly Shield Wall Support Bolt Assembly (Bolts, and Nuts) SS External Loss of Material AMP Notes: (1) Abbreviations for Intended Function Column: PB - Directly or indirectly maintains a pressure boundary (confinement) SH - Provides radiation shielding CC - Provides criticality control of spent fuel SS - Provides structural support HT - Provides heat transfer RE - Retrievability (2) Only in-scope subcomponents from Chapter 2, Table 2-7 are listed in this table.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-116 3.7 Aging Management Review Results - Transfer Cask This section summarizes the resu lts of the AMR for the in-scope subcomponents of the MP187 TC. The in-scope TC subcomponents and their intended functions are summarized in the scoping evaluation Table 2-8, Chapter 2.

The evaluation boundary for the TC incl udes the TC subcomponents, which perform the following intended functions (MAPS designations in parentheses, if different): HT (TH) Provides heat transfer SH Provides radiation shielding SS (SR) Provides structural suppor t (impact resistance, lifting, etc.) RE Provides retrievability of DSC 3.7.1 Description of Transfer Cask Subcomponents Note: All of the Rancho Seco SFAs and GTCC waste have been loaded and placed into the HSMs for interim storage.

The MP187 TC is currently stored in a sheltered environment and the only re maining MP187 TC function is to retrieve the DSCs when they are to be shipped offsite. The following discussion, excerpted from the Ranc ho Seco ISFSI FSAR, discusses the MP187 TC functions, including those for transferring fuel from the spent fuel pool to the ISFSI. The activities are not functions required for the PEO.

As described in the ISFSI SAR [3-15], the MP187 TC is a cylindrical vessel with a welded bottom assembly and a bol ted top cover plate. The TC is designed for onsite transfer of the DSC to and from the plant's spent fuel pool and the ISFSI. The TC provides radiological shielding and heat rejection

during handling in the fuel or reactor building, DSC closure operations, and transfer to the HSM at the ISFSI. In addition, the TC provides physical protection for the loaded DSC during off-normal and drop accident events

postulated to occur during the transfer operations. The TC also provides

protection of the DSC against potential natural and operational hazards during transfer of the DSC to the ISFSI.

The TC is constructed from three concentric cylindrical shells to form an inner and outer annulus. The inner annulus is f illed with cast lead to provide gamma shielding. The outer annulus forms a steel jacket, which is filled with NS-3, a hydrogen rich castable solid material, m anufactured by BISC O Products, Inc.

See "NS-3 Specification Sheet," by BI SCO Products Inc., [3-45] for neutron shielding. The two inner shells are welded to heavy forged ring assemblies at the top and bottom ends of the cask. The TC structural shell and the bolted top cover plate are fabricated from stainle ss steel. A stainless steel cover plate equipped with an O-ring is provided to seal the bottom hydraulic ram access penetration of the cask during fuel loading. All surfaces exposed to fuel pool water are stainless steel.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-117 Two trunnion assemblies are provided in the upper region of the cask for lifting of the TC inside the plant's spent f uel building, and for supporting the cask on the skid for transfer to and from the ISFSI. An addi tional pair of trunnion assemblies, provided in the lower end of the cask, used to position the cask on the support skid, serve as the rotation axis during down-ending of the cask, and provide support for the bottom end of the cask during transfer operations. The trunnion assemblies are fabricated from a stainless steel trunnion sleeve welded into the structural shell. A removable trunnion, machined from a stainless steel bar, is bolted to the trunnion sleeve. In the trunnions, a machined hollow space is formed and this is filled with NS-3 neutron shielding material to provide shielding during transfer operations. The TC is provided with a set of internal rails, fabricated from a non-galling, wear resistant

stainless steel material coated with a hi gh contact pressure dry film lubricant (containing graphite) to facilitate DSC transfer into and out of the HSM.

The ram access penetration ring located on the bottom plate allows access to the DSC for transfer operations. The annulus drain valve is located within the

bottom support ring and the annulus fill valve is located in the top flange. The neutron shield jacket, which surrounds the cask structural shell, extends

axially from the bottom ring to the t op flange, and is composed of an outer stainless steel jacket, top and bottom support rings, and axial support angles.

The neutron shielding material is NS-3.

The cask is provided with a top cover assembly, which is bolted to the cask body during transfer of a fuel-loaded or GTCC DSC from the fuel building to the HSM. Lifting eyes are provided to a llow removal of the cover from the TC when it is in either a horizontal or vertical orientation. The following TC subcomponents ar e excluded from further aging management review because they do not support or impact the intended function of the TC during the period of extended operation: Coatings, lubricants, sealants, Teflon tape Eyebolts for bottom access plate and top cover plate and associated thread inserts Cover plates, gaskets, and screws for annulus fill and drain ports Quick-connect fittings for annulus and neutron shield fill and drain ports Alignment pins for top cover plate Stick-on alignment targets

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-118 3.7.2 Transfer Cask Materials Evaluated The materials of construction for t he TC and its subcomponents are listed in Table 3-9. 3.7.3 Environments for the Transfer Cask The TC is normally stored in a sheltered environment between uses and during staging activities prior to each use. The TC was last used in August

2002 for fuel loading and transfer operations except for the loading and transfer of GTCC waste, which concluded in 2006. All of the Rancho Seco fuel is currently in storage in the HSMs and the TC will only be used when the DSCs are to be retrieved from the HSMs for offsite shipment.

The total time exposure of the TC to the spent fuel pool environment (during the historic loading operations) and to the external environment (during transfer operations) repres ents a negligible fraction of its total life span, including PEO. Hence, the only environment considered for the TC AMR is the sheltered environment. 3.7.4 Aging Effects Requiring Management for the Transfer Cask 3.7.4.1 Steels and Other Metals This section describes the potential aging effects that could, if left unmanaged, cause degradation of steel TC subcom ponents and result in loss of the component's intended function(s). The potential aging effects that could cause loss of intended function(s) are: Loss of material Cracking Change in material properties Loss of Material Aging Effects Assessment Loss of material due to general corrosion - carbon steel Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Loss of material due to galvani c corrosion - dissimilar metals Loss of material due to wear Cracking Aging Effects Assessment Cracking due to stress corrosion cracking - stainless steel Cracking due to thermal fatigue - carbon steel and stainless steel Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-119 Change in Material Properties Aging Effects Assessment Change in material properties du e to thermal aging - carbon steel and stainless steel Change in material properties due to irradiation embrittlement - carbon steel and stainless steel 3.7.4.2 Discussion of Aging Mechanisms General Corrosion Carbon steel surfaces in contact with mo ist air or water are subject to general corrosion. Therefore, loss of material due to general corrosion is an aging effect requiring management for carbon and low alloy steel in outdoor and sheltered environments. Stainless steel is not susceptible to general corrosion.

Crevice Corrosion Crevice corrosion is localized corrosion within crevices or shielded areas. It most frequently occurs in connections, lap joints, splice plates, bolt threads, under bolt heads, or points of contact between metals and non-metals, and it is associated with a stagnant or low flow solution (an electrolyte). Per EPRI Report 1015078 [3-33], to function as a co rrosion site, the crevice must be wide enough to permit liquid entry and narrow enough to maintain a stagnant zone, typically a few thousandths of an inch or less.

Crevice corrosion is strongly dependent on the presence of dissolved oxygen. Any surface exposed to atmospheric c onditions will be saturated in oxygen

above the threshold levels for crevice co rrosion to occur (0.1 ppm). This form

of corrosion, as the name implies, r equires a crevice in which contaminants and corrosion products can concentrate. In addition to oxygen, moisture is required for the mechanism to operate.

Typically, atmospheric pollutants and contaminants, both indoors and outdoors, ar e insufficient to concentrate and thereby promote crevice corrosion.

Per EPRI Report 1015078 [3-33], alternating wetting and drying is particu larly harmful because this leads to a concentration of atmospheric pollutants and contaminants. Air with enough moisture can facilitate the loss of material in steel caused by crevice corrosion. Therefore, loss of material due to crevice corrosion is an aging effect requiring management for carbon steel, low alloy steel, and

stainless steel in outdoor, and sheltered environments.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-120 Pitting Corrosion Pitting corrosion is a localized corrosive attack in aqueous environments containing dissolved oxygen and chlorides. When passivity breaks down at a

spot on a metal surface, an electrolytic cell is formed with the anode at the minute area of active metal and the ca thode at the cons iderable area of passive metal. The large electric potential difference between the two areas accounts for considerable flow of current with rapid corrosion at the anode. The anode does not spread because it is surrounded by passive metal, and as

the mechanism continues, it penetrates deeper into the metal, forming a pit. Pitting corrosion is more common with pa ssive materials such as austenitic (300 Series) stainless steels than with non-passive materials, such as carbon steels. However, all materials of inte rest are susceptible to pitting corrosion under certain conditions. See EPRI Report 1015078 [3-33].

Oxygen is required for pitting initiation. Areas in which aggressive species can concentrate, that is, locations of frequent or prolonged wetting or of alternate wetting and drying, are particularly su sceptible to pitting. Per EPRI Report 1015078 [3-33], most pitting is the result of halide c ontamination, with chlorides, bromides, and hypochlorites being prevalent.

Loss of material due to pitting corro sion is an aging effect requiring management for carbon steel, low alloy steel, and stainless steel in outdoor and sheltered environments.

Galvanic Corrosion Galvanic corrosion occurs when two or more metals of differing electrochemical potential are in electrical contact in a conducting environment (the presence of an electrolyte). Under these conditions, an electrolytic cell is formed transmitting an electrical current between an anode and a cathode.

Loss of material occurs when ions of the metal with the lower potential, the anode, are being depleted and deposited onto the more noble metal, the cathode. Galvanic corrosion will not occu r in a dry environment; an electrolyte must be present and remain liquid. The ratio between surface areas of the metals in contact is of significant importance. Per EPRI Report 1015078

[3-33], corrosion rates increase when the more noble metal has a greater surface area than the more active metal in the presence of moisture and water.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-121 One instance of the TC components coming in contact with dissimilar metals is where the graphite lubricant is in cont act with the TC rails, inner shell, and bottom end closure (due to the potential fo r the lubricant to flow off the rails and onto the inner shell or bottom end closure). Because the graphite lubricant is noble relative to the stainless steel components, there is the potential for galvanic corrosion of the TC rails, inner shell, and bottom end closure.

Therefore, loss of material due to galvanic corrosion of the rail face, inner shell, and bottom end closure is an aging effect requiring management in a sheltered environment.

Wear General wear may occur as a result of movement of one ma terial with respect to another. One type of wear applicable to the external portions of equipment is the result of relative motion betw een components called fretting. Fretting is the loss of material that occurs as a result of relative motion between two materials. The DSC is designed to slide from the TC into the HSM and back without undue galling, scratching, gougi ng, or other damage to the sliding surfaces. This is accomplished by the addition of Nitronic 60 austenitic stainless steel sliding rails to the TC. Furthermore, t here is OE with scratching of the cask liner and trunnions. The MP187 TC is in storage at the Rancho Seco site and is not in routine use. Therefore, loss of material due to wear is not an aging

effect requiring management for the TC Nitronic 60 rails, the TC inner shell, and the trunnions. Stress Corrosion Cracking SCC is a localized non-ductile cracking failure resulting from an unfavorable combination of sustained tensile stresses either applied (external) or residual (internal), material condition, and t he presence of a corrosive environment.

SCC is a phenomenon that occurs in aus tenitic stainless steels, but becomes significant only if tensile stress and a corrosive environment exist. In most cases, SCC involves crack initiation, subcritical crack growth, and failure when the crack reaches a critical size and the tensile strength of the remaining material is exceeded. According to EPRI Report 015078 [3-33], dissolved oxygen, sulfates, fluorides, and chlo rides can provide the necessary environment for SCC to occur.

Chloride Induced Stress Corrosion Cracking (CISCC)

Operating experience documented in NRC Information Notice 2012-20 [3-10], has shown that austenitic stainless st eels under tensile stresses are known to

be susceptible to CISCC when exposed to chlorides in the environment. This

phenomenon is of concern at temperature and relative humidity combinations that allow the chloride compounds to deliquesce. Airborne salts could deposit Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-122 on the material surface, then form ch loride-rich deliquescent brines in conditions of high relative humidity. O perating experience s howed that through wall cracking attributed to CISCC in aus tenitic stainless steel piping exposed to atmospheric conditions near saltwater bodies occurred at three plants in the United States at service lives of 16, 25, and 33 years.

It is possible for airborne chloride salts to deposit on the TC stainless steel surfaces, particularly if the TC is in service at locations with significant chloride aerosols. However, it is highly unlikely that CISCC will occur for the MP187 TC since all of the Rancho Seco SFAs and GTCC waste have been loaded and placed into the HSMs for interim storage.

The MP187 TC is currently stored in a sheltered environment at the Rancho Seco site and is not exposed to external ambient environmental condi tions (rain, wind or snow). More importantly, the Rancho Seco ISFSI is far away from salt water bodies and

thus it is unlikely that TC surface salt concentrations reach concentration levels that might be conducive to CISCC.

Based on the above discussion, the conditions for deposition of chloride-containing salts to reach concentration levels necessary for CISCC to occur on the TC external surfaces are not pres ent. This is confirmed by the Rancho Seco Pre-Inspection [3-8] conducted afte r 15 years of exposure of the MP187 TC to the sheltered environment at the Rancho Seco ISFSI. Therefore, cracking due to CISCC is not an aging effect requiring management.

Thermal Fatigue Thermal fatigue is the progressive and lo calized structural damage that occurs when a material is subjected to cyclic loading associated with thermal cycling.

Potential thermal fatigue of the TC ma y be due to temperature fluctuations associated with transfer operations of a loaded DSC from the time fuel is loaded into the DSC until the DSC is pushed from the cask and loaded into the HSM. Appendix A documents the TLAA perform ed to evaluate the effects of pressure and temperature fluctuations in accordance with the provisions of NB 3222.4(d) of the ASME B&PV Code [3-14]. As provided by NB 3222.4(d) of the ASME B&PV Code, fatigue effects need not be specifically evaluated provided the six criteria in NB 3222.4(d) are met.

The number of loading cycles used is based on a conservative average of 20 uses per year of a TC, for a service life of 60 years, or 1,200 uses per loaded TC. The evaluation demonstrat es that the six criteria, (a) through (f), contained in NB 3222.4(d) are satisfied for all components of the TCs. Therefore, cracking of the TC subcomponents due to the thermal fatigue is an aging effect managed via a TLAA.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-123 Thermal Aging Steels in the TC are used in the annealed condition, except for the precipitation hardened trunnions and optionally cold-worked Nitronic 60 rails.

Maximum TC temperatures are well bel ow the levels that would permanently affect the trunnion mechanical properties. Therefore, change in material properties due to thermal aging is not an aging effect requiring management for TC subcomponents.

Irradiation Embrittlement High neutron radiation can cause loss of fracture toughness in steel. However, the neutron radiation seen by the metal components of dry fuel storage systems are orders of m agnitude lower than that required to produce any significant effect, so neutron radiation is not a significant aging effect for the steel components. Gamma radiation does not have any significant impact on the properties of steel. The TC, no longer in routine operation, was subjected to neutron fluence and gamma exposure only when a loaded DSC was in the cask during loading and transfer operations. Since the exposure of the TC to neutron fluence was limited to a very short duration, the supplemental evaluation presented in Appendix A for radiation exposure on DS C steel materials bounds radiation exposure for the TC.

Neutron irradiation may also result in generation of combustible gases in the neutron shielding material of the TC wh ich is discussed in the next section. 3.7.4.3 Other Materials This section describes the aging effect s that could, if left unmanaged, cause degradation of TC shielding material (l ead and NS-3) and result in loss of the component intended function(s).

The TC is constructed from three concentric cylindrical shells to form an inner and outer annulus. The inner annulus is filled with cast lead. The outer annulus is filled with a solid neutron shielding materi al, NS-3. The two inner shells are welded to heavy forged ring assemblies at the top and bottom ends of the cask.

Two trunnion assemblies, located in the upper region of the transfer cask the TC are fabricated as a hollow asse mbly, which is filled with NS-3. The aging effects that could cause loss of intended function(s) are: Change in Material Properties Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-124 The lead shielding material of the TC is completely encased in the inner annulus. Shrinkage gaps formed as the lead is cooled from the bottom up are filled by a pool of molten lead maintained above the solidified bottom

until the lead pour is complete. Therefor e, the lead is in full surface contact

with the inner shell. No electrolyte is present for galvanic corrosion of lead

in contact with stainless steel. T he dry conditions preclude general or pitting corrosion as well. Lead creep, which could result in local shielding

reduction, is not a concern due to the full and tight encasement of the

lead. The MP187 TC outer annulus is f illed with NS-3, a neutron shielding material. NUREG/ CR-7116 "Materials Aging Issues and Aging Management for Extended Storage and Tr ansportation of Spent Nuclear Fuel" [3-6] indicates that neutron shielding degradati on is primarily applicable to polymeric materials.

These materials are subject to degradation and reduced shielding effectiveness as a result of thermal and radiation exposure. In addition, radiolytic decomposition of polymeric materials may result in generation of combustible gases. A supplemental evaluation has been performed (see Appendix A). This evaluation shows that the amount of combustible gases generated due to radiolysis is statistically insignificant.

Therefore, there is no degradation of the solid neut ron shield or the lead during the period of ext ended operation that r equires aging management. 3.7.4.4 Coating Evaluation The DSC support rails of the TC are coated with a dry film lubricant, a NITS component, to minimize friction during in sertion and retrieval of the DSC. The dry film lubricant provides a thin, clean, dry layer of lubricating solids to reduce wear and prevent galling. It is applied before each loading campaign. Graphite lubricants are suitable from very high to cryogenic temperature applications.

The lubricant is not affected by water and is designed to be highly resistant to aggressive chemicals. The lubricant suffe rs no radiation effects because it consists entirely of graphite. The coeffi cient of friction associated with these lubricants is below 0.05, while the design basis calculations employed a coefficient of friction of 0.25. The me chanical system used for DSC transfer is capable of exerting an extraction force equal to the loaded we ight of a DSC.

An effective coefficient of friction of 100% (assuming no lubrication) has been used for these "jammed DSC analyses.

" The support structure is also designed for this loading. Therefore, dry lubricant deterioration is not an aging effect requiring aging management since t he dry film lubricant is not relied upon for DSC retrievability. 3.7.4.5 Summary of Aging Effects Requiring Management The following aging effects and mechanisms for steel components are applicable:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-125 Loss of Material Loss of material due to general corrosion - carbon steel Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Loss of material due to galvanic corrosion - stainless steel rail, inner shell, and bottom end closure Cracking Cracking due to thermal fatigue -

carbon steel and stainless steel 3.7.5 Aging Management Ac tivities for the NUHOMS MP187 Transfer Cask (TC) 3.7.5.1 TC Time-Lim ited Aging Analysis Appendix A documents the thermal fatigue analysis of the TC for pressure and temperature fluctuations in accordance with the provisions of NB 3222.4(d) of the ASME B&PV Code [3-14]. As provided by NB 3222.4(d) of the ASME B&PV Code, fatigue effects need not be specifically evaluated provided the six criteria in NB 3222.4(d) are met. This evaluation is performed considering a 60-year service life using maximu m bounding initial TC pressures and temperatures (at the beginning of storage). This evaluation shows that all the six criteria of NB 3222.4(d) are met. 3.7.5.2 TC Aging Management Programs The MP187 TC has not been in-service fo r more than 11 years since all the Rancho Seco SFAs and GTCC waste have been placed into the ISFSI in 2006. However, the only remaining TC safety function during the PEO is retrieval of the DSCs from the HSMs pr ior to offsite shipment of the DSCs.

The TC AMP, described in Appendix B.5, is employed to manage the aging effects and mechanisms for the DSC:

Rancho Seco will perform the inspections and monitoring activities described in this AMP prior to use to identify areas of degradation. Evaluation of this information during preparations for DS C retrieval and transfer provides adequate predictability and allows time for corrective action, if required, in order for the TC to perform its intended functions. 3.7.5.3 Summary of the AMR Results for the TC Table 3-10 summarizes the results of the AMR for the TC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-126 Table 3-9 Transfer Cask Materials TC Subcomponents Material Cask Top Cover Assembly Stainless steel Elastomeric O-ring Shell Assembly (Top Flange, Bottom End Forging, Bottom End Plate, Bottom Support Plate, Ram Access Penetration Forging, Inner Liner) Stainless steel Structural Shell Assembly (Structural Shell) Stainless steel Upper Trunnion Assemblies (Trunnion Sleeves, Trunnions) Stainless steel NS-3 Lower Trunnion Assemblies (Trunnion Sleeves, Trunnions) Stainless steel Gamma Shielding Lead Neutron Shielding NS-3 Neutron Shield Assembly (Neutron Shield Panels (NSP), NSP Top and Bottom Support Rings, NSP Support Angles) Stainless steel Canister Rails Nitronic 60 Cask Bottom Ram Penetration cover plate Stainless steel Elastomer O-ring Fasteners (Cask Top Cover Closure Screws, Bottom Ram Plate Closure Screws) Carbon steel, Stainless steel Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-127 Table 3-10 MP187 TC Intended Functions and AMR Results (4 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Storage Environment (3) Aging Effects Requiring Management (4) Aging Management Activity (4) Main Assembly Inner Shell SH, SS, HT, RE Sheltered /

Encased Loss of Material, Cracking AMP Main Assembly Bottom End Closure SH, SS Sheltered Loss of Material AMP Main Assembly Bottom Structural Shell SH, SS, HT, RE Encased / Sheltered Loss of Material, Cracking AMP Main Assembly Top Structural Shell SH, SS, HT, RE Encased / Sheltered Loss of Material AMP Main Assembly Top Flange SH, SS Sheltered Loss of Material AMP Main Assembly Gamma Shielding SH, HT Encased None Identified None Required Main Assembly Upper Trunnion Plug Cover & Side Plate SS Encased / Sheltered Loss of Material AMP Main Assembly Upper Trunnion Sleeve SH, SS, RE Encased / Sheltered Loss of Material AMP Main Assembly Lower Trunnion Sleeve SH, SS Encased / Sheltered Loss of Material AMP Main Assembly Pad Plate SS Encased None Identified None Required Main Assembly Bearing Block SS Encased / Sheltered Loss of Material AMP Main Assembly Tie Bar SS Encased / Sheltered Loss of Material AMP Main Assembly NSP Top & Bottom Support Ring SH, SS, HT Encased / Sheltered Loss of Material, Cracking AMP Main Assembly NSP Support Angle, Outer SH, SS, HT Encased None Identified None Required Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-128 Table 3-10 MP187 TC Intended Functions and AMR Results (4 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Storage Environment (3) Aging Effects Requiring Management (4) Aging Management Activity (4) Main Assembly Rupture Plug SH Encased / Sheltered Loss of Material AMP Main Assembly Plugs SH Loss of Material, Cracking AMP Main Assembly Neutron Shield Shell SH, SS, HT Sheltered Loss of Material, Cracking AMP Main Assembly Upper Trunnion Plug Bottom Plate SH, SS Encased / Sheltered Loss of Material, AMP Main Assembly Rails SS, RE Sheltered Loss of Material, Cracking AMP Main Assembly / On-Site Transfer Castable Neutron Shielding Material SH Encased None Identified None Required Main Assembly Ram Closure Plate SH, SS, RE Sheltered Loss of Material AMP Main Assembly Top Closure Plate SH, SS, RE Sheltered Loss of Material AMP Main Assembly Screw, Cap Hd. Soc.

SS, RE Sheltered Loss of Material AMP Main Assembly Filler Plate SH, SS Encased / Sheltered Loss of Material AMP Main Assembly Hardened Washer (3" & 1.5" OD) SS Sheltered Loss of Material AMP Main Assembly Test Port Screw SS Sheltered Loss of Material AMP Main Assembly Vent/Drain Port Screw SS Sheltered Loss of Material AMP Main Assembly Lower Trunnion Plug Cover Plate SS Encased / Sheltered Loss of Material AMP Main Assembly Lower Trunnion Plug Shield Block SH, SS, RE Encased / Sheltered Loss of Material AMP Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-129 Table 3-10 MP187 TC Intended Functions and AMR Results (4 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Storage Environment (3) Aging Effects Requiring Management (4) Aging Management Activity (4) Main Assembly Screw, Flat Hd. Cap SS Sheltered Loss of Material AMP Main Assembly NSP Support Angle, Inner SH, SS, HT Sheltered Loss of Material AMP Main Assembly Screw Thread Insert (1" and 2")

SS, RE Encased / Sheltered Loss of Material AMP Main Assembly 10 Gage Sheet SS Encased / Sheltered Loss of Material AMP On-Site Transfer Outer Plug Cover Plate SH Encased / Sheltered Loss of Material AMP On-Site Transfer Outer Plug Sleeve SS Encased / Sheltered Loss of Material AMP On-Site Transfer Nut, 1/2-13UNC-2B SS Encased / Sheltered Loss of Material AMP On-Site Transfer Inner Plug Cover Plate SH Encased / Sheltered Loss of Material AMP On-Site Transfer Inner Plug Sleeve SS Encased / Sheltered Loss of Material AMP On-Site Transfer Inner Plug Inside Sleeve SS Encased / Sheltered Loss of Material(6) AMP On-Site Transfer Bolt, 1-8UNC-2A SS Sheltered Loss of Material AMP On-Site Transfer Outer Plug Support Bracket SS Sheltered Loss of Material AMP Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-130 Table 3-10 MP187 TC Intended Functions and AMR Results (4 pages) Subcomponent(2) Subcomponent Parts(2) Intende d Function(1) (2) Storage Environment (3) Aging Effects Requiring Management (4) Aging Management Activity (4) On-Site Transfer Key Plug Cover Plate SS Encased / Sheltered Loss of Material AMP On-Site Transfer Flat Hd Socket Cap Screw SS Sheltered Loss of Material AMP On-Site Transfer Socket Hd Cap Screw SS Sheltered Loss of Material AMP On-Site Transfer Lower Trunnion SH, SS Sheltered Loss of Material AMP On-Site Transfer Upper Trunnion SH, SS, RE Sheltered Loss of Material AMP On-Site Transfer Trunnion Back SS Encased / Sheltered Loss of Material AMP On-Site Transfer Key Plug Side Plate SS Encased / Sheltered Loss of Material AMP On-Site Transfer Key Plug Bottom Plate SS Encased / Sheltered Loss of Material AMP Notes: (1) Abbreviations for Intended Function Column: PB Directly or indirectly maintains a pressure boundary (confinement) SH Provides radiation shielding CC Provides criticality control of spent fuel SS Provides structural support HT Provides heat transfer RE Retrievability Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-131 (2) Only in-scope subcomponents from Chapter 2, Table 2-8 are listed in this table. (3) The TC operations are intermittent and following the completion of each fuel loading campaign all exposed cask surfaces are thoroughly cleaned to remove potential contamination. Therefore, the Aging Management Results are based on the Encased / Sheltered environments. (4) Cracking due to thermal fatigue of the transfer cask subcomponents has been addressed by performing a TLAA that bounds all subcomponents.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-132 3.8 Aging Management Review Results - Spent Fuel Assemblies The intended functions of the SFAs include critica lity control, confinement, structural integrity, and heat transfer. The geometry of the SFA is a factor in the proper conduction and convection of heat to the DSC surface and in the criticality model. The fuel cladding provides a confinement barrier, and its structural integrity is necessary to maintain a favorable geometry and for retrieval. After fuel loading and DSC dr ying, the SFAs are not moderated, ensuring subcriticality during subsequent operations and configurations. The SFA principal function dur ing dry storage is to maintain proper geometry and position of radioactive material through confinement. No credit is taken in the safety analysis for the fuel cl adding as a confinement boundary. The evaluation boundary for the SFA includ es the fuel claddi ng and end plugs, guide tubes, grid assemblies, upper no zzle, and bottom nozzle, which perform the following intended functions (MAPS designations in parentheses, if different): CC (CR) Provides criticality control HT (TH) Provides heat transfer PB (CO) Directly or indirectly maintains a pressure boundary (confinement) SS (SR) Provides structural support (structural integrity) 3.8.1 Description of Spent Fuel Assembly Subcomponents Chapter 2, Section 2.4.4, provides a general descr iption of the B&W 15x15 SFA subcomponents. The characteristics of the SFAs and GTCC waste stored at the Rancho Seco ISFSI are listed in Chapter 2, Tables 2-2 and 2-3, respectively. The in-scope SFA subcom ponents and their intended functions are listed in Chapter 2, Table 2-9. 3.8.2 Spent Fuel Assemblies Materials Evaluated The materials of construction of the SFA hardware consist of Zirconium-based alloys, stainless steel and nickel-based alloys.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-133 The AMR for the SFAs focuses primarily on the fuel rod cladding as it is considered the limiting co mponent of the FA hardware because it serves as a barrier to fission products, provides defense-in-depth, and maintenance of its structural integrity ensures its retrievability from the DSC (See Section 2.2.1 for the canister based licensing basis for retrievability for the Rancho Seco ISFSI.) Though fuel cladding is the first barrier for confinement of radioactive materials, no credit for confi nement of radioactive materi al is taken for the fuel cladding in the SMUD ISFSI design and licensing basis. The DSC pressure boundary is the only credited confinem ent boundary. As stated in EPRI TR-108757, Data Needs for Long-Term Dry St orage of LWR Fuel [3-35], the impact of irradiation on stainless steel and nickel-based superalloys during storage is less than in the reacto r environment. Furthermore, annealing temperatures are bounded by that of zi rcaloy. According to EPRI TR-108757

[3-35], "storage temperatures are too low to anneal out the radiation damage in stainless steel or nickel-based alloys [and] no significant changes are expected to occur in stainless steels and nickel-based superalloys during dry

storage." 3.8.3 Environments for the Spent Fuel Assemblies The environments that affe ct the subcomponent s of each SFA, both externally and internally, are those that are normally (continuously) experienced and are described below: External For SFAs, external environment refers to the internal DSC atmosphere. The storage atmosphere is predominantly hel ium with trace amounts of water vapor and air.

Additionally, boric acid residue may coat the PWR SFA surfaces, since they were exposed to a borated water environm ent in the spent fuel pool prior to storage. Any boric acid residue rema ining on the SFAs will have no deleterious effects due to the absence of water and due to the materials of construction for the SFAs.

In dry storage, the SFA subcomponents that are subject to aging management review are stored in an inert helium environment.

The maximum cladding temperature at the beginning of storage for SFAs loaded in the FO/FC DSCs is 746 °F (397 °C) for off-normal conditions as presented in Volume II, Table 8-5 of the ISFSI FSAR [3-15]. This is greater than the normal temperature of 714 °F (379

°C), but less than the fuel cladding acceptance criteria of 1058 °F (570 °C). The FF and GTCC DSC thermal analysis results are bounded by the FO/FC DSC thermal analysis results.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-134 Internal For SFAs, internal environment refers to the fuel rod interior. The fuel rods were pressurized with helium during m anufacturing. For purposes of this evaluation, the fuel rod in ternal environment is assumed to be a combination of the original helium fill gas and fission products produced during reactor operation. 3.8.4 Aging Effects Requiring Managem ent for the Spent Fuel Assemblies This section identifies t he possible effects of stor age on SFA. Relevant EPRI, ASTM, and NRC documents were used to identify the possible aging effects. The following sections discuss those documents. Only creep, and hydrogen embrittlement are considered potential degradation mechanisms for SFAs.

EPRI Report on Data Needs for Storage EPRI contracted with Battelle's Pacific Northwest Division to prepare a report (EPRI TR-108757 [3-35]) on data needs fo r long-term dry storage. The report discusses available data and its usef ulness in treating some degradation mechanisms. The emphasis of this r eport is on fuel performance during the period from 20 to 100 years after the fuel is placed into dry storage.

The report's summary section provides an assessment of the durability of spent fuel: "The results obtained so far lead to the view that any concerns about long-term dry storage, in all likelihood, do not lie with the behavior of the SFAs - at least for those with bur nups lower than ~50,000 MWd/MTU." The remainder of the report provides details to support this conclusion.

EPRI Report on Bases for Extended Dry Storage EPRI produced a second report EPRI 1003416, Technical Bases for Extended Dry Storage of Spent Nuclear Fuel [3-36], which to some extent, is a supplement to EPRI TR-108757 [3-35]. T he report reviews possible fuel and cladding degradation mechanisms. As discussed, only hydrogen embrittlement was considered applicable to extended dr y storage under normal conditions. ASTM Standard on Extended Dry Storage The ASTM produced a consensus standard, which discusses possible fuel

and cladding degradation mechanisms. This standard also views embrittlement as a degradation mechanism applicable to extended dry

storage, ASTM C1562-10 [3-32].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-135 Dry Cask Storage Characterization Project In the mid-1980s, DOE sponsored a program to evaluate the thermal performance of a CASTOR dry st orage cask, EPRI Report 1002882 [3-34]. Surry PWR fuel was placed in it and exposed to six thermal cycles (referred to

as "benchmark testing");

the two hottest cycles reached fuel cladding

temperatures of 415 °C (779 °F) and 398 °C (748 °F). After the last thermal test, the cask was stored on a conc rete pad for about 15 years. As part of an EPRI and NRC program to evaluate dry storage facility license

renewal, fuel from this cask was t hen removed and examined. The FA was a Westinghouse 15x15 assembly with an assembly-averaged burnup of 35.7 GWd/MTU. The fuel was 3.11% enric hed and 95% dense. The cladding was cold-worked/stressed relieved Zircaloy-4. Detailed examination showed that the f uel was suitable for extended storage.

No deleterious effects, such as fiss ion gas release, cladding creep, cladding hydride reorientation, or cladding property degradation, was observed.

In terms of cladding mate rial, assembly burnup, and pellet enrichment, this fuel is similar to that being stored at the Rancho Seco IS FSI. Therefore, the report's observations are also applicable to Rancho Seco SFAs: The rods experienced very little thermal creep during benchmark testing and storage. Little additional creep w ould be expected for additional storage duration because of the low temperature. No additional fission gas appears to have been released. This means further pressurization of the cask is not expected. No evidence of hydrogen pickup or hy dride reorientati on was observed. A small amount of axial mi gration of hydrogen to cooler sections might have occurred. Little or no cladding annealing occurred during either the benchmark testing or long-term storage. Creep tests on post-storage samples showed residual creep strains exceeding 1% with the 400 °C sample exceeding 6%. The cladding retains significant creep ductility. The fuel was suitable for extended storage. No deleterious effects from 15 year s of dry cask storage were observed.

Cladding Considerations for the Transportation and Storage of Spent Fuel Interim Staff Guidance ISG-11 Revision 3, Cladding Considerations for the Transportation and Storage of Spent Fuel

[3-44] defines the acceptance criteria needed to provide reasonable assurance that commercial spent fuel is maintained in the configuration that is analyzed by a licensee.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-136 The NRC discussed the applicability of this ISG to storage of fuel with burnups less than 45 GWd/MTU. "Based on staff's ev aluation, it is expected that FAs with burnups less than 45 GWd/MTU are not likely to have a significant amount of hydride reorient ation due to limited hydri de content. Even if hydride reorientation occurr ed during storage, the network of reoriented hydrides is not expected to be extensive enough in low burnup fuel to cause fuel rod failures."

Creep is a potentially active degradati on mechanism during the period of extended operation. The relatively hi gh initial temperatures, differential pressures, and corresponding hoop stress on the cladding could potentially result in permanent creep deformati on of the cladding over time.

Tests to assess creep performance of cladding under long-term storage are documented in NUREG/CR-6831, Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage [3-43]. Fuel rods were stored for 15 years at an initial temperature of 350 °C (662 °F) (and r eached as high as 415 °C (779 °F) for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during the performance test ing at the beginning of storage).

Pre- and post-storage creep tests results sh ow that the spent fuel cladding has significant creep capacity even after 15 years of dry cask storage. The creep tests of fuel rods indicated that the creep deformation was uniform around the circumference of the cladding with no signs of localized bulging, which can be a precursor to rupture. In gener al, the data and analyses support the conclusions that: deformation caused by creep will proceed slowly over time and will decrease the rod pressure, the decreasing cladding temperature also decreases the hoop stress, which also slows the creep rate so that during later stages of dry storage, further creep deformation will become exceedingly small, and in the unlikely event that a breach of the cladding due to creep occurs, it is believed that this will not re sult in gross rupture.

Conclusions Creep is identified as a potentially active degradation mechanism during the period of extended operation. The extensive work of creep, documented in NUREG/CR-6831 [3-43], generally suppor ts the conclusions that creep deformation is a slow process. Under long-term storage, creep deformations will be exceedingly small because the creep rate will slow down due to decreasing temperatures in the period of extended operation. This section also identified that low to moderate burnup fuel is not impacted by either of these mechanisms as docum ented in EPRI Report TR-108757 [3-35]

and EPRI Report 1003416 [3-36]. The re sults of the Dry Cask Storage Characterization Project [3-34] support the conclusion that low burnup SFAs will not degrade under extended storage.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-137 3.8.5 Aging Management Activities for the Spent Fuel Assemblies The materials inside the DSC, includi ng the SFAs, cannot practically be inspected in-situ due to radiation levels and accessibility (i.e., DSC is seal welded). In preparation for dry storage, the DSC inte rnals are vacuum dried and backfilled with helium to establish an inert gas environment in the DSC cavity. The DSC is leak tested to ensur e that the inert gas environment is maintained so that the SFAs will not become subject to age-related degradation mechanisms during the stor age period. A demonstration project provides the basis for the assertion that the SFAs will not degrade to unacceptable levels during the period of extended operation, NUREG/CR-6831 [3-43] and EPRI Report 1002882 [3-34]. 3.8.5.1 Aging M anagement Program There are no aging effects that require management for low to moderate burnup fuel ( 45 GWd/MTU) that is stored in an inert environment. Safe storage of low to moderate burnup fuel has been demonstrated in NUREG/CR-6831 [3-43] and EPRI R eport 1002882 [3-34]. Therefore, reasonable assurance is provided that the intended functions of the SFAs will be maintained under current licensing basis conditions during the PEO. Therefore, no aging management program or activities are credited during the PEO for the Rancho Seco low burnup SFAs and associated subcomponents.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-138 3.9 Periodic Tollgate Assessment Industry guidance on the preparation of IS FSI LRAs is contained in NEI 14-03, "Format, Content and Implementati on Guidance for Dry Cask Storage Operations-Based Aging Management," [3

-19]. This NEI document introduces the concept of "tollgates" and "tollgate assessments" and provides specific guidance in Section 3.6.5 and A ppendix C. SMUD will perform tollgate assessments during the PEO of the R ancho Seco ISFSI, spanning the period from June 30, 2020 through June 30, 2060 or the date the last licensed material is removed from the Rancho Seco ISFSI, whichever occurs sooner.

SMUD may choose to integrate the toll gate assessment into existing Rancho Seco ISFSI assessment programs, while continuing to meet the underlying intent of the tollgate concept. Tollgate assessments for the Rancho Seco ISFSI will be performed in accordance with Table 3-11.

In order to prepare the to llgate assessments effectively, SMUD will participate in, and have access to the Industry's Aging Management Institute of Nuclear Power Operation Databas e (AMID) via the NUHOMS Dry Storage System (DSS) vendor, TN Americas. SMUD will review the AMID for relevant information to support the preparation of the tollgates assessments and will prepare those assessments as recommended in NEI 14-03 [3-19].

It is important to note that the tollgate process is not a substitute for the other SMUD OE reviews or the SMUD corre ctive action program. Operating Experience and other information or event s pertaining to ISFSI aging-related issues that SMUD becomes aware of will be reviewed for relevance to the Rancho Seco ISFSI. As a result, acti ons will be taken in a timeframe commensurate with the safety significance of the issue. Relevant items will be addressed in the SMUD corrective action program, as appropriate.

The preparation of tollgate assessments during the PEO will be an administratively controlled by procedure.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-139 Table 3-11 Rancho Seco ISFSI Tollgates TOLLGATE DUE DATE A SS E SS M E N T 1 6/30/2025 Evaluate information from the following sources and perform a written assessment of the aggregate impact of the information, including but not limited to applicable and relevant trends, corrective actions required, and the effectiveness of the AMPs with which they are associated:

- Results, if any, of research and development programs focused specifically on aging-related degradation mechanisms identified as potentially affecting DSS ISFSIs;

- Relevant domestic and international OE including research results on aging effects/mechanisms (including non-nuclear on an opportunistic basis); - Relevant results of domestic and international ISFSI and DSS performance monitoring;

- Relevant results of domestic and international ISFSI and DSS inspections Topics of particular interest for the Rancho Seco ISFSI tollgate assessment should include the following:

- Reinforced concrete degradation in general, and degradation of NUHOMS HSMs in particular

- Deterioration of carbon steel and coatings 2 6/30/2030 Evaluate additional information gained from the sources listed in Tollgate 1 along with any new relevant sources and perform a written assessment of the aggregate impact of the information. This evaluation should be informed by the results of Tollgate 1. The aging effects and mechanisms evaluated at this Tollgate, and the time at which it is conducted, may be adjusted based on the results of the Tollgate 1 assessment.

3 and later No more than five years after completion of the previous tollgate assessment Same as Tollgate 1, as informed by the results of Tollgates 1 and 2

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-140 3.10 Conclusions The AMR was conducted using the guidance in NUREG-1927 [3-1], NEI 14-03 [3-19], and, to the extent possible, the draft MAPS Report [3-68]. The SSCs determined to be within the scope of r enewal are evaluated for aging effects and mechanisms that could adversely a ffect their ability to perform their intended safety function during the PEO. For each SSC, the aging effects and associated aging mechanism that could c ause degradation, or could result in

loss of intended function, are evaluated. Th ese evaluations result in TLAAs or

AMPs. TLAAs, described in Appendix A, are prepared to assess SSCs that have a time-dependent operating life to demonstrate that the existing licensing basis remains valid, and that the intended functi ons of the SSCs in scope of renewal are maintained during the period of ex tended operation. The following TLAAs have been developed for the Rancho Seco SSCs: Fatigue Analysis of NUHOMS DSC Shell Assembly (Appendix A) Fatigue Analysis of NUHOMS MP187 Transfer Cask (TC) (Appendix A) Boron Depletion (Appendix A) In addition, supplemental evaluations (Appendix A) were performed to show that the following aging mechanism s did not require aging management: Irradiation embrittlement Combustible gas generation AMPs, described in Appendix B, are developed for managing the effects of aging for those components and aging e ffects where a TLAA cannot be performed. The following AMPs describe the activities that need to be implemented to monitor and manage the aging effects. DSC External Surfaces Aging Management Program (Appendix B.3) HSM Aging Management Program (Appendix B.4) Transfer Cask, MP187 Aging Management Program (Appendix B.5) Basemat Aging Management Program (Appendix B.6)

The results of the AMR and the impl ementation of the associated AMAs described in this chapter provide r easonable assurance that the intended functions of the Rancho Seco ISFSI in-scope SSCs will be maintained during the requested 40-year period of extended operation.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-141 3.11 References 3-1 NUREG-1927, "Standard Review Plan fo r Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance," U.S. Nuclear Regulatory Commission, Revision 1, June 2016. 3-2 Calvert Cliffs Nuclear Power Plant, Independent Spent Fuel Storage Installation, Material License No. SNM-2505, Docke t No. 72-8, Response to Request for Supplemental Information, RE: Calvert Cliffs Independent Spent Fuel Storage Installation License Renewal App lication (TAC No. L24475), ADAMS ML12212A216, July 27, 2012. 3-3 Duke Energy Carolinas, LLC, Oconee Nucl ear Station, Docket No. 72-4, License No. SNM-2503, License Renewal Applicat ion for the Site-Specific Independent Spent Fuel Storage Installation (ISFSI) - Response to Requests for Additional Information, License Amendment Request No. 2007-06, ADAMS ML090370066, January 30, 2009. 3-4 H.B. Robinson Steam Electric Plant, Unit No. 2, Independent Spent Fuel Storage Installation, Docket No. 72-3/Licens e No. SNM-2502, Independent Spent Fuel Storage Installation (ISFSI) Inspection Report, January 31, 1994. 3-5 H.B. Robinson Steam Electric Plant, Un it No. 2, Independent Spent Fuel Storage Installation, Docket No. 72-3/Licens e No. SNM-2502, Independent Spent Fuel Storage Installation (ISFSI) Inspection Report, May 5, 2000. 3-6 NUREG/CR-7116, "Materials Aging Issues and Aging Management for Extended Storage and Transportation of Spent Nuclear Fuel," U.S. Nuclear Regulatory Commission, November 2011. 3-7 Vectra Technologies, Inc., "NUH-003, Certified Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, Revision 4A," Docket No. 72-1004, June 1996. 3-8 Rancho Seco Independent Spent Fuel Storage Installati on Pre-Application Inspection Report, E-48447, Revision 0. 3-9 NRC Information Notice 2011-20, "Concrete Degradation by Alkali-Silica Reaction," U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, November 18, 2011. 3-10 NRC Information Notice 2012-20, "Pot ential Chloride-Induced Stress Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System Canister," U.S. Nuclear Regul atory Commission, November 14, 2012. 3-11 NRC Information Notice 2013-07, "Premature Degradation of Spent Fuel Storage Cask Structures and Components from Environmental Moisture," U.S. Nuclear Regulatory Commission, April 16, 2013. 3-12 NUREG-1801, Revision 2, "Final R eport - Generic Aging Lessons Learned (GALL) Report," U.S. Nuclear R egulatory Commission, December 2010.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-142 3-13 NUREG-1536, Revision 1, "Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility - Final Report," U.S. Nuclear Regulatory Commission, July 2010. 3-14 ASME B&PV Code,Section III, Divisi on 1, 1992 Edition, with Addenda through 1993. 3-15 Rancho Seco Independent Spent Fuel Stor age Installation Final Safety Analysis Report (ISFSI FSAR), Revision 6, August 2016 (Docket 72-11). 3-16 Rancho Seco Independent Spent Fuel Storage Installation Materials License SNM-2510 including Technical Specific ations, Amendment 3, August 11, 2009 (Docket 72-11). 3-17 Rancho Seco Independent Spent Fuel Storage Installation Materials License SNM-2510 including Technical Specific ations, November 2017 (Docket 72-11). 3-18 ASTM C216-17a, "Standard Specification for Facing Brick (Solid Masonry Units Made from Clay or Shale)." 3-19 Nuclear Energy Institute 14-03, "Format, Content and Implementation Guidance for Dry Storage Operations-Based Aging Management," Revision 2, 2016. 3-20 ACI 349.3R-02, "Evaluation of Existing Nuclear Safety-Related Concrete Structures." 3-21 ACI 318-83 or ACI 318-95, "Building Code Requirements for Reinforced Concrete." 3-22 ACI 201.1-08, "Guide for C onducting a Visual Inspection of Concrete in Service." 3-23 ACI 209R-92, "Prediction of Creep, Shrinkage, and Temperature Effects in Concrete Structures." 3-24 ACI 221.1R-98, "State-of-the-Art Report on Alkali-Aggregate Reactivity." 3-25 ACI 349-85 or ACI 349-97, "Nuclear Safety Related Concrete Structures." 3-26 ASTM A123/A123M-13, "Standard Specification for Zinc (Hot-Dip Galvanized)

Coatings on Iron and Steel Products" ASTM International, 2013. 3-27 ASTM C33/C33M-13, "Standard Specification for Concrete Aggregates," ASTM International, 2013. 3-28 ASTM C150/C150M-12, "Standard Specif ication for Portland Cement," ASTM International, 2012. 3-29 ASTM C227-10, "Standard Test Method fo r Potential Alkali Reactivity of Cement-Aggregate Combinations (Mortar-Bar Method)," ASTM Inte rnational, 2010. 3-30 ASTM C289-07, "Standard Test Method fo r Potential Alkali-Silica Reactivity of Aggregates (Chemical Method),"

ASTM International, 2007. 3-31 ASTM C295/C295M-12,"Standard Gui de for Petrographic Examination of Aggregates for Concrete,"

ASTM International, 2012.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-143 3-32 ASTM C1562-10, "Standard Guide for Eval uation of Materials Used in Extended Service of Interim Spent Nuclear Fuel Dry Storage Systems," ASTM International, 2010. 3-33 EPRI Report 1015078, "Plant Support Engine ering: Aging Effect s for Structures and Structural Components (Struc tural Tools)," December 2007. 3-34 EPRI Report 1002882, "Dry Cask Storage Characterizati on Project, Final Report, Electric Power Research Institute," September 2002. 3-35 EPRI Report TR-108757, R. E. Einziger, D. L. Baldwin, and S. G. Pitman, "Data Needs for Long-Term Dry Storage of LWR Fuel," Electric Power Research Institute, 1998. 3-36 EPRI Report 1003416, J. Kessler and R. Einziger, "Technical Bases for Extended Dry Storage of Spent Nuclear Fuel," Electric Power Research Institute, December 2002. 3-37 CENG Letter from G. H. Gellrich (CCNPP) to Document Control Desk (NRC), dated April 24, 2013, Calvert Cliffs Nuclear Power Plant, Independent Spent Fuel Storage Installation, Materials License No. SNM-2502, Docket No. 72-8, Response to Request for Additional Information, RE: Calvert Cliffs Independent Spent Fuel Storage Installation License Renewal Application (TAC No. L24475). 3-38 EPRI Report 1025209, K. Waldrop, "Cal vert Cliffs Stainle ss Steel Dry Storage Canister Inspection," Fi nal Report, April 2014. 3-39 "Safety Evaluation Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradi ated Nuclear Fuel," U.S. Nuclear Regulatory Commission, December 1994. 3-40 ACI 224.1R-07, Causes, Evaluation, and Repair of Cracks in Concrete Structures. 3-41 NUREG/CR-6927, "Primer on Durability of Nuclear Power Plant Reinforced Concrete Structures - A Review of Pert inent Factors," U.S. Nuclear Regulatory Commission, Oak Ridge Nationa l Laboratory, February 2007. 3-42 NUREG/CR-6745, "Dry Cask Storage Characterization Project-Phase 1:

CASTOR V/21 Cask Opening and Examination," U.S. Nuclear Regulatory

Commission, Idaho National Engineerin g & Environmental Laboratory, September 2001. 3-43 NUREG/CR-6831, "Examinati on of Spent PWR Fuel Rods after 15 Years in Dry Storage," U.S. Nuclear Regulatory Commission, Argonne National Laboratory, September 2003. 3-44 Interim Staff Guidance, ISG-11, "Cladding Considerations fo r the Transportation and Storage of Spent Fuel," Spent Fuel Project Office, Revision 3, November 2003. 3-45 BISCO Products, Inc., "NS-3 Specif ication Sheet: Castable Neutron and/or Gamma Shielding Material."

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-144 3-46 NUREG/CR-6428, "Effects of The rmal Aging on Fracture Toughness and Charpy-Impact Strength of Stainless Steel Pipe Welds," U.S. Nuclear Regulatory Commission, Argonne National Laboratory, May 1996. 3-47 K. Chandra, et al. "Low temperature thermal ageing embrittlem ent of austenitic stainless steel welds and its electrochem ical assessment," Corrosion Science 54 (2012) 278-290. 3-48 K. Chandra, et al. "Low temperature thermal aging embrittlement of austenitic stainless steel welds: Kinetics and effects on mechanical properties," Materials Science and Engineering A, 534 (2012) 163-175. 3-49 EPRI Report NP-4887, "The CASTOR-V/21 PER Spent-Fuel Storage Cask: Testing and Analysis", November 1986. 3-50 NUREG/CR-7116, "Materials Aging Issues and Aging Management for Extended Storage and Transportation of Spent Nuclear Fuel," U. S. Nuclear Regulatory Commission, Savannah River National Laboratory, November 2011. 3-51 R.S. Glass, G.E. Overturf, R.A. va n Konynenburg, and R.D. McCright, "Gamma radiation effects on corrosion-I. Electrochemical mechanisms for the aqueous corrosion processes of austenitic stainl ess steels relevant to nuclear waste disposal in tuff," Corrosion Scienc e, Volume 26, Issue 8, Pages 577-590, Lawrence Livermore National Laboratory, Livermore, California, January 1986. 3-52 G.P. Marsh, K.J. Taylor, G. Bryan, and S.E. Worthington, "The influence of radiation on the corrosion of stainless steel," Corrosion Science, Volume 26, Issue 11, Pages 971-982, Corrosion Technology Group, AERE Harwell, Oxfordshire X11 ORA, United Kingdom, 1986. 3-53 S.E. Worthington, G.P. Marsh and K.J. Taylor, "Improvements in Materials Reliability in the Back End of the Nuclear Fuel Cycle," IAEA Vienna, Austria, IAEA-TECDOC-686, Pages 55-64, IAEA Technical Committee Meeting, Vienna, November 28-December 1, 1989. 3-54 T. Furuya, H. Tomari, K. Fujiwara, S. Muraoka and K. Araki, "Influence of Gamma Irradiation on Stress Corrosion Cracking of Aust enitic Stainless Steels,"

Fuel Reprocessing and Waste Management, Pages 493-502, American Nuclear Society, LaGrange Park, Illi nois; ANS International topical meeting on fuel reprocessing and waste management; Jacks on Hole, Wyoming; August 26-29, 1984. 3-55 A. Turnbull et al., "Sensit ivity of stress corrosion cracking of stainless steel to surface machining and grinding proc edure," Corrosion Science 53 (2011) 3398-3415. 3-56 "Ettringite Formation and the Performance of Concrete," Portland Cement Association, 2001. 3-57 A. H. Chowdhury, L. Ca seres, Y, Pan, G. Oberson, C. Jones, "Expert Panel Workshop on Concrete Degradation in Spent Nuclear Fuel Dry Cask Storage

Systems - Summary Report," Prepared for U.S. Nuclear Regulatory Commission, March 2016.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Chapter 3 - Aging Management Review Page 3-145 3-58 S. Wei, Z. Jiang, H.

Liu, D. Zhou, and M. Sanchez-Silva, "Microbiologically Induced Deterioration of Concrete - A Review," Brazilian Journal of Microbiology, Vol. 44, pp. 1001-1007, 2013. 3-59 Second Response to NRC Request for Additional Information - Areva Inc., Renewal Application for the Stan dardized NUHOMS System - CoC 1004 (Docket 72-1004, TAC No. L24760), June 6, 2016. 3-60 U.S Nuclear Regulatory Commission, Sa fety Evaluation Report, Docket No. 72-03, "H.B. Robinson Independent Spent F uel Storage Installation," License No. SNM-2502 License Renewal, March 30, 2005, ADAMS ML050890397. 3-61 U.S Nuclear Regulatory Commission, Sa fety Evaluation Report, Docket No. 72-04, "Oconee Nuclear Stat ion Independent Spent Fuel Storage Installation,"

License No. SNM-2503 License Renewal, May 29, 2009, ADAMS ML091520159. 3-62 EPRI Report 3002005371, "Susceptibilit y Assessment Criteria for Chloride-Induced Stress Corrosion Cracking (CISCC) of Welded Stainless Steel Canisters for Dry Cask Storage S ystems," September 2015. 3-63 Calculation 502917-AMR03, Revision 0, "Rancho Seco ISFSI Site Chloride-Induced Stress Corrosion Cracking Susceptibility Ranking." 3-64 EAG Laboratories, X-Ray Fluorescence (XRF) Analysis Report for AREVA TN, June 7, 2017. 3-65 Letter from Ray Phan to Dan A Tallman, "X-Ray Fluorescence Analysis Results (Chloride Deposition Result s)," E-48939, June 19, 2017. 3-66 EPRI TR 1025209, "Calvert Cliffs Stainl ess Steel Dry Storage Inspection," April 2014. 3-67 SAND2014-16383, "Analysis of Dust Samples Collected from Spent Fuel Nuclear Fuel Interim Storage Containers at Hope Creek, Delaware and Diablo Canyon, California," July 2014. 3-68 NUREG-2214, "Managing Ag ing Processes in Storage (MAPS) Report," U.S.

Nuclear Regulatory Commission, dra ft report for comme nt, October 2017. 3-69 Regulatory Guide 1.31, Revision 3, "Control of Ferrite Content in Stainless Steel Weld Metal," April 1978. 3-70 ASTM C1064/C 1064M, "S tandard Test Method for Te mperature of Freshly Mixed Hydraulic-Mixed Concrete," ASTM International. 3-71 ASTM C231/C231M, "Standard Test Method for Air Content of Freshly Mixed Concrete by the Pressure Test Method," ASTM International. 3-72 ASTM C989/C989M, "Standard Specific ation for Slag Cement for Use in Concrete and Mortars," ASTM International. 3-73 NRC Bulletin 96-04, "Chemical, Galvanic, or other Reactions in Spent Fuel Storage and Transportation Casks," U.S, Nu clear Regulatory Commission, OMB No. 3150-0011, July 5, 1996.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-i APPENDIX A TIME-LIMITED AGING ANALYSIS (TLAA) AND OTHER SUPPORTING ANALYSES FOR THE RANCHO SECO ISFSI CONTENTS A.1Summary Descr iption .................................................................................... A-1A.2Analyses .......................................................................................................... A-2A.2.1Fatigue Analysis of the NUHOMS DSC Shell Assembly ....................... A-2A.2.1.1Atmospheric To Service Pressure Cycle ................................... A-2A.2.1.2Normal Service Pressure Fluctuation ........................................ A-2A.2.1.3Temperature Difference - Startup and Shutdown ..................... A-3A.2.1.4Temperature Difference - Normal Service ................................ A-3A.2.1.5Temperature Difference - Dissimilar Materials .......................... A-4A.2.1.6Mechanical Loads .....................................................................

A-4A.2.1.7Conclusion

................................................................................. A-5A.2.2Fatigue Analysis of the NUHOMS MP187 Transfer Cask (MP187 TC) .......................................................................................................... A-5A.2.2.1Atmospheric To Service Pressure Cycle ................................... A-5A.2.2.2Normal Service Pressure Fluctuation ........................................ A-6A.2.2.3Temperature Difference - Startup and Shutdown ..................... A-6A.2.2.4Temperature Difference - Normal Service ................................ A-6A.2.2.5Temperature Difference - Dissimilar Materials .......................... A-7A.2.2.6Mechanical Loads .....................................................................

A-7A.2.2.7Conclusion

................................................................................. A-7A.2.3Boron Depletion, Gamma Irradiation, and Neutron Fluence Analysis ..... A-8A.2.3.1Boron-10 Depletion ................................................................... A-8A.2.3.2Neutron Fluence and Gamma Exposure ................................... A-8A.2.4Combustible Gas Generation .................................................................. A-9A.3Conclusion .................................................................................................... A-10A.4References .................................................................................................... A-11 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-ii LIST OF TABLES Table A-1 Boron-10 Depletio n Results .................................................................. A-12Table A-2 Maximum Neutron Fluence in 32-Assembly DSC Over 100 Years ....... A-13Table A-3 Maximum Gamma Exposure in 32-Assembly DSC Over 100 Years .... A-14 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-1 A.1 Summary Description This appendix discusses the results for each of the Time-Limited Aging Analyses (TLAAs) evaluated for license renewal. The analyses were evaluated for a time period of 60 years, which co vers the entirety of the original and renewed license period. The basis for these TLAAs is the system design documented in The Topical Report fo r the NUTECH Horizontal Modular Storage System for Irradiated Nuclear Fuel, NUHOMS

- 24P, [A-4] and the Safety Analysis Report for Standardized NUHOMS Horizontal Modular Storage System for Irradiat ed Nuclear Fuel, [A-5].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-2 A.2 Analyses A.2.1 Fatigue Analysis of the NUHOMS DSC Shell Assembly The AREVA TN Calculation 502917-0201 Rancho Seco License Renewal Dry Storage Canister (DSC) Thermal Fatigue Analysis, Rev 1, [A-7] evaluated the effects of cyclic loading (fatigue) for 60 years on the mechanical properties of the Dry Shielded Canister (DSC) shell assembly, i.e., pressure boundary subcomponents, for the Rancho Seco IS FSI. The evaluation was performed in accordance with the provisions of NB 3222.4(d) ("Rules to Determine Need for Fatigue Analysis of Integral Parts of Vessels") of the applicable ASME B&PV Code,Section III, Division 1, Subsections NB, NF, NG and Appendix I, 1992 Edition through 1993 Addenda, [A-1]. Fatigue effects need not be specifically evaluated provided the six cr iteria contained in NB 3222.4(d) are met. An evaluation using these six criteria was performed to sh ow that the ASME B&PV Code fatigue exemption requirements are satisfied for the DSCs at the Rancho Seco ISFSI. A.2.1.1 Atmospheric To Service Pressure Cycle The first criterion states that the DSC is adequate fo r fatigue effects provided that the total number of atmospheri c-to-operating pressure cycles during normal operation (including startup and shutdown) does not exceed the number of cycles on the applicable fatigue curve corresponding to an S a value of three times the S m value of the material at operating temperatures.

This condition is satisfied for the DSC since the pressure is not cycled during its design life. Apart from minor fluc tuations due to seasonal temperature variations, the pressure established at the time that the DSC is sealed following fuel loading and DSC closure operations is constant during normal storage in the Horizontal Storage Module (HSM). A.2.1.2 Normal Service Pressure Fluctuation The second criterion states that the DSC is adequate for fatigue effects provided that the specified full r ange of pressure fluctuations (P) during normal operation does not exceed the quantity:

(Eq. 1)

Where P d is the design pressure, S a is the value obtained from the applicable fatigue curve for the total specified number of significant pressure fluctuations, and S m is the allowable stress intensit y for the material at operating temperatures. Significant pressure fluctuations (P s) are those for which the total excursion exceeds Equat ion 1, using a value for S a corresponding to 10 6 cycles.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-3 Ambient temperature cycles that are significant enough to cause measurable pressure fluctuation are assumed to occur five times per year for 60 years.

The number of fluctuations with this pr essure range is expected to be 300 for the DSC. Hence, for an S a value associated with 300 cycles, Equation 1 is equal to 21.6 psig. For a DSC the total range for a significant pressure fluctuation was calculated to equal 3.5 psig. This small pressure fluctuation may occur during normal storage as a result of seasonal ambient tem perature changes. Since the threshold value of 21.6 psig will not be exceeded during the pressure fluctuation of t he DSC, the second criterion is satisfied for the DSC. A.2.1.3 Temperature Differ ence - Startup and Shutdown The third criterion states that the DSC is adequate fo r fatigue effects provided that the temperature di fferences between any two adjacent points on the DSC during normal operation do not exceed:

(Eq. 2)

Where S a is the value obtained from the applicable fatigue curve for the specified number of startup-shutdown cycles, is the instantaneous coefficient of thermal exp ansion at the mean value of the temperatures at the two points, and E is the modulus of el asticity at the mean value of the temperatures at the two points. For an operational cycle of the DSC, thermal gradients occur during fuel loading, DSC closure, transport to t he HSM, and transfer of the DSC to the HSM. This half-cycle is approximately re versed for DSC unloading operations. This normal operational cycle occurs only once in the 60 year design service

life of a DSC at Rancho Seco. Since there is only one st artup-shutdown cycle associated with the DS C, the value of S a and, thus the value of (S a /2E), are very large. This is far greater than the temperature difference between any two adjacent points on the canist er. Thus, the third criter ion is satisfied for the DSC. A.2.1.4 Temperature Difference - Normal Service The fourth criterion stat es that the DSC is a dequate for fatigue effects provided that the temper ature difference between any two adjacent points on the DSC does not change during normal operation by more than the quantity described in Equation 2.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-4 Small fluctuations in the DSC therma l gradients during normal storage in the HSM occur as a result of seasonal ambient temperature changes. Ambient temperature cycles significant enough to cause a measurable thermal gradient fluctuation are assumed to occur fi ve times per year for 60 years. For normal service operations, the maximum stress allowed equates to a maximum temperature of 58°F (Equation 2). The most significant fluctuation in normal operating temperature occurs during a maximum change in ambient temperature. This fluctuation result s in an estimated change of temperature difference for the DSC of 20°F. The effe cts of this temperature difference is below the threshold set by Equation 2 under normal service conditions, therefore the fourth condition is satisfied for the DSC. A.2.1.5 Temperature Differ ence - Dissimilar Materials The fifth criterion states that for components fabricated from materials of differing moduli of elasticity or coeffi cients of thermal expansion, the total algebraic range of temperature fluct uation experienced by the component during normal operation must not exceed the magnitude S a/2(E 11 - E 22), where S a is the value obtained from the applic able fatigue curve for the total specified number of significant temperature fluctuations, E 1 and E 2 are the moduli of elasticity, and 1 and 2 are the values of the instantaneous coefficients of thermal ex pansion at the mean temperature value involved for

the two materials of construction.

Since the structural material used to construct the DSC is homogeneous (all materials are stainless steel), this fifth condition is not applicable. A.2.1.6 Mechanical Loads The sixth criterion states that the DSC is adequate fo r fatigue effects provided that the specified full range of mechanica l loads do not result in a stress range which exceeds the S a value obtained from the applic able fatigue curve for the total specified number of significant l oad fluctuations. If the total specified number of significant load fluctuations exceeds 10 6 , the S a value at N = 10 6 may be used. A load fluctuation is considered to be significant if the total

excursion of stresses exceeds the value of S a obtained from the applicable fatigue curve for 10 6 cycles.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-5 The only mechanical loads which affect the DSC are thos e associated with handling loads and a seismic event. One handling load cycle and a major seismic event are postulated during t he design life of the DSC. The DSC stresses resulting from these mechanical load fluctuations are small since the

structural capacity of the DSC is design ed for extreme accident loads such as a postulated cask drop. The number of significant cycles associated with mechanical load fluctuations is conserva tively assumed to be 1,000. The value of S a associated with this number of cycl es is 119 ksi. Since the maximum stress range intensity permitted by the code is 3.0 S m or 56.1 ksi for SA-240, Type 304 stainless steel at 400°F, this sixth condition is satisfied for the DSC.

A.2.1.7 Conclusion With the six criteria satisfied for a ll components of the DSC, per NB-3222.4 (a), "no analysis for cyclic service is r equired, and it may be assumed that the limits on peak stress intensities as gov erned by fatigue have been satisfied by compliance with the applicable requirements for material, design, fabrication, examination, and testing" of NB-3222.4 of the ASME B&PV Code. A.2.2 Fatigue Analysis of the NUHOMS MP187 Transfer Cask (MP187 TC) The AREVA TN Calculation 502917-0200 Rancho Seco License Renewal

MP187 Multi-Purpose Cask Thermal Fatigu e Analysis, Rev 0, [A-6] evaluated the integrity of the MP187 TC due to fatigue load ing. As with the fatigue evaluation for the DSC, fatigue effect s on the transfer cask are governed by the same six criteria described Section NB 3222.4(d), ASME B&PV Code,Section III, Division 1, Subsections NB, NF, NG and Appendix I, 1992 Edition through 1993 Addenda, [A-1] of the ASME B&PV Code that were used to evaluate the DSC. On-site vertical storage conditions are mentioned in the

case that the DSCs are transported to off-site permanent storage and the Transfer Cask moves from the horizontal to vertical condition during the process. A.2.2.1 Atmospheric To Service Pressure Cycle For on-site transfer conditions (from the fuel build ing to the on-site HSM location) the TC is not a pressure reta ining boundary; hence this first criterion is not applicable.

For on-site vertical storage conditions the cask is designed to serve as a pressure boundary during vertical storage of a leaking DSC. The pressure established at the time t hat the cask is sealed, follo wing loading of a leaking DSC and cask closure operations, is maintained during storage operations.

Therefore, the cask will experience only one atmospheric-to-operating pressure cycle per vertical storage. As described in Section A.2.1.1, the most limiting S m is approximately 1,800 psig. This value is far greater than the unlikely DSC leaking event, and thus t he first criterion is satisfied.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-6 A.2.2.2 Normal Service Pressure Fluctuation For on-site transfer conditions the TC is not a pressure retaining boundary; hence the second criterion is not applicable.

For on-site vertical storage conditions , the cask serves as a pressure boundary. In these conditions, the tota l range of significant pressure fluctuations as described by Equation 1 is 14.1 psig. The most significant fluctuation for normal operating pressure occurs during a maximum change in ambient temperature. This fluctuation results in a maximum pressure change for the TC of approximately 4.5 psig at the maximum total accident pressure case. This value will not be exceeded for on-site vertical storage conditions, and thus the second criterion is satisfied. A.2.2.3 Temperature Differ ence - Startup and Shutdown For on-site transfer conditions, during an operational cycle of the cask, thermal gradients occur during fuel loading , cask closure, transportation, and unloading of the DSC. Conservatively assuming the TC will be used 1,200 times, for the most limiting case, Equation 2 is equal to 210

ûF. This is greater than the temperature diffe rence between any adjacent points on the cask, and thus the third criterion is satisfied.

For on-site vertical storage conditions, the cask thermal gradient differences during this one-time accident scenar io are bounded by on-site transfer conditions. Therefore, the third criterion is satisfied for the cask. A.2.2.4 Temperature Difference - Normal Service For on-site transfer conditi ons, the TC is not affected by the significant temperature difference fluctuations; henc e, this fourth criterion is not applicable.

For on-site vertical storage conditions, sm all fluctuations in the cask thermal gradients during vertical storage occur as a result of seasonal ambient temperature changes. Ambient temperatur e cycles significant enough to cause a measurable thermal gradient fluctuation are conservatively assumed to occur five times per year for 60 years. The cask stresses resulting from

thermal gradient fluctuations are small compared to the stru ctural capacity as the cask is designed for extreme acci dent loads, such as cask drop loads, which are postulated to be a one-time occurrence.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-7 Using very conservative values, for on-site vertical storage conditions Equation 2 equals 49

ûF. The most significant fluctuation in normal operating temperature occurs during a maximum ch ange in ambient te mperature from -

20°F to 100°F. This fluctuation result s in a maximum temperature difference for the cask of approximately 47°F at the cask bottom end closure. The effects of this temperature difference are below the 49

ûF threshold obtained through Equation 2; therefore, the fourth condition is satisfied for the cask. A.2.2.5 Temperature Differ ence - Dissimilar Materials The structural components of the cask consist entirel y of ASME SA-240, Type 304 and XM-19 stainless steels, which have identical modulus of elasticity and slightly different coefficients of thermal expansion. Inconel we ld material (UNS N06625) is used for the longitudinal welds in the XM-19 cask shells and the stainless steel lifting trunnion sleeve to XM-19 cask shell welds.

For these materials the magnitude of S a/2(E 11 - E 22) is equal to 302°F. The most significant fluctuation in norma l operating temperature occurs during a maximum change in ambient temperature.

This fluctuation results in a maximum temperature difference of approx imately for the cask of 47°F at the cask bottom end closure. The effects of this maximum temperature difference are not significant since the calculated 47°F temperature difference in the TC is less than the 302°F temperature fluc tuation associated with the maximum allowed thermal stress of 28.2 ksi. As a re sult, the fifth condition is satisfied for the cask for both on-site transfer and vertical storage conditions. A.2.2.6 Mechanical Loads A load fluctuation is considered significant if the total excursion of stresses exceed the value of S a, obtained from applicable fatigue curve for 10 6 cycles, S = 28.2 psi. The only mechanical loads which affect the cask are those associated with handling loads, normal drop and shock, and seismic loads.

The cask stresses resulting from these me chanical load fluctuations are small since the structural capacity of the cask is designed for extreme accident loads such as postulated cask side drop. The number of significant cycles

associated with mechanical l oad fluctuations is asso ciated with the numbers of lifts of the cask with the trunnions. The maximum stress intensity at upper trunnion/cask shell location due to lifting of the cask is 17.7 ksi, which is less

than the allowed 28.2 ksi. Since the effects of the loads are not significant for this criterion, the sixth condition is satisfied for the cask on-site transfer conditions and vertical storage conditions.

A.2.2.7 Conclusion The evaluation performed demonstrated that the six criteria contained in NB-3222.4(d) are satisfied for all com ponents of the transfer cask and fatigue analysis need not be specifically performed.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-8 Having determined that the six criteria contained in NB-3222.4 (d) are satisfied for all components of the transfer cask, "no analysis for cyclic service is required, and it may be a ssumed that the limits on pe ak stress intensities as governed by fatigue have been satisfied by compliance with the applicable

requirements for material, design, fabrication, examination, and testing" of NB-3222.4 of the ASME B&PV Code. A.2.3 Boron Depletion, Gamma Irradiation, and Neutron Fluence Analysis The AREVA TN Calculation 502917-0500 Rancho Seco License Renewal Boron Depletion and Fluence Analysis, Rev 0, [A-8] performed an analysis to determine the amount of boron depletion of the poison plate material for the Fuel Only (FO) and Fuel with Contro l Components (FC) DSC types at the Rancho Seco site. This analysis also determined the effect on ISFSI equipment materials from gamma exposure and neutron radiation fluence. The analysis was done using MCNP5, MCNP

/MCNPX - Monte Carlo N-Particle Transport Code System Including M CNP5 1.40 and MCNPX 2.5.0 and Data Libraries, [A-2] a general purpose Monte Carlo N-Particle computer code, and SCALE 5.0: Modular Code System fo r Performing Standardized Computer Analysis for Licensing Evaluations for Workstations and Personal Computers, [A-3] a comprehensive modeling and simulation package of codes to perform

reactor physics, criticality safety, radiation shielding, and spent fuel characterization for nuclear facilities and transportation/storage package designs. A.2.3.1 Boron-10 Depletion The results indicate that a negligible amount of boron-10 is depleted over 100 years as shown on Table A-1. Additionally, for a given areal density of boron-10, the depletion increases with decreasing poison plate thickness. An additional sensitivity calculation using half as much boron-10, or [ ] demonstrated similar results.

Conservative hand calculations, assumi ng every source neutron is absorbed by B-10, give a fraction depleted of

[ ] B-10 content plates. More importantly, it is evident that for any poison plate thickne ss, the depleted amount is negligible compared to the initial c oncentration of boron-10. A.2.3.2 Neutron Fluenc e and Gamma Exposure The summarized results of the maximum neutron fluence and gamma exposure integrated over 100 years of storage are presented in Table A-2 and Table A-3, respectively. The results are for a 32-assembly DSC (32PTH1), which is a more conservative model and thus bounds the 24P DSCs (24P-FO, FC, and FF) stored at Rancho Seco.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-9 The results indicate that there is no credible mechanical degradation occurring in compressive strength and tensile strengt h of the DSC shell, shield plug and HSM components due to neutron fluence and gamma exposure levels. Note that neutron fluence in the HSM steel is bounded by neutron fluence of the DSC shell. All radiation levels are below the applicable acceptance criteria. The results also indicate that embrittl ement due to neutron irradiation will not occur in the stainless steel compartment over 100 years of total HSM service life. A.2.4 Combustible Gas Generation This supporting analysis, AREVA TN Calculation 502917-0501 Rancho Seco License Renewal Combustible Gas Generation Analysis, Rev 0, [A-9] was performed to determine the amount of combustible gases generated as a result of irradiation of neutron shield material for the MP187 TC during its function as a TC during the assumed tr ansport scenario at the Rancho Seco ISFSI site.

To estimate the combustible gas generati on in the neutron shield material of the TC due to radiolysis, the analysis: Step 3: Given the energy deposit rate in the neutron shield materials, the combustible gas generation can be determined using the method described in Reference, NUREG/CR-6673, Hydrogen Generation in TRU Waste Transportation Packages, [A-10]. It is determined in this analysis that t he maximum amount of hydrogen, total combustible gases, and all gases generated due to radiolysis of NS-3 is

[ ] moles respectively. Considering that the total hydrogen mass originally present in the neutron shield material is

~209 kg, the fraction of hydrogen liberat ed from the neutron shield material over the service period of the cask is

[ ] by weight, which is statistically insignificant. This very small fractional loss of hydrogen will have an insignificant impact on the ability of the TC neutron shield material to perform its design shie lding function over the Period of Extended Operations (PEO).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-10 A.3 Conclusion The analyses described in Sections A.2.1 and A.2.2 demons trate that the Rancho Seco DSC Shell Assembly, i.

e., pressure boundary subcomponents, and the NUHOMS MP187 TC meet the six criteria contained in NB-3222.4(d), [A-1] and thus "no analysis for cyclic service is required, and it may be assumed that the limits on peak stress intensities as governed by fatigue have been satisfied by compliance with the applicable requirements for material, design, fabrication, examination, and testing" of NB-3222.4 of the ASME B&PV Code, [A-1]. The analysis in Section A.2.3 demonstrates that a negligible amount of boron-10 is depleted over 100 years of service.

In addition, there is no credible mechanical degradation occurring in compressive strength and tensile strength of the DS C shell, shieldin g plug and HSM components due to neutron fluence and gamma exposure levels. The analysis in Section A.2.4 determined that the hydrogen liberated from the neutron shield material over the service period of the cask is statistically insignificant, and thus will have an insignificant impact on the ability of the neutron shield materials of the TC to perform its design function over the PEO.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-11 A.4 References A-1 ASME B&PV Code,Section III, Divis ion 1, Subsections NB, NF, NG and Appendix I, 1992 Editi on through 1993 Addenda. A-2 "MCNP/MCNPX - Monte Carlo N-Partic le Transport Code System Including MCNP5 1.40 and MCNPX 2.5.0 and Data Libraries," Radi ation Shielding Information Center Code Package CCC-730, Oak Ridge National Laboratory, January 2006. A-3 "SCALE 5.0: Modular Code System for Performing Standardized Computer Analysis for Licensing Evaluations fo r Workstations and Personal Computers," Radiation Shielding Information Center Code Package CCC-725, Oak Ridge National Laboratory, June 2004. A-4 "The Topical Report for the NUTECH Horizontal Modular Storage System for Irradiated Nuclear Fuel, NUHOMS

- 24P," Document Number NUH002.0103, Revision 2A, VECTRA File Number NUH002.0103. A-5 "Safety Analysis Report for Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel," NUH-003, Revision 3A, Pacific Nuclear Fuel Services, VECTRA File No. NUH003.0103. A-6 AREVA TN Calculation 502917-0200 Rancho Seco License Renewal MP187 Multi-Purpose Cask Thermal Fatigue Analysis, Revision 0. A-7 AREVA TN Calculation 502917-0201 Rancho Seco License Renewal Dry Storage Canister (DSC) Thermal Fatigue Analysis, Revision 1. A-8 AREVA TN Calculation 502917-0500 Rancho Seco License Renewal Boron Depletion and Fluence Analysis, Revision 0. A-9 AREVA TN Calculation 502917-0501 Rancho Seco License Renewal Combustible Gas Generation Analysis, Revision 0. A-10 NUREG/CR-6673, "Hydrogen Generat ion in TRU Waste Transportation Packages," May 2000.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-12 Table A-1 Boron-10 Depletion Results B-10 Areal Density (g/cm 2) Poison Plate Thickness (inches) Initial B-10 Number Density (#/barn-cm) Basket Component Variations Depleted Amount (#/barn-cm) Percentage B-10 Remaining 1.780E-10 99.999 1.072E-10 99.999 5.405E-11 99.999 1.838E-10 99.999 1.797E-10 99.999 1.898E-10 99.999 1.990E-10 99.999 9.581E-11 99.999

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix A - TLAA for the Rancho Seco ISFSI and Transfer Cask Page A-13

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-i APPENDIX B AGING MANAGEMENT PROGRAMS CONTENTS B.1Purpose ........................................................................................................... B-1B.2Methodology ................................................................................................... B-2B.2.1Scope ...................................................................................................... B-2B.2.2Aging Management Progr am Elements .................................................. B-2B.3DSC External Surfaces Aging Management Program ................................. B-4B.3.1Materials ................................................................................................. B-4B.3.2Environment

............................................................................................ B-4B.3.3Aging Effects Requiri ng Management .................................................... B-4B.3.4Program Description ............................................................................... B-5B.3.5Evaluation and Techni cal Basis .............................................................. B-5B.4HSM Aging Manageme nt Program .............................................................. B-13B.4.1Materials ............................................................................................... B-13B.4.2Environment

.......................................................................................... B-13B.4.3Aging Effects Requiri ng Management .................................................. B-13B.4.4Program Description ............................................................................. B-14B.4.5Evaluation and Techni cal Basis ............................................................ B-14B.5Transfer Cask Aging Mana gement Program .............................................. B-21B.5.1Materials ............................................................................................... B-21B.5.2Environment

.......................................................................................... B-21B.5.3Aging Effects Requiri ng Management .................................................. B-21B.5.4Program Description ............................................................................. B-21B.5.5Evaluation and Techni cal Basis ............................................................ B-22B.6Basemat Aging Manage ment Program ....................................................... B-25B.6.1Materials ............................................................................................... B-25B.6.2Environments ........................................................................................ B-25B.6.3Aging Effects Requiri ng Management .................................................. B-25B.6.4Program Description ............................................................................. B-26B.6.5Evaluation and Techni cal Basis ............................................................ B-26B.7Conclusion .................................................................................................... B-30 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-ii B.8References .................................................................................................... B-31 CONTENTS Table B DSC AMP Inspections ............................................................................. B-32Table B HSM AMP Inspections ............................................................................. B-34Table B Transfer Cask AMP Inspections .............................................................. B-38Table B Basemat AMP Inspections

....................................................................... B-39 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-1 B.1 Purpose The application for the renewal of the Rancho Seco 10 CFR Part 72-specific storage license SNM-2510 must demonstrat e that the effect s and mechanisms of aging on structures, systems, and components (SSCs) subject to aging management review (AMR) will be managed in a manner that is consistent with the licensing basis for the proposed period of extended operation (PEO). Based on the results of the AMR, t he in-scope SSCs and subcomponents will

be subject to an appropriate Aging M anagement Program (AMP) for managing these aging effects.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-2 B.2 Methodology B.2.1 Scope The AMPs included in this evaluation are: DSC External Surfaces AMP. HSM AMP for External and Internal Surfaces. Transfer Cask AMP.

Basemat AMP. B.2.2 Aging Management Program Elements The structure of each AMP is consis tent with the ten program elements described in NUREG-1927 Standard Review Plan for Renewal of Specific Licenses and Certificates of Complia nce for Dry Storage of Spent Nuclear Fuel, [B-11] and input from the draft MAPS Report Managing Aging Process in Storage (MAPS) Report, [B-12] as applicable and identified below. The elements for each AMP are as follows:

1. Scope of the Program: The scope of the program includes specific SSCs and subcomponents covered by the AMP and the intended functions to be maintained.
2. Preventive Actions:

Preventive actions will ei ther prevent aging or mitigate the rate of aging for SSCs by following the activities in the AMP.

3. Parameters Monitored or Inspected:

Parameters monitored or inspected will identify t he specific parameters t hat will be monitored or inspected and describe how t hose parameters will be capable of

identifying degradation or potential degradation before a loss of intended function.

4. Detection of Aging Effects: It is intended that det ection of aging effects will occur before there is a loss of intended function for any SSC identified within the scope of the progr am. This includes aspects such as method or technique (i.e., visual, volumetric, su rface inspection), frequency, sample size, data collection, and timing of new or one-time inspections to ensure

timely detection of aging effects.

"Accessible areas" are defined as surfaces of in-scope SSCs and subcomponents that can be visually inspected by direct means without disassembly.

"Normally non-accessible areas" are defined as surfaces of in-scope SSCs and subcomponents that can be visually inspected by remote means without significant disassembly (such as removal of HSM door).

"Inaccessible areas" are defined as surfaces of in-scope SSCs and subcomponents that cannot be visually inspected by direct or remote means.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-3 5. Monitoring and Trending:

Monitoring and trending shall provide for an evaluation of the extent of the effects of aging and the need for timely corrective or mitigating actions.

6. Acceptance Criteria: Acceptance criteria, against which the need for corrective action will be evaluated, will ens ure that the parti cular structure and component intended functions and the approved design bases are maintained during the period of extended operation. Proposed acceptance

criteria will be appropria tely justified.

7. Corrective Actions:

Corrective actions are the measures to be taken when the acceptance criter ia are not met. Time ly corrective actions, including root cause determinati on and prevention of recurrence for significant conditions adverse to qualit y, are critical for maintaining the intended functions of the SSCs during the initial storage peri od, as well as the PEO. 8. Confirmation Process:

The confirmation process will ensure that preventive actions are adequate and appr opriate corrective actions have been completed and are effective.

9. Administrative Controls:

Administrative controls for the AMPs and implementing procedures will provide a formal review and approval process. 10. Operating Experience: Operating experience (OE) involving the AMP, including past corrective actions resulting in program enhancements or

additional programs, is intended to prov ide objective evidence to support a determination that the effects of aging will be adequately managed so that the structure and component intended f unctions will be maintained during the period of ex tended operation.

Note that this is a learning AMP process. Inspections and associated precursors for the monitoring of aging effects will be updated as necessary to incorporate new information as it becomes available.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-4 B.3 DSC External Surfaces Aging Management Program The materials, environments and aging e ffects requiring management for the external surfaces of the DSC are as follows: NOTE: For the purpose of this AMP, 1) all references to "DSC" also include the "GTCC" canister unless otherwis e stated; and 2) t he DSC external surfaces of the shell assembly also incl ude the external surfaces of the outer bottom cover plate, grapple ri ng and outer top cover plate.

B.3.1 Materials The DSC shell assembly components subj ect to AMR are constructed of the following material: Stainless Steel B.3.2 Environment The DSC shell assembly components subject to AMR are exposed to the following environment:

Sheltered B.3.3 Aging Effects Requiring Management The following aging effects associated with the DSC shell assembly components require monitoring:

Loss of material due to crevice and pitting corrosion for stainless steel components. Loss of material due to galvanic co rrosion for the DSC shell contacting graphite lubricant at t he sliding rail surface. Cracking due to stress corrosion cracking (SCC) - reference to Section 6.5 and Table 6-2 of MAPS, [B-12] as it points out recent industry information by Electric Power Research Institute (EPRI) Aging Management Guidance to Address Po tential Chloride-Induced Stress Corrosion Cracking of Welded Stainl ess Steel Canisters, [B-5].

Note that an analysis was performed in accordance with current EPRI guidance for ranking susceptibility for loss of material due to chloride-induced stress corrosion cracking (CISCC), [B-5

]. The analysis determined that the susceptibility ranking for the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) site is "2" on a 1 to 10 scale ("10" being the most susceptible to CISCC). This low ranking, along with the favorable environmental conditions, points to the conclusion that the potential for chloride aerosols leading to chloride accumulation on ISFSI components at

Rancho Seco is very low and that enhanced monitoring for CISCC is not warranted.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-5 B.3.4 Program Description The objective of the program is to manage the effects of aging mechanisms on the external surfaces of the DSC shell assembly subject to aging during the PEO. The program manages aging effects through inspection of external surfaces for evidence of the following:

1) loss of material due to corrosion; and
2) cracking due to SCC. B.3.5 Evaluation and Technical Basis 1) Scope of Program This program visually inspects and moni tors the external surfaces of the DSC that may be subject to loss of material and cracking. The program scope includes external surfaces of the DSC shell assembly. The areas of DSC inspection are: Fabrication welds of the confinement boundary and the associated heat affected zone (HAZ), i.e., longi tudinal and circumferential welds on the cylindrical shell. Crevice locations, i.e., where the shell sits on the support rail The upper surface of the cylindrical shell, where atmospheric particulates would settle. The top and bottom ends of the cy linder, which are cooler than the center. Outer bottom cover plate, grapple assembly, their welds and HAZ. Outer top cover plate, welds and HAZ.

The last two areas are not part of the confinement boundary, but their condition must be ascertained prior to retrieval and transport. As vertical surfaces out of the main path of air fl ow, they are the least susceptible to the effect of atmospheric deposits. A ccessibility to the outer top cover plate is limited during storage due to tight clearance with the end wall of the horizontal storage m odule (HSM) and no access to the top of the HSM. Accessibility to the outer botto m cover plate and grapple ring will be through the 2-inch diameter seismic restraint port of the HSM access door.

Based on industry experience, the HAZ is considered to extend approximately 1/2 inch away from the edge of a weld on both sides. To be conservative, the inspections of the HA Z will extend to a distance of at least 2 inches on either side of the welds.

Locations of temporary fabr ication welds are not likely to result in through-thickness sensitization or tensile stress, so they are not included as areas for inspection. 2) Preventive Actions This is a condition monitoring progra

m. It does not include preventive actions.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-6 3) Parameters Monitored or Inspected The DSC External Surfaces AMP consists of visual inspections to monitor for material degradation.

There are no "accessible" areas of the DSC available for direct visual inspections since it is sheltered inside the HSM.

The following "normally non-accessible" areas will undergo remote visual inspection for loss of material and cracking:

DSC surfaces, welds and HAZs, and crevice locations near the DSC support rails are inspected for discontinuities and imperfections. Localized corrosion (e.g., pitting and cr evice corrosion), cracking and stains (caused by leaking rainwater) or discolorations are documented, if any. Appearance and location of atmospheric deposits on the DSC

surfaces are recorded. No additional action is required for rainwater stains or discoloration unless evid ence of corrosion is exhibited.

Portions of the outer top cover plate, closure weld and HAZ. Outer bottom cover plate, grapple ring assembly and their welds and HAZs. Portions of the DSC Shell botto m surface (including edge of DSC support rails and HAZ). The "inaccessible" areas of the DSC include: The upper surface of the DSC Shell (i.e., where atmospheric particulates may settle) The majority of outer top cover plate, welds and HAZ The DSC Shell crevice locations (i.e. where the shell rests on DSC support rail) 4) Detection of Aging Effects This program manages aging effects for loss of material due to crevice, pitting, and galvanic corrosion, and cracki ng due to SCC of stainless steel using visual inspection. Visual examinations follow procedures consistent with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PVC),Section XI, Rules for Inservice Inspection of Nuclear Power Plants and Fuel Processing Plants, [B-4]

Subsection IWA-2200. 4.1) Selection of DSC(s) for Inspection One DSC was selected for the baseline and any subsequent inspections; it was the same DSC inspected during the pre-application inspection. The DSC selected for inspection was based on the following considerations/criteria and the benign environ ment at the Rancho Seco ISFSI site:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-7 A) Time in service: Storage duration (time in service) is related to surface temperature and depositi on of contaminants. The DSC selected for inspection was from the pool of DSCs with longest time in service. B) Initial heat load: The DSC selected for inspection was from a pool of DSCs with low initial heat loadi ng that result in low DSC shell surface temperatures, thus increa sing relative humidity inside the

HSM and promoting incubation of ambient contaminants. C) DSC Fabrication and Design Co nsiderations: A review of the design drawings and DSC fabrication package was performed to

further "screen-in" the DSC from the pool of candidates selected based on (A) and (B). Fabrication we ld maps were reviewed to identity locations of the circum ferential and longitudinal welds; location and disposition of wel ded attachments, and external configurations of the inner bottom cover-to-shell weld. D) HSM array configuration relative to climatological and geographical features: Per Volume I, Rancho Se co ISFSI Final Safety Analysis Report (FSAR), Rancho Seco Independent Spent Fuel Storage Installation Final Safety Analysis Report Rev. 6, dated August 2016 (Docket 72-11), [B-1] the HSM back-to-back arrays are installed on the Rancho Seco ISFSI pad with a North-South exposure. The vents of the HSMs are oriented in an east-west direction. Per Section 2.3.1.1 of the ISFSI FS AR, the wind direction at Rancho Seco generally follows a north to northwest direction or south to southeast direction. Therefore, the vent openings do not face the prevalent wind direction. However, the potential to bring ambient contaminants (if any) to the DSC external surfaces was still considered.

The considerations/criteria described above provide the basis for selection of the bounding DSC for inspection. This is a learning AMP. The selection

criteria described above will be updated as necessary to incorporate new information.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-8 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-9 4.3) Inspection Timing and Frequency The baseline AMP visual inspection will be no later than two years after entering the PEO, with follow-on inspections at a 10 + 2-year interval. If the preceding inspecti on identified a major corrosion indication (see Acceptance Criteria section below for definition), the interval between inspections is decr eased to 5 years + 1 year (or when an engineering evaluation calculates an identified cra ck will reach 75% through-wall (whichever is less). The inspection interval of 10 years is consistent with ASME, B&PV Code,Section XI, [B-4] Subarticle IWA-2430 optional inspection progr am B (Paragraph IWA-2432). 5) Monitoring and Trending The inspections and monitoring activities in this AMP are performed periodically in order to identify areas of degradation. Conditions adverse to quality noted during the inspection and monitoring activities, such as non-conformances, failures, malfunctions, deficiencies and deviations are

entered into the SMUD Corrective Acti on Program. Visual inspections appropriately consider cumulative OE from previous inspections and assessments, in order to monito r and trend the progression of aging effects over time. Data taken for thes e inspections are to be monitored by comparison to past site data taken as well as comparison to industry OE, including data gathered by the Ag ing Management INPO Database (AMID) as discussed in NEI 14-03 Fo rmat, Content and Implementation Guidance for Dry Cask Storage Oper ations-Based Aging Management" Revision 2, 2016, [B-13]. 6) Acceptance Criteria The acceptance criteria for this AM P follows the guidance provided in EPRI Report 3002008193, [B-5] which fo cuses on CISCC. This report states that CISCC has been identifi ed as the most likely and limiting degradation mechanism that could lead to through-wall penetration of the austenitic stainless steel canister dur ing storage. Thus, other atmospheric corrosion mechanisms (e.g. pitting) are conservatively addressed by these acceptance criteria. There are thr ee tiers of acceptance criteria: (i) Visual examination criteria - Visual examination results are evaluated using this criteria (ii) Augmented Examination criteria - Surface or volumetric examination is evaluated using this criteria (iii) Flaw Evaluation criteria

- Used if cracking is detected 6.1) Visual Examination criteria: Criteria are provided below to classify the indication as a major, minor, or an insignificant corrosion indication.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-10 The presence of a major corrosion indication anywhere on the DSC, or a minor corrosion indication within 2 inches of a weld, will result in performance of a supplemental surface or volumetric examination for the presence of cracking. This will also be entered into SMUD's Corrective Action Program. A minor corrosion indication more t han 2 inches from a weld will receive a supplemental VT-1 exam to demonstrate that there is no attack of the metal under the corrosion indication. If it is determined there is an attack of the metal under the corrosion indication, then the condition will be entered into SMUD's Corrective Action Program. Major corrosion indications: If a corrosion indication meets any of the following, it will be considered a major indication: Cracking of any size. Corrosion products having a linear appearance, except light corrosion indicative of iron contamination. Corrosion products having a branching appearance.

Evidence of pitting corrosion, und er-deposit corrosion, or etching with measurable depth (removal/atta ck of material by corrosion). In a 10 cm x 10 cm region, corrosi on product is present in 25% or more of the surface with evidenc e of attack into the DSC. Evidence of water intrusion into a crevice location with rust staining at the edge of the crevice. Corrosion product deposit present at the mouth of an occluded region that includes a portion of the DSC shell weld. Minor corrosion indications: If a corrosion indication is not a majo r indication and it meets any of the following, it will be considered a minor indication: Evidence of water intrusion via staining in the color of normal corrosion products. Areas of light corrosion that follo w a fabrication f eature or anomaly (e.g. scratch or gouge) - such indi cations are indicative of iron contamination. In a 10 cm x 10 cm region, corrosi on product is present in 10% to 25% of the canister surface. Corrosion product greater than 2 mm in diameter. Insignificant corrosion indications:

Corrosion indications that do not meet the criteria for being either a major or minor corrosion indicati on are considered insignificant corrosion indications. Insignificant corrosion indications are acceptable without further action.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-11 6.2) Augmented Examination:

If a surface examination is performed, no further actions are required if any of the following apply: If a surface examination conf irms the absence of flaws. If the detected flaw is a rounded indication, and if no corrosion products or masking deposits are present. If the detected flaw is a linear indi cation, if no corrosion products or masking deposits are present, and if the linear indication is determined not to have a crack-like morphology.

If a volumetric examination is perfo rmed no further actions are required if any of the following apply: If a volumetric examination confi rms the absence of planar flaws. If the detected indication is det ermined to not be connected to the exterior of the DSC (i.e., not associated with the outside surface). If the entirety of the detected flaw is in an area that is confirmed to have no corrosion products present, and if the indication is determined to not have a crack-like morphology. If the detected indication was reco rded prior to being mitigated or remediated and there has been no measurable increase in the flaw size after being remediated.

If none of the above volumetric examin ation bullets appl y, the detected indication is associated with the outside surface connected planar flaw and is considered material cracki ng. In this case, an engineering evaluation is performed to demonstr ate the acceptability of the cracking indication using Flaw Evaluation. 6.3) Flaw Evaluation If a crack is identified, an engine ering evaluation is performed to determine when the flaw will reach 75% of through-wall thickness.

If the flaw is measured to be greater than 75%, or if it is not feasible to perform a supplemental inspection prior to when the engineering evaluation determined the flaw will reach 75% through-wall, the condition will be addressed in accordance with SMUD's Corrective Action Program. Industry OE will be reviewed to identify any consequences of through-wall CISCC with an appropriate limiting

length. 7) Corrective Actions Sacramento Municipal Utility District quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented according to the requirements of t he Rancho Seco Quality Manual (latest revision), [B-2]. Sacramento Municipal Utility District's Corrective Action Program ensures that conditions adverse to quality are promptly identified and Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-12 corrected, including root cause determi nations and prevention of recurrence.

Deficiencies are either co rrected, or are evaluated as acceptable for continued service through engineering analysis, which provides reasonable assurance that the intended function is maintained consistent with current licensing basis conditions. Evaluations performed to assess conditions associated with aging should utilize the same methodology used in the licensing and design basis calculations for SMUD as much as practical to ensure intended functions are maintained through the PEO. Extent of condition investigation may trigger

additional inspections via a different method, increased inspection frequency or expanded inspection sample size. Ident ification of major corrosion requires an expansion of the sample size to determine the extent of condition at the site. A subject DSC with major corrosion that does not meet the prescribed evaluation criteria must be evaluated for continued service. 8) Confirmation Process Conditions adverse to quality noted during the inspection and monitoring activities are entered into SMUD's Co rrective Action Program. Procedural controls are in place to ensure the responses to corrective action assignments are reviewed and to verify the response adequacy. Condition reports are also reviewed for trending purposes. A tollgate will be established to assess effectiveness of corrective actions and update the AMP as necessary on a periodic basis. 9) Administrative Controls Administrative controls are based on and implemented in accordance with the requirements of a 10 CFR Part 72, Subpart G quality program and will continue for the PEO. The Rancho Seco Quality Manual, [B-2] meets this

requirement. 10) Operating Experience Operating Experience for DSCs is as evaluated in the AMR. The OE consisting of Industry OE, TN-spe cific OE and SMUD-specific OE supports a conclusion that no other actions will be necessary to adequately detect aging effects and mechanisms other than those

prescribed above.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-13 B.4 HSM Aging Management Program The materials, environments, and agi ng effects requiring management for the HSM internal, external and struct ural components are as follows:

B.4.1 Materials The HSM subcomponents subject to aging management review are constructed of the following materials: Reinforced concrete - base, roof and walls and reinforcing bar (rebar).

Carbon Steel - support structures, heat shields, and bolting.

Stainless steel (Nitronic

60) - DSC support rail plate.

B.4.2 Environment The HSM subcomponents that are subject to aging management are exposed to the following environments: Sheltered Outdoors Embedded B.4.3 Aging Effects Requiring Management The following aging effects associated with the HSMs require management: Cracking; loss of material (spalling, scaling) due to corrosion of embedded steel for reinforced concrete. Cracking due to expansion from r eaction with aggregates, such as alkali silica reaction (ASR) for reinforced concrete). Change in material properties -

increase in porosity and permeability due to aggressive chemical attack and l eaching for reinforced concrete. Loss of material due to general, pitti ng, and crevice corrosion for carbon steel components. Loss of material due to crevic e, pitting and galvanic corrosion of Nitronic 60 DSC support rail plates. Cracking due to SCC - welds attaching Nitronic 60 rail face - reference to Section 6.6 and Table 6-3 of MAPS, [B-12] as it points out recent industry information by EPRI, [B-5]. Loss of material due to aggressive chemical attack.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-14 B.4.4 Program Description The objective of the program is to manage the aging effects on the internal and external surfaces of the HSMs dur ing the PEO. This is accomplished by inspection for evidence of cracking due to aggressive chemical attack, and ASR for reinforced concrete structures

loss of material due to aggressive chemical attack and corrosion of embedded steel; and increase in porosity and

permeability, and loss of strength due to aggressive chemical attack and leaching of calcium hydroxide and carbonat ion. The inspections will also look for evidence of cracking of the welds on the Nitronic 60 rail face due to SCC.

It also manages loss of ma terial due to general, pitting, and crevice corrosion of steel components (e.g., access door, DSC support structure, heat shields, connecting hardware a nd embedments). B.4.5 Evaluation and Technical Basis 1) Scope of Program The scope of the HSM AMP includes visual inspection of accessible

concrete and steel components includi ng HSM walls, roof, and floor slab, HSM access door, DSC support structure and rail assembly, heat shields, embedments and anchorages (including bolts and mounting hardware).

The program consists of periodic vis ual inspections by personnel qualified to monitor structures and components for applicable aging effects and mechanisms, such as those described in the American Concrete Institute (ACI) 201.1R ACI-201.1R, Guide for C onducting a Visual Inspection of Concrete in Service, 2008, [B-6] and ACI 349.3R, Evaluation of Existing Nuclear Safety Related Concrete Structures, [B-8]. 2) Preventive Actions The program is a conditionmonitoring program that does not include preventive actions. 3) Parameters Monitored The accessible areas of the HSMs under direct visual inspection include: The external concrete surfaces of the HSM roof and walls. External surfaces of the HSM access door. Attachment hardware.

The normally non-accessible areas of HSM under remote visual inspection for loss of material and cracking include: Portions of the concrete floor sl ab, and visible areas of front, back and side walls. Portions of the DSC support st ructure and attachment hardware.

The inaccessible areas of the HSM include:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-15 The internal surface of the HSM roof blocked from view due to the upper heat shield. Heat shields at internal surface of the roof and side walls.

For each material/aging effect comb ination, the specific parameters monitored or inspected depend on the particular HSM subcomponent as described below. Parameters monitored or inspected are commensurate with industry codes , standards, and guidelines and consider industry OE as well as SMUD-specific OE. Reinforced Concrete For concrete structures, parameters monitored include: (1) cracking, and loss of material (spalling and scaling) due to corrosion of embedded steel, or aggressive chemic al attack; (2) cracking due to expansion from reaction with aggregates from ASR; and (3) increase in porosity and permeability due to leaching. Steel Carbon steel and stainless steel components are monitored for loss of material due to general, pitting, crevice corrosion and galvanic corrosion. Other conditions, such as loose or missing anchors, and missing or degraded grout are also part of the inspection.

Stainless Steel (Nitronic

60) components are monitored for loss of material due to general, pitting, and crevice corrosion.

The welds attaching the Nitronic 60 rail face are inspected for cracking due to SCC. 4) Detection of Aging Effects As appropriate, direct or remote visual inspections utilizing ACI-349.3R, [B-8], Section 3.5.1 are conducted fo r HSM concrete in both Outdoor and Sheltered environments, allowing fo r detection of aging effects from

Section B.4.5(3). Consistent with ASME B&PV Code,Section XI, [B-4] on visual examination techniques, VT-3 direct or remote vi sual inspections are utilized for general inspections for HSM steel components depending on whether these components are accessible or normally non-accessible, respectively. VT-3 visual examinations are performed for steel surfaces, detecting aging effects while identifying and assessing discontinuities and imperfections on the surface of components. As much of the HSM steel surfaces as can be reasonably accessed, are examined by VT-3 to

ascertain their general condition.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-16 Inspection of the normally non-accessibl e internal surfaces of the HSM concrete may be performed using a video camera, fiber-optic scope, or other remote inspection technology vi a existing access points of the HSM.

The remote inspection system is qualified and demonstrated to have sufficient resolution capability and enhanced lighting to resolve the acceptance criteria identif ied in Section B.4.5(6).

For HSM concrete, crack maps wit h a photographic record and physical dimensions are developed using ACI-224.4R guidance, Guide to Design Detailing to Mitigate Cracking, [B

-7] and are monitored and trended as a means of identifying progressive grow th of defects that may indicate degradation due to specific aging effects, such as rebar corrosion. Crack maps and photographic records are co mpared with those from previous inspections to identify accelerated degradation of the concrete during the PEO. Similarly, dimensioning is do cumented in photographic records by inclusion of a tape measure/cra ck gauge, a comparat or, or both.

Within the HSM cavity, certain su rface areas may be inaccessible for direct visual and remote inspection. This AMP addresses detection of aging effects for inaccessible areas indi rectly by monitoring the inspection findings within accessible and normally non-accessible areas. Therefore, inaccessible area inspections may only be required because of the SMUD ISFSI Corrective Action Program to ensure the aging effect is adequately managed and that the component's intended function is maintained during the PEO. Performance of the baseline AMP visual inspection will be no later than two years after PEO commencement, with follow-on inspections at a 10+ 2-year interval. The inspection interv al of 10 years is consistent with ASME, B&PV Code,Section XI, [B

-4] Subarticle IWA-2430 optional inspection program B (Paragraph IWA-2432). Furthermore, a 10-year inspection frequency for both inside and outside HSM surfaces is justified based on the benign environmental conditions observed during the pre-

application inspection. If preceding in spection acceptance criteria have

been exceeded or the trending from previ ous inspections is unclear, the

interval between the sheltered envi ronment HSM component inspections is decreased to 5 years +/-1 year.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-17 5) Monitoring and Trending Inspection and monitoring activities in this AMP are performed periodically in order to identify areas of degradation. Conditions adverse to quality noted during the inspection and monitoring activities, such as non-conformances, failures, malfunctions, deficiencies, and deviations are

entered into the SMUD Corrective Acti on Program. Visual inspections appropriately consider cumulative OE from previous inspections and assessments, in order to monito r and trend the progression of aging effects over time. Data taken for thes e inspections are to be monitored by comparison to past site data taken as well as comparison to industry OE, including data gathered by the AMID, as discussed in NEI 14-03, [B-13].

In addition, for sheltered environment SCCs, confirmed aging effects within accessible locations require expanded remote visual inspections within accessible or normally non-accessible locations and may also require expanded remote visual inspections within inaccessible locations. 6) Acceptance Criteria For the HSM AMP for External and In ternal Surfaces, inspection results will be evaluated by qualif ied engineering personnel based on acceptance criteria selected for each structure and aging effect to ensure that the need for corrective actions is identified before loss of intended function

occurs. The criteria are derived from design basis codes and standards that include ACI 349.3R, [B-8] ACI 318, Building Code Requirements for Reinforced Concrete, [B-9] ANSI/ASCE 11-99, Guideline for Structural Condition Assessment of Existing Buildings, [B-10] and ASME B&PV Code,Section XI, [B-4]. The criteria are directed at the identification and evaluation of degradation that may affect the ability of the HSM to perform its intended function. Should the in spection acceptance criteria be exceeded, the identified issue requires further evaluation and is entered into SMUD's corrective action program. Loose bolts and nuts and cracked

bolts are not acceptable unless approv ed by an engineering evaluation. Metallic Components of the HSM:

Consistent with Subarticle IWA-2210 of the ASME B&PV Code,Section XI, [B-4] on visual ex amination techniques, VT-3 inspections in accordance with IWF-3400 are utilized for general inspections for HSM

steel components. For metallic surfaces, any of the following indications of relevant degradation detected require further evaluation: Corrosion and material wa stage (loss of material) Crevice, pitting and galvanic corrosion (loss of material) Corrosion stains on adjacent com ponents and structures (loss of material) Surface cracks (cracking)

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-18 Stains caused by leaking rainwater if evidence of corrosion is exhibited (stains alone do not require action beyond documenting the condition)

If any of the above items are identified by the VT-3 inspection, these items are to be considered exceeding the second-tier cr iteria (ACI 349.3R), requiring further evaluation through t he SMUD Corrective Action Program. (Though the ACI applies to concrete structures, the reason for providing this as acceptance criteria for metallic components is that individual metallic component degradations are given the same level of corrective

actions as the parent HSM material code. Note that it says "

above identified items are considered as exceeding second tier criteria of ACI 349.3R requiring further evaluation"). This may include performing a more detailed VT-1 visual examination of the flaws.

Concrete HSM structure:

Concrete acceptance criteria from ACI 349.3R, [B-8] provide acceptable conditions for observed degradation that has been determined to be

inactive. These criteria are termed se cond-tier for structures possessing a concrete cover in excess of the minimum requirements of ACI 349. Inactive degradation can be determined by the quantitative comparison of current observed conditions with that of prior inspections. If there is a high potential for progressive degradation or propagation to occur at its present or an accelerated rate, the disposit ion should consider more frequent evaluations of the specif ic structure or initia tion of repair planning.

The following findings from a visual in spection are considered acceptable without requiring any further evaluation: Absence of leaching and chemical attack, including microbiological chemical attack. Absence of signs of corrosion in the steel reinforcement. Absence of drummy areas (poorly consolidated concrete, air void with paste deficiencies per ACI 201.1R, [B-6]). Popouts and voids less than 50 mm (2 in.) in diameter or equivalent surface area. Scaling less than 30 mm (1-1/8 in.) in depth. Spalling less than 20 mm (3/4 in.)

in depth and 200 mm (8 in.) in any dimension. Absence of corrosion staining of undefined source on concrete surfaces. Passive cracks less than 1 mm (0.04 in.) in maximum width ("passive cracks" are defined as those having an absence of recent growth and absence of other degradation me chanisms at the crack). Passive deflections within the original design limits.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-19 7) Corrective Actions Sacramento Municipal Utility District QA procedures, review and approval processes, and administrative controls are implemented according to the requirements of the Rancho Seco Quality Manual, [B-2]. Sacramento Municipal Utility District's Correct ive Action Program ensures that conditions adverse to quality are pr omptly identified and corrected, including root cause determinati ons and prevention of recurrence. Deficiencies are either corrected, or are evaluated as acceptable for continued service through engineering analysis, which provides reasonable assurance that the intended function is maintained consistent with current licensing basis conditions. Evaluations performed to assess

conditions associated with aging s hould utilize the same methodology

used in the licensing and design basis calculations for SMUD as much as practical to insure intended functions are maintained throughout the PEO. Extent of condition investigation ma y trigger additional inspections via a different method, increased inspec tion frequency or expanded inspection

sample size.

In addition, for sheltered environm ent SSCs, confirmed aging effects within accessible locations require expanded remote visual inspections within inaccessible locations. More frequent inspections would remain in effect until reasonable assurance is atta ined that indicates deterioration is adequately detected, appropriately addressed, and that the current material condition complies with the acceptance criteria.

Repair, restoration or corrective action of an unacceptable condition should be performed consistent with ACI-224.4R, [B-7] and article IWA-4000 of the ASME B&PV Code,Section XI, [B-4]. 8) Confirmation Process Conditions adverse to quality noted during the inspection and monitoring activities are entered into SMUD's Co rrective Action Program. Procedural controls are in place to ensure the responses to corrective action assignments are reviewed and to verify the response adequacy. Condition reports are also reviewed for trending purposes. A tollgate will be established to assess effectiveness of corrective actions and update the

AMP as necessary on a periodic basis. 9) Administrative Controls Administrative controls in accordance with SMUD's QA procedures and

Corrective Action Program provide a formal review and approval process. Administrative controls are based on and implemented in accordance with

the requirements of a 10 CFR Part 72, Subpart G quality program and will continue for the PEO. The Rancho Seco Quality Manual, [B-2] meets this

requirement.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-20 10) Operating Experience Operating Experience for the HSMs is as evaluated in the AMR. The OE supports an assessment that the e ffects of aging ar e adequately managed to the extent that t he HSM design functions ar e maintained during the PEO. No other actions are necessary to adequately detect aging effects other than those prescribed above.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-21 B.5 Transfer Cask Aging Management Program The NUHOMS MP187 Transfer Cask has not been needed for on-site transfer of spent nuclear fuel or Greater-Than-Cla ss C (GTCC) waste at Rancho Seco since 2006 because all of the fuel and GTCC waste had been placed into storage at the ISFSI at that time. However, materials, environments, and aging effects still require management for the exposed surfaces of the TC as follows:

B.5.1 Materials The TC is constructed of the following materials: Stainless Steel - shell assembly and rails Carbon Steel - attachment hardware Lead - inner annulus shielding ma terial (internal/inaccessible)

NS-3 resin - outer annulus shielding B.5.2 Environment The TC is exposed to the following environment: Sheltered B.5.3 Aging Effects Requiring Management The following aging effects associat ed with the TC assembly require management: Loss of material due to general corrosion - carbon steel Loss of material due to crevice and pitting corrosion for carbon steel and stainless steel components Loss of material due to wear Cracking due to SCC Loss of Material due to galvanic corrosion - stainless steel rail, inner shell, bottom end closure B.5.4 Program Description The objective of the program is to m anage the aging effects on the surfaces of the TC shell requiring management dur ing the PEO. The program manages aging effects through visual inspection of external surfaces of the TC subcomponents for evidence of the follo wing: 1) loss of material due to corrosion (e.g., general, crevice, galvani c corrosion and pitting), 2) loss of material due to wear, and cracking due to SCC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-22 B.5.5 Evaluation and Technical Basis 1) Scope of Program This program visually inspects and monitors all the accessible TC subcomponents surfaces to ensure that they are intact and free from loss of material due to general, crevice, galvanic, or pitting corrosion, loss of material due to wear, and cracking due to SCC.

The program performs ASM E B&PV Code,Section XI, [B-4] VT-3 visual inspections on all TC accessible su rfaces. An ASME B&PV Code,Section XI VT-1 visual inspection will also be performed on any area of the TC where the VT-3 inspections detect signs of degradation. 2) Preventive Actions The program is a conditionmonitoring program that does not include preventive actions. 3) Parameters Monitored The parameters inspected by this AMP are visual evidence of degradation of accessible surfaces of the TC, including the trunnions. The surfaces of the cask cavity inner liner are ex amined for surface conditions and for indications of corrosion, cracking or excessive wear. Fasteners are examined for surface conditions and for indications of damage or excessive wear.

Visual inspections of the external su rfaces of the TC, bearing surfaces of the upper and lower trunnion assemblies, fasteners, and cask lid surfaces are performed prior to use. Visual in spections look for signs of degradation (corrosion and wear).

The TC rails, which provide the slidin g surface for the DSC, are fabricated from a non-galling, wear resistant Nitronic 60 material. They are visually inspected for indications of corrosi on, cracking, or excessive wear.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-23 4) Detection of Aging Effects This program manages aging effects for loss of material due to crevice, galvanic, pitting, and general corrosion, cracking and loss of material due to wear. Inspections in this AMP ar e all performed "prior to use" for a loading/unloading campaign in order to identify areas of degradation.

Visual inspections are performed to determine the physical condition of accessible surfaces of the TC, including the upper and lower trunnion assemblies and cask lid. VT-3 examinations are in accordance with the ASME B&PV Code,Section XI, [B-4] Subsection IWA-2213. These inspections check for loss of materi al (corrosion and wear). Any area of the TC where the VT-3 inspections detect degradation, with respect to corrosion and wear, will also be subjec ted to a VT-1 examination per ASME B&PV Code,Section XI, [B-4

] IWA-2211. Fasteners are inspected for condition of threaded parts, corrosion, and signs of wear or

degradation.

The TC cask was used at SMUD during fuel loading and transfer operations that concluded in August 2002 for all DSCs except the GTCC canister, which concluded in 2006. All of the DSCs are in storage in the HSMs and the TC will only be used when the DSCs are to be retrieved

from the HSMs for offsite shipment. T herefore, pre-servic e inspections are more appropriate for the TC at SMUD. 5) Monitoring and Trending Monitoring activities in this AMP are performed in order to identify areas of

degradation. Conditions adverse to quality noted during the monitoring activities, such as non-conformances, failures, malfunctions, deficiencies, and deviations are entered into the SMUD Corrective Action Program.

Visual inspections appropriately consider cumulative OE from previous inspections and assessments, in order to monitor and trend the progression of aging effects over ti me. Evaluation of this information during preparations for DSC retrie val and offsite shipment provides adequate time for corrective action to be taken, if necessary, in order to ensure that the TC is able to perform its intended functions. Data taken for these inspections are to be monitored by comparison to past site data taken as well as comparison to industry OE, including data gathered by the AMID, as discussed in NEI 14-03, [B-13]. 6) Acceptance Criteria The acceptance criteria for the TC AMP are: The TC AMP includes VT-3 and VT-1 examinations in accordance with Section XI IWA-2213 and IWA-2211, respectively. If corrosion on any

of the TC subcomponents or wear of the inner liner thickness are detected, the finding is entered in SMUD's Corrective Action Program Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-24 to determine, based on engineering ev aluation, the extent and impact of the corrosion on the ability of the TC to perform its intended function. 7) Corrective Actions SMUD QA procedures, review and approval processes, and administrative controls are implemented according to the requirements of the Rancho Seco Quality Manual, [B-2]. SMUD's Corrective Action Program ensures that conditions adverse to quality are promptly identified and corrected, including root cause determinati ons and prevention of recurrence. Deficiencies are either corrected, or are evaluated as acceptable for continued service through engineering analysis, which provides reasonable assurance that the intended function is maintained consistent with current licensing basis conditions. Evaluations performed to assess

conditions associated with aging need to follow the same methodology

used in the licensing and design basis calculations for SMUD as much as practical to ensure intended functions are maintained throughout the PEO. 8) Confirmation Process Conditions adverse to quality noted during the inspection and monitoring activities are entered into SMUD's Co rrective Action Program. Procedural controls are in place to ensure the responses to corrective action assignments are reviewed and to verify the response adequacy. Condition reports are also reviewed for trending purposes. A tollgate will be established to assess effectiveness of corrective actions and update the

AMP as necessary on a periodic basis. 9) Administrative Controls Administrative controls in accordance with SMUD's QA procedures and

corrective action program provide a formal review and approval process. Administrative controls are based on and implemented in accordance with the requirements of a 10 CFR Part 72, Subpart G quality program and will continue for the PEO. The Rancho Seco Quality Manual, [B-2] meets this

requirement. 10) Operating Experience Operating Experience for the TC is as evaluated in the AMR. The OE consisting of Industry OE, TN-spe cific OE and SMUD-specific OE supports a conclusion that no other actions will be necessary to adequately detect aging effects other than those prescribed above.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-25 B.6 Basemat Aging Management Program The ISFSI basemat is a reinforced conc rete structure designed to support the HSMs. Settlement or deflection of the basemat beyond design limits could affect the ability to retrieve the DSCs containing the spent nuclear fuel or GTCC waste; therefore, it is within the scope of the AMP in accordance with NUREG-1927, [B-11]. The basemat is evaluated to support the following intended function: Provides support for DSC retrievability B.6.1 Materials The basemat is constructed of the following materials: Reinforced concrete Carbon steel (embedded rebar)

B.6.2 Environments The basemat is exposed to the following environments: Sheltered Outdoors Embedded Below-grade B.6.3 Aging Effects Requiring Management The following aging effects associated with the basemat require management: Cracking and loss of material (s palling, scaling) due to corrosion of embedded steel for reinforced concrete. Cracking due to expansion from r eaction with aggregates for reinforced concrete. Change in material properties - in crease in porosity and permeability due to aggressive chemical attack and l eaching for reinforced concrete Cracking due to increased stress levels from settlement for reinforced concrete. Loss of material due to general, pitti ng, and crevice corrosion for carbon steel components. Loss of material due to delayed ettri ngite formation or aggr essive chemical attack.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-26 B.6.4 Program Description The objective of the program is to manage the aging effects on the basemat during the PEO. This is accomplished by inspection for evidence of cracking due to ettringite formation, aggressive c hemical attack, and ASR for reinforced concrete structures; loss of materi al due to corrosion of embedded steel; increase in porosity and pe rmeability; and loss of strength due to aggressive chemical attack and leaching of calcium hydroxide and carbonation. Section 3.5.1.3 of the MAPS Report, [B-12] indicates that reduction of concrete strength due to ASR can be mitigated by minimizing moisture from a water source and by keeping wet-dry cycles to a minimum (e.g. providing good drainage from around the basemat). B.6.5 Evaluation and Technical Basis 1) Scope of Program The scope of the ISFSI Basemat AMP in cludes visual inspection of the accessible above-grade portions of t he basemat within the HSM array and the basemat extending ar ound the perimeter of the HSM that is exposed to the outdoor environment.

The program consists of periodic vi sual inspections to manage the aging effects on the above-grade portions of the basemat. 2) Preventive Actions The program is a conditionmonitoring program that does not include preventive actions. 3) Parameters Monitored This AMP describes periodic visual monitoring, which is performed to determine the surface condition of the ISFSI basemat. The surface condition is a leading indicator for the overall integrity of the basemat. For the ISFSI basemat surface, paramet ers monitored include: (1) cracking and loss of material (spalling and scaling) due to corrosion of embedded steel, ettringite formation or aggressive chemical attack; (2) cracking due to expansion from reaction with aggr egates from ASR; (3) increase in porosity and permeability due to leaching of calcium hydroxide and carbonation or aggressive chemical a ttack; and (4) reduction of concrete anchorage capacity due to local concrete degradation.

Changes in site conditions (e.g., water table, soil consolidation, construction) may cause settlement of the ISFSI pad. Therefore, cracking and distortion due to settlement is also a monitored parameter.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-27 4) Detection of Aging Effects The above-grade portion of the concrete basemat is monitored using periodic visual inspection by a qualifie d inspector to ensure that aging degradation will be dete cted and quantified befor e loss of intended functions. These visual inspections check for irregularities such as cracking, loss of material on the conc rete surface and effects from change in material properties (due to leac hing). As appropriate, direct visual inspections utilizing ACI 349.3R Section 3.5.1, [B-8] are conducted for

basemat concrete in the outdoor env ironment allowing for detection of aging effects and mechanisms from Section B.6.5(3), above. Performance of the baseline AMP visual inspection will be no later than two years after

PEO commencement, with follow-on ins pections at a frequency of 10+ 2-years. The inspection interval of 10 years is consistent with ASME, B&PV Code,Section XI, [B-4] Subarticle IWA-2430 optional inspection program B (Paragraph IWA-2432). If preceding inspection acceptance criteria have

been exceeded or the trending from previ ous inspections is indeterminate, the interval between inspections is decreased to 5 +/- 1 year. 5) Monitoring and Trending The inspections and monitoring activities in this AMP are performed periodically in order to identify areas of degradation. Conditions adverse to quality noted during the inspection and monitoring activities, such as non-conformances, failures, malfunctions, deficiencies, and deviations are

entered into the SMUD corrective ac tion program. Visual inspections appropriately consider cumulative OE from previous inspections and assessments, in order to monito r and trend the progression of aging effects and mechanisms over time. Data taken for these inspections are to be monitored by comparison to past site data taken as well as comparison

to industry OE, including data gathered by the AMID as discussed in NEI 14-03, [B-13]. 6) Acceptance Criteria Observed degradation can be determined to be inactive (i.e. no longer

degrading) using criteria from ACI 349.

3R, [B-8]. These criteria are termed

second-tier for structures possessing concrete cover in excess of the minimum requirements of ACI 349.

Inactive degradation can be assessed by comparison of current observed conditions with deterioration noted from prior inspections. If there is a high potential for progressive degradation to occur at its present or at an accelerated rate, the disposition should consider more fr equent evaluations of the specific structure or initiation of repair planning.

The following findings from a visual in spection are considered acceptable without requiring any further evaluation:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-28 Absence of leaching and chemical attack, including microbiological chemical attack Absence of signs of corrosion in the steel reinforcement Absence of drummy areas (poorly consolidated concrete, air void with paste deficiencies per ACI 201.1R, [B-6]) Popouts and voids less than 50 mm (2 in.) in diameter or equivalent surface area Scaling less than 30 mm (1-1/8 in.) in depth Spalling less than 20 mm (3/4 in.)

in depth and 200 mm (8 in.) in any dimension Absence of corrosion staining of undefined source on concrete surfaces Passive cracks less than 1 mm (0.04 in.) in maximum width ("passive cracks" are defined as those having an absence of recent growth and absence of other degradation mechanisms at the crack) Passive settlements or deflections within the original design limits 7) Corrective Actions Sacramento Municipal Utility District QA procedures, review and approval processes, and administrative controls are implemented according to the requirements of the Rancho Seco Quality Manual, [B-2]. SMUD's Corrective Action Program ensures that conditions adverse to quality are promptly identified and corrected, including root cause determinations and

prevention of recurrence. Deficienci es are either corrected, or are evaluated as acceptable for cont inued service through engineering analysis, which provides reasonable assu rance that the intended function is maintained consistent with cu rrent licensing basis conditions.

Evaluations performed to assess conditions associated with aging should utilize the same methodology used in the licensing and design basis calculations for SMUD as much as practical to ensure intended functions are maintained throughout the PEO. Extent of condition investigation may trigger additional inspections via a di fferent method, in creased inspection frequency or expanded inspec tion sample size.

Repair, restoration or corrective action of an unacceptable condition should be performed consistent with ACI-224.4R, [B-7] and article IWA-4000 of the ASME B&PV Code,Section XI, [B-4]. 8) Confirmation Process Conditions adverse to quality noted during the inspection and monitoring activities are entered into SMUD's Co rrective Action Program. Procedural controls are in place to ensure the responses to corrective action assignments are reviewed and to verify the response a dequacy. Condition reports are also reviewed for trending purposes. A tollgate will be established to assess effectiveness of corrective actions and update the

AMP as necessary on a periodic basis.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-29 9) Administrative Controls Administrative controls in accordance with SMUD's QA procedures and corrective action program provide a formal review and approval process.

Administrative controls are based on and implemented in accordance with the requirements of a 10 CFR Part 72, Subpart G quality program and will continue for the PEO. The Rancho Seco Quality Manual, [B-2] meets this

requirement. 10) Operating Experience Operating Experience for the ISFSI bas emat (pad) is as evaluated in the AMR. The OE consisting of Industry OE, TN-specific OE and

SMUD-specific OE supports a conclu sion that no other actions will be necessary to adequately detect and manage aging effects other than those prescribed above. Per Rancho Seco ISFSI SAR , Volume I, [B-1] Section 2.4.6, it is indicated that there may be groundw ater present underlying the site approximately 150 feet below the original ground su rface. The water table has receded over recent years and is expected to recede further due to the grape vineyards adjacent to the site. The IS FSI pad is only 2 feet thick, and per Section 3.4.2.2 of Volume I of the Rancho Seco ISFSI SAR, it is stated that soil liquefaction generally occurs in areas where groundwater is not deeper than 50 ft below grade. As a result, it is concluded that soil liquefaction at the SMUD ISFSI site is highly unlikely.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-30 B.7 Conclusion The AMPs described in Sections B.

3 through B.6 above provide reasonable assurance that potentially detrimental aging effects can be adequately managed to the extent that the intended functions of SSCs are maintained consistent with the Rancho Seco ISFSI licensing basis for the PEO.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-31 B.8 References B-1 Rancho Seco Independent Spent Fuel Stor age Installation Final Safety Analysis Report Rev. 6, dated August 2016 (Docket 72-11). B-2 Rancho Seco Quality Manual (latest revision). B-3 ASME B&PV Code,Section III, Divis ion 1, Subsections NB, NF, NG and Appendix I, 1992 Editi on through 1993 Addenda. B-4 ASME B&PV Code,Section XI, "Rules fo r Inservice Inspection of Nuclear Power Plants and Fuel Processing Plants," 2013 edition. B-5 EPRI Report 3002008193, March 2017, "Aging Management Guidance to Address Potential Chloride-Induced Stress Corrosion Cracking of Welded Stainless Steel Canisters." B-6 ACI-201.1R, "Guide for Conducting a Visual Inspection of Concrete in Service,"

2008. B-7 ACI-224.4R, "Guide to Design Deta iling to Mitigate Cracking," 2013. B-8 ACI-349.3R, "Evaluation of Existing Nuclear Safety Related Concrete Structures," 2002. B-9 ACI-318, "Building Code Requirements for Reinforced Concrete," 1983, 1995. B-10 ANSI/ASCE 11-99, "Guideline for Struct ural Condition Assessment of Existing Buildings." B-11 NUREG-1927 Rev. 1, "Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry St orage of Spent Nuclear Fuel," June 2016. B-12 NUREG-2214 Rev. 0, "Managing Aging Process in Storage (MAPS) Report" (draft report for comment, October 2017). B-13 NEI 14-03, "Format, Content and Implem entation Guidance for Dry Cask Storage Operations-Based Aging M anagement" Revision 2, 2016.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-32 Table B DSC AMP Inspections (2 Sheets) Subcomponents Number Inspected EnvironmentInspection Type Frequency Trending Acceptance Criteria Corrective Action DSC Shell External Surfaces (normally non-accessible areas) portions of the outer top cover plate, closure welds and HAZ; portions of the DSC shell bottom surface DSC surfaces, welds and HAZ, crevice locations near DSC

support rails, inspected for discontinuities and imperfections; localized corrosion (e.g. general, pitting

and crevice corrosion); cracking and stains caused by leaking rainwater;

appearance and

location of

atmospheric deposits on DSC surfaces are

recorded; no

additional action for rainwater stains or discoloration unless corrosion is exhibited outer bottom cover plate, grapple ring assembly, closure welds and HAZ 1 Sheltered Remote Visual Baseline no later than 2

years after PEO begins; 10 +/- 2 yrs thereafter.

If "major" corrosion is

identified, Increase frequency to

5 yrs +/- 1 yr Data taken

from the inspections

are to be monitored by comparison

to past site

data taken as well as comparison

to industry OE. Visual Exams: The presence of a major corrosion indication anywhere on the DSC, or a minor corrosion indication within 2" of a weld, will receive a supplemental surface or volumetric examination. A

minor corrosion indication more than 2" from a weld will receive a supplemental VT-1 exam. Augmented Exams: absence of flaws, or flaw is a round indication, or does

not have corrosion

products present, or does not have crack-like morphology. Flaw Evaluation: Determine when 75% through-wall is reached. Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should use the same methodology used in licensing and design basis as much as practical. Identification of

major corrosion requires an expansion of the sample. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-33 Table B DSC AMP Inspections (2 Sheets) Subcomponents Number Inspected EnvironmentInspection Type Frequency Trending Acceptance Criteria Corrective Action DSC Shell (inaccessible areas) upper surface of DSC shell where atmospheric particulate may settle majority of the outer top cover plate, welds and HAZ DSC shell crevice locations where shell rests on support rails As required by

inspection findings Sheltered In accordance with Corrective Actions AMP Section B.3.5(7) In accordance

with Corrective Actions AMP Section B.3.5(7).

In accordance

with Corrective Actions AMP Section B.3.5(7). Via the SMUD corrective

action program to ensure the aging effect is adequately managed and that the intended function is maintained during the PEO. Further evaluation and disposition per SMUD

corrective action program (See AMP Section B.3.5(7), including more frequent inspections.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-34 Table B HSM AMP Inspections (4 Sheets) Subcomponents Number Inspected Environment Inspection Type Frequency Trending Acceptance Criteria Corrective Action HSM Concrete - External front, back, and side walls & rebar roof exterior HSM access door 1 Outdoors/ Embedded Direct Visual (accessible

areas) Baseline no later

than 2 years after PEO begins; 10

+/- 2 yrs thereafter.

Increase frequency to 5 yrs

+/- 1 yr if

acceptance criteria exceeded.

Data taken for

these inspections

are to be monitored by comparison to

past site data taken as well as comparison

to industry OE, including data

gathered by

the AMID, as

discussed in NEI 14-03 Cracking, spalling, scaling, loss of material

and other anomalies do not exceed ACI-349.3R. The following anomalies are considered acceptable: absence of leaching and chemical attack (including microbiological chemical attack) absence of signs of corrosion of steel

reinforcement absence of Drummy areas (poorly consolidated concrete, air voids with paste deficiencies per ACI-

201.1R) popouts and voids less than 2" in dia or equal surface area scaling less than 1-1/8" in depth spalling less than 3/4" in depth and less than 8" for any dimension absence of corrosion staining of undefined source on concrete passive cracks less than 0.04" in maximum

width Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should

use the same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-35 Table B HSM AMP Inspections (4 Sheets) Subcomponents Number Inspected Environment Inspection Type Frequency Trending Acceptance Criteria Corrective Action HSM Concrete - Internal visible portions of front, back, and side walls portions of the HSM concrete floor (base) 1 Sheltered/ Embedded Remote Visual (normally non-accessible) Baseline no later

than 2 years after PEO begins; 10

+/- 2 yrs thereafter.

Increase frequency to 5 yrs

+/- 1 yr if

acceptance criteria exceeded.

Data taken for

these inspections

are to be monitored by comparison to

past site data taken as well as comparison

to industry OE, including data

gathered by

the AMID, as

discussed in NEI 14-03.

Cracking, spalling, scaling, loss of material

and other anomalies do not exceed ACI-349.3R. The following anomalies are considered

acceptable: absence of leaching and chemical attack (including microbiological chemical attack) absence of signs of corrosion of steel

reinforcement absence of Drummy areas (poorly consolidated concrete, air voids with paste deficiencies per ACI-

201.1R) popouts and voids less than 2" in dia or equal surface area scaling less than 1-1/8" in depth spalling less than 3/4" in depth and less than 8" for any dimension absence of corrosion staining of undefined source on concrete passive cracks less than 0.04" in maximum width Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should

use the same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-36 Table B HSM AMP Inspections (4 Sheets) Subcomponents Number Inspected Environment Inspection Type Frequency Trending Acceptance Criteria Corrective Action HSM Concrete & Steel Internal (inaccessible areas) internal surface of the HSM roof due to the

upper heat shield heat shields at internal surface of the roof and side walls As required by

inspection findings Sheltered/

Embedded In accordance with Corrective Actions AMP Section B.4.5(7) In accordance with Corrective

Actions AMP

Section B.4.5(7). In accordance with Corrective

Actions AMP

Section 5 B.4.5(7). Via the SMUD corrective

action program to ensure the aging effect is adequately managed and that the HSMs intended function is maintained

during the PEO. Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should

use the same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size. HSM Steel - External HSM access door attachment hardware 1 Outdoors/Embedd ed Direct Visual (accessible

areas) Baseline no later

than 2 years after PEO begins; 10

+/- 2 yrs

thereafter.

Increase frequency to 5 yrs

+/- 1 yr if

acceptance criteria exceeded.

Data taken for

these inspections

are to be

monitored by

comparison to

past site data taken as well as comparison

to industry OE, including data gathered by the AMID, as

discussed in NEI 14-03. VT-3: ASME Section XI, Subarticle IWF-3400 and any indications of the following are evaluated: corrosion and material loss crevice, pitting, and galvanic corrosion corrosion stains on adjacent components and structures surface cracks stains caused by leaking rainwater if evidence of corrosion exhibited loose bolts and nuts and cracked bolts are

not acceptable unless

approved by the Engineering evaluation.Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program.

Evaluations should

use the same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-37 Table B HSM AMP Inspections (4 Sheets) Subcomponents Number Inspected Environment Inspection Type Frequency Trending Acceptance Criteria Corrective Action HSM Steel - Internal DSC support structure including Nitronic 60 rail plates and welds attachment hardware 1 Sheltered/ Embedded Remote Visual (normally non-accessible) Baseline no later

than 2 years after PEO begins; 10

+/- 2 yrs thereafter.

Increase frequency to 5 yrs

+/- 1 yr if

acceptance criteria exceeded.

Data taken for

these inspections

are to be monitored by comparison to

past site data taken as well as comparison

to industry OE, including data

gathered by

the AMID, as

discussed in NEI 14-03. VT-3: ASME Section XI, Subarticle IWF-3400 and any indications of the following are evaluated: corrosion and material loss crevice, pitting, and galvanic corrosion corrosion stains on adjacent components and structures surface cracks Stains caused by leaking rainwater if evidence of corrosion exhibited loose bolts and nuts and cracked bolts are not acceptable unless

approved by the engineering evaluation.Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should

use the same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-38 Table B Transfer Cask AMP Inspections Subcomponents Number Inspected EnvironmentInspection Type FrequencyTrending Acceptance Criteria Corrective Action MP187 External Surfaces Cask lid surfaces bearing surfaces of upper and lower trunnions attachment fasteners exterior cask surfaces 1 Sheltered Direct Visual of external surfaces accessible areas Prior to use Data taken from the inspections

are to be

monitored by

comparison to

past site data taken as well

as comparison to industry OE. VT-3:ASME Section XI, IWA-2213 VT-1 (if req'd): ASME Section XI, IWA-2211 with No indications of corrosion or wear on TC external surfaces Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program.

Evaluations should use the

same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size. MP187 Internal Surfaces Cask cavity inner liner Nitronic 60 rails 1 Sheltered Direct Visual, Remote Visual or both of accessible

areas Prior to use Data taken from the inspections

are to be

monitored by

comparison to past site data taken as well

as comparison to industry OE. VT-3:ASME Section XI, IWA-2213 VT-1 (if req'd): ASME Section XI, IWA-2211 with No indications of corrosion or cracking on TC internal surfaces No wear of inner liner thickness Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program.

Evaluations should use the

same methodology used in licensing and design basis as much as practical. Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix B - Aging Management Programs Page B-39 Table B Basemat AMP Inspections Subcomponents Number Inspected EnvironmentInspection Type Frequency Trending Acceptance Criteria Corrective Action Basemat Concrete 1 Outdoors/

Embedded/ Sheltered/

Below-grade Direct Visual of the accessible above-

grade surfaces.

Baseline no

later than 2

years after PEO begins; 10 +/- 2 yrs thereafter.

If acceptance

criteria is

exceeded, increase frequency to 5

yrs +/- 1 yr.

Data taken from the inspections

are to be

monitored by comparison to past site data taken as well as

comparison to industry OE.

Cracking, spalling, scaling, loss of material and other anomalies do not exceed ACI-349.3R and ACI-201.1R. The following anomalies are considered

acceptable: absence of leaching and chemical attack (including microbiological attack) absence of signs of corrosion of steel reinforcement absence of Drummy areas (poorly consolidated concrete, air voids with paste deficiencies per ACI-201.1R) popouts and voids less than 2" in dia or equal

surface area scaling less than 1-1/8" in depth spalling less than 3/4" in depth and less than 8" for any dimension absence of corrosion staining of undefined source on concrete passive cracks less than 0.04" in maximum width passive settlement or deflection within original design limits Conditions adverse to quality are evaluated in accordance with SMUD's Corrective Action Program. Evaluations should use the same methodology used in licensing and design basis as much as practical.

Extent of condition may trigger additional inspections, increased inspection frequency or expanded inspection sample size. Repair, restoration meets ACI-224.4R and ASME Sect.

XI, IWA-4000.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-i APPENDIX C CHANGES TO THE RANCHO SECO ISFSI FSAR FINAL SAFETY ANALYSIS REPORT CONTENTS C.1Introduction

..................................................................................................... C-1C.2Proposed New Rancho Seco IS FSI FSAR Sections .................................... C-2C.2.1FSAR Section 9.8 - Ag ing Management ............................................... C-2C.2.2FSAR Section 9.8.1 - Scoping Evaluation Methodology ....................... C-2C.2.3FSAR Section 9.8.2 - Results of Scoping Evaluation ............................ C-4C.2.4FSAR Section 9.8.3 - Agin g Management Review ................................ C-5C.2.4.1FSAR Section 9.8.3.1 - Re sults of Aging Management Review - DSC ........................................................................... C-7C.2.4.2FSAR Section 9.8.3.2 - Re sults of Aging Management Review - HSM .......................................................................... C-8C.2.4.3FSAR Section 9.8.3.3 - Re sults of Aging Management Review - Concrete Basemat .................................................... C-9C.2.4.4FSAR Section 9.8.3.4 - Re sults of Aging Management Review - Trans fer Cask ......................................................... C-10C.2.4.5FSAR Section 9.8.3.5 - Re sults of Aging Management Review - Spent Fuel Assemblies ........................................... C-11C.2.5FSAR Section 9.8.4 - Summary of Time-Limited Aging Analyses .............................................................................................. C-12C.2.5.1FSAR Section 9.8.4.1 - DSC Time-Limited Aging Analyses .. C-12C.2.5.2FSAR Section 9.8.4.2 - HSM Time-Limited Aging Analyses .. C-13C.2.5.3FSAR Section 9.8.4.3 - Trans fer Cask Time-Limited Aging Analyses ................................................................................. C-13C.2.5.4FSAR Section 9.8.4.4 - ISFSI Basemat Time-Limited Aging Anal yses .......................................................................

C-13C.2.6FSAR Section 9.8.5 - Summary of Aging Management Programs ............................................................................................. C-14C.2.6.1FSAR Section 9.8.5.1 - DSC Aging Management Program ... C-14C.2.6.2FSAR Section 9.8.5.2 - HSM Ag ing Management Program .. C-14C.2.6.3FSAR Section 9.8.5.3 - TC Aging Management Program

...... C-14C.2.6.4FSAR Section 9.8.5.4 - ISFSI Basemat Aging Management Program ............................................................ C-15 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-ii C.2.7FSAR Section 9.8.6 -Aging Management Tollgates ............................ C-15C.3Proposed Revised Rancho Seco ISFSI FSAR Sections ............................ C-17C.3.1FSAR Volume I, Section 1.1 - Introduction

.......................................... C-17C.3.2FSAR Volume I, Section 1.2 -General Description of the Installation

............................................................................................ C-17C.3.3FSAR Volume I, Section 3.3.4.1.1 -Fuel-Only (FO) DSC Design Features .................................................................................. C-18C.3.4FSAR Volume I, Section 8.1.

1.9 -Thermal Cycling of the Cask.....................................................................................................

C-18C.4References .................................................................................................... C-20 LIST OF TABLES Table C-1 (New Rancho Seco ISFSI FSAR T able 9.8-1) Scopi ng Evaluation of Rancho Seco IS FSI SSCs ................................................................... C-21Table C-2 (New Rancho Seco ISFSI FSAR Table 9.8-2) Scoping Evaluation Results for Spent Fuel Assemblies ...................................................... C-22Table C-3 (New Rancho Seco ISFSI FSAR Table 9.8-3) Rancho Seco FO-DSC Intended Functions and AMR Results ......................................... C-23Table C-4 (New Rancho Seco ISFSI FSAR Table 9.8-4) Rancho Seco FC-DSC Intended Functions and AMR Results ......................................... C-24Table C-5 (New Rancho Seco ISFSI FSAR Table 9.8-5) Rancho Seco FF-DSC Intended Functions and AMR Results ......................................... C-25Table C-6 (New Rancho Seco ISFSI FSAR Table 9.8-6) Rancho Seco GTCC DSC Intended Functions and AMR Results ......................................... C-26Table C-7 (New Rancho Seco ISFSI FSAR Table 9.8-7) Rancho Seco HSM Intended Functions and AMR Result s.................................................. C-27Table C-8 (New Rancho Seco ISFSI FSAR Table 9.8-8) Rancho Seco TC Intended Functions and AMR Result s.................................................. C-28Table C-9 (New Rancho Seco ISFSI FSAR Table 9.8-9) DSC External Surfaces Aging Mana gement Program ................................................ C-29Table C-10 (New Rancho Seco ISFSI FSAR Table 9.8-10) HSM Aging Management Program for External and Internal Surfaces ................... C-30Table C-11 (New Rancho Seco ISFSI FSAR Table 9.8-11) TC Aging Management Program ......................................................................... C-31Table C-12 (New Rancho Seco ISFSI FSAR Table 9.8-12) ISFSI Basemat Aging Management Program ............................................................... C-32 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-iii Table C-13 (New Rancho Seco ISFSI FSAR T able 9.8-13) Rancho Seco ISFSI Tollgates .............................................................................................. C-33 Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-1 C.1 Introduction The proposed supplement to the R ancho Seco Independent Spent Fuel Storage Installation (ISFSI) Final Safe ty Analysis Report (FSAR) to support the specific Rancho Seco ISFSI license renewal application is discussed and described in this appendix. These proposed ISFSI FSAR changes summarize

the aging management activities and pr ograms planned for the period of extended operation (PEO) for the Rancho Seco ISFSI. Section C.2 of this appendix provides a proposed new section to address aging management during the PEO for t he Rancho Seco ISFSI FSAR to be added in existing Volume I, Chapter 9, "C onduct of Operations."

Section C.3 of this appendix identifies changes to t he existing ISFSI FSAR that are necessary to reflect this PEO.

Proposed new FSAR Section 9.8, "Aging Management," contains subsections that summarize the following aging management elements: Scoping evaluation and results Aging management review (AMR) and results Time-limited aging analyses (TLAAs) Aging management programs (AMPs) Tollgate assessments For efficiency and in order to avoid r epetition, many tables proposed for inclusion in the Rancho Seco ISFSI FSAR that reside elsewhere in this license renewal application (LRA) are cross-refe renced in the new Section C.2 Aging Management subsections below. Upon issuance of the renewed licens e (SNM-2510) for the Rancho Seco ISFSI, Sacramento Municipal Utility District (SMUD) will provide an update to the Rancho Seco ISFSI FSAR incorporating the provisions in this supplement, with any modifications resulting from U.S. Nuclear Regulatory Commission (NRC) review, in accordance with the provisions of 10 CFR 72.70(c).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-2 C.2 Proposed New Rancho Seco ISFSI FSAR Sections The following aging management information to be included in new Rancho Seco ISFSI FSAR, Section 9.8, is based on Chapters 2 and 3, and

Appendices A and B of this LRA, and any applicable reference documents.

Further details can be found in those sections/appendices and reference documents. References to chapter and section numbers in the proposed FSAR sections below refer to current FSAR chapters and sections unless otherwise noted. Specific FSAR subs ection numbers may differ from those presented here. References herein are in the form "[C-x]." These will be translated to the form "[9.8-x]" when the FSAR is updated. C.2.1 FSAR Section 9.

8 - Aging Management Aging management activities (AMAs) have been undertaken in order to identify the structures, systems, and components (SSCs) and associated subcomponents of the Rancho Seco ISFS I that are within the scope of the Rancho Seco Independent Spent Fuel Stor age Installation Materials License SNM-2510 Amendment 4, November 2017, [C-1] renewal. The methodology used to perform this scoping evaluation is based on the guidance contained in NUREG-1927 Standard Review Plan for R enewal of Specific Licenses and Certificates of Compliance for Dry St orage of Spent Nuclear Fuel, [C-2]. The scoping evaluation identifies the ISFSI SSCs that are within the scope of renewal, and therefore require an AMR.

The AMR identifies the materials and environment for the SSCs and associat ed subcomponents determined to be within the renewal scope. These SSCs with in the scope of renewal are further subjected to evaluation for potential degr adation due to aging effects. After potential aging effects are identified, it is determined for each in-scope SSC whether they can be addressed by a TLAA, or if they will require an AMP. Additional details of the AMR can be found in Chapter 3. Listed in the subsections below are a description of the scoping evaluation methodology and the results of the scoping evaluation, the results of the AMR, TLAAs and the AMPs selected to manage the effects of aging over the PEO. C.2.2 FSAR Section 9.8.1 - Scoping Evaluation Methodology The scoping evaluation is performed bas ed on the two-step process described in Section 2.4.2 of NUREG-1927, [C-2].

SSCs are considered to be within the scope of renewal if they satisfy ei ther of the follo wing two criteria:

Criterion 1: The SSC is classified as important-to-safety (ITS) as it is relied on to perform one of t he following functions: A. Maintain the conditions required by the regulations, specific license or certificate of compliance (CoC) to store spent fuel safely. B. Prevent damage to the spent f uel during handli ng and storage.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-3 C. Provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved without undue risk to the health and safety of the public.

These SSCs ensure that important safety functions are met for (1) criticality, (2) shielding, (3) confinement, (4) heat trans fer, (5) structural integrity, and (6) spent fuel canister retrievability.

Criterion 2: The SSC is classified as not important-to-safety (NITS), but according to the licensing basis, its failure could prevent fulfillment of a function that is ITS, or its failure as a support SSC could prevent fulfillment of a function that is ITS.

The second step of the scoping evaluatio n includes a more detailed review of the SSCs that are determined to be within the scope of the re newal to identify and describe the subcomponents and subc omponent parts that support the intended function or functions of the SSCs. The intended functions of the SSC subcomponents (and the corresponding abb reviations used to denote this function) include: Providing criticality contro l of the spent fuel (CC), Providing heat transfer (HT), Directly or indirectly mainta ining a pressure boundary (PB), Providing radiation shielding (SH), Providing structural support, functiona l support, or both, to SSCs that are ITS (SS) and Providing retrieval of spent fuel canister from the storage cask (RE).

The scoping of the spent fuel assemb lies (SFAs) authorized for storage at the Rancho Seco ISFSI has been addressed as specified in Section 2.4.2.1 of NUREG-1927, [C-2].

The HSM, DSC, and transfer cask (TC) drawings list the associated subcomponents of the major SSCs, their quality categories and their materials of construction. The drawings and other licensing basis documents were reviewed to determine the SSCs and associated subcomponents that meet either Scoping Criterio n 1 or 2. Based on this review, those SSCs and subcomponents that perfo rm or support any of t he identified intended functions are determined to require an AMR. Those SSCs and associated subcomponents that do not perform or support one or mo re of these intended safety functions are excluded from further evaluation.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-4 C.2.3 FSAR Section 9.8.2 - Results of Scoping Evaluation Table C-1 (new ISFSI FSAR Table 9.8-1) summarizes the results of the scoping evaluation, listing the SSCs that are identified to be within the scope of renewal and the criterion upon which this determination is based. The SSCs determined to be within the scope of Rancho Seco ISFSI license renewal are

the DSC (containing SFAs and GTCC wa ste), HSM, TC and ISFSI basemat.

Detailed scoping evaluation results for each SSC and associated

subcomponents have been generated. Thes e results are included in AMR Table C-3 to Table C-8 (new ISFSI FSAR Tables 9.8-3 to 9.8-8).

At the Rancho Seco ISFSI, all fuel is currently in dry storage and no more fuel or new canisters are to be loaded. Henc e, the TC and the auxiliary equipment will not be used for any loading operations. The only remaining TC safety

function during the PEO is retrieval of t he DSCs from the HSMs directly into a transport package for offsite shipment of the DSC.

The SFAs, which are stored in an inert and sealed environment and are supported inside the FO/FC/FF DSC baske t assembly, are also determined to be within the scope of renewal. The in-scope subcomponents of the SFAs and their intended functions are identified in Table C-2 (new ISFSI FSAR Table 9.8-2). Note: The external design characteristi cs of the greater than class C (GTCC) waste containing DSC are identical to the fuel-containing DSCs (FO/FC/FF DSCs). Hence, the term "DSC" has been used to address both DSC types in this application, unless a distinction is necessary to address a specific

characteristic of the GTCC DSC.

The storage pad (also referred to as the basemat) is a NITS structure. Since settlement of the basemat may affect retrievability of the DSC, the basemat is included within the scope of renewal (m onitoring for basemat settlement). The accessible above-grade and inaccessibl e below-grade areas of the storage pad are within the scope of renewal.

Structures, systems, and co mponents that are not in the scope of renewal include the fuel transfer and auxiliary equipment. These components are classified as NITS and do not meet scopi ng Criterion 2. Also not within the scope are those NITS subcomponents of the DSC, HSM and TC that do not meet Criterion 2 because their failure does not prevent fu lfillment of an ITS function.

The approach or apron slab is a NITS re inforced concrete structure, designed and constructed to Rancho Seco specific conditions. The slab provides access to the HSM but does not support the HS M. It does not provide a safety function, and its failure would not prevent fulfillment of a safety function of the HSM loaded with a DSC Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-5 C.2.4 FSAR Section 9.8.3

- Aging Management Review The purpose of the AMR is to asse ss the proposed aging management activities of SSCs determined to be withi n the scope of renewal for the Rancho Seco ISFSI. The AMR addresses aging mechanisms and effects that could adversely affect the ability of the SSC s (and associated subcomponents) from performing their intended f unctions during the PEO.

The AMR process involves the following major steps: Identification of materials and environments; Identification of aging effects and mechanisms requiring management; Determination of the activities required to manage the effects and mechanisms of aging. This involves t he identification of TLAAs or AMPs for managing the effects of aging; Evaluation of spent fuel (canister) retrievability during the period of extended operation.

For each SSC, the material of construc tion and the environment to which each SSC is exposed are determined.

The component environments are determined based on the location of the component within the storage system.

Once the component material/environm ent combinations are determined, potential aging effects requiring m anagement are determined. Engineering literature, related resear ch and industry informati on, and existing operating experience (OE) are reviewed to identify expected aging degradation mechanisms for different materials and environments. After the expected aging effects are identified, it is determined whether the effects can be addressed by analysis (TLAA), or will require an AMP.

The environments to which SSCs and associated subcomponents are exposed play a critical role in the det ermination of potential aging effects and mechanisms. The environments to which the Rancho Seco SSCs are exposed

are affected by the characteristics of the ISFSI site environment, as well as by the component location within the st orage system. There are five basic environments that apply for t he Rancho Seco ISFSI SSCs. Inert Gas - Inert envir onment inside the DSC cavity. The spent fuel assemblies (SFAs), the DSC inter nal basket assembly, and the inside surfaces of the DSC shell and inte rior shell assembly subcomponents (e.g., inner top and bottom cover plates and top shield plugs) are exposed to the inert gas (helium) environment inside the shell assembly cavity. These components are exposed to significant neutron and gamma radiation. Refer to DSC cavity helium temperatures and pressures

presented in Volume I, Tables 8-2a and 8-2b, for normal and off-normal conditions. Both temperature and pre ssure are expected to continuously decrease over the period of extended operation. Sheltered - Protected environment, su ch as HSM interior or TC stored indoors in an uncontrolled environmen

t. A sheltered environment is a Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-6 protected environment with no direct exposure to sun, wind, or precipitation. A shelter ed environment may contai n moisture and salts or other contaminants from the external ambient air. The temperature inside the HSM depends on the ambient air tem perature and the heat load of the loaded canister. Components exposed to the HSM sheltered environment (interior side of the HSM walls, HSM steel, and DSC external shell assembly components) are exposed to neutron and gamma radiation to a

lesser extent than those of the interior cavity of the DS C. Temperatures and radiation sources are expect ed to decrease over the PEO. Embedded or Encased - This environment applies for materials that are embedded or encased (sealed) inside another material. These include rebar and anchorage embedded in the HSM concrete, DSC bottom shield plug encased between the inner and outer cover plates, NS-3 solid neutron shielding material encased in the TC lids and between the TC

neutron shield jacket and the struct ural shell, and the lead encased between the inner liner and the structur al shell of the TC. Embedded or encased environments are exposed to r adiation. The radiation source is expected to decrease over the period of extended operation. External (Yard and Outdoor) - During st orage, the exterior surfaces of the HSM are exposed to all weather conditions, including insolation, wind, rain, snow, and plant-specific ambient air conditions, including moist atmospheric air, ambient temperatures, and humidity. Underground - At the R ancho Seco ISFSI, the HSMs are installed on a reinforced concrete basemat, which is constructed on compacted, engineered fill. The concrete basemat accessible areas above-grade and inaccessible areas below-grade are within the scope of Rancho Seco ISFSI renewal. The ISFSI basemat t hat is located below grade could be exposed to a groundwater/soil environment.

After the component material/environment combinations are determined, potential aging management effects are determined. Aging effects are the manifestation of aging mechanisms. The AMR process identifies both the aging effects and the associated aging mechanisms that cause them. Each subcomponent that was subjected to AMR was evaluated to determine if the potential aging effects and mechanisms were credible considering the various material/environment combinations.

Supplemental Evaluations For the following aging mechanisms, supplemental evaluations were performed to show that the aging mechanisms did not require aging management:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-7 A. Irradiation Embrittlement This supplemental evaluation assess ed the effect of neutron and gamma radiation on the DSC and HSM structural materials. Although the license renewal period is for 40 years, this ev aluation takes into account the initial 20 years of storage period and an addi tional 80 years of storage period, for a total of 100 years. The ma ximum fluence is calculated as 7.57 E+15 neutrons/cm 2 for the DSC fuel com partment and the total gamma exposure is calculated as 3.58 E+09 rad. The neutron fluence and gamma exposure are below the threshol d levels of concern for the DSC and HSM materials. The results indi cate that there is no credible mechanical degradation occurring in compressive strength and tensile strength of the DSC sh ell, shield plug, and HSM components due to neutron fluence and gamma exposure le vels. Therefore, irradiation embrittlement is not an aging effe ct requiring management for the DSC and HSM components. B. Combustible Gas Generation This supplemental evaluation documents an analysis performed to determine the quantity of combustible gases generated as a result of irradiation of the NS-3 neutron shield material for the MP187 TC during its function as a transfer cask. The com bustible gas generation in the neutron shield material of the transfer cask was calculated based on the design basis radiological fuel loaded in a DSC inside the transfer cask.

Considering that the tota l hydrogen mass originally present in the neutron shield material is approximately 209 kg, the fraction of hydrogen liberated from the neutron shield material over the service period of the cask is

[ ] by weight, which is statistically insignificant. Therefore, generation of combustible gases is not an aging mechanism requiring management for the NS-3 neutron shield material. C.2.4.1 FSAR Section 9.8.3.1 - Resu lts of Aging Management Review - DSC The DSC performs the following intended functions: CC Provides criticality control of spent fuel HT Provides heat transfer PB Directly or indirectly mainta ins a pressure boundary (confinement) RE Provides retrievability of SFAs SH Provides radiation shielding SS Provides structural s upport (structural integrity) The GTCC DSC is designed to store gr eater than Class C waste and, thus, criticality is not an intended function for the GTCC DSC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-8 The Rancho Seco DSCs consist of two main subcomponents: the shell assembly and the internal basket assemb ly. The materials of construction for the DSC subcomponents that are subject to further AMR include stainless steel and carbon steel. The following aging effects and mechanisms are applicable for DSC steel components:

Loss of Material Loss of material due to crev ice corrosion - stainless steel Loss of material due to pitti ng corrosion - stainless steel Loss of material due to galvanic corrosion - Nitronic 60 rail plate and graphite lubricant Cracking Cracking due to stress corrosion cracking - stainless steel Cracking due thermal fatigue - st ainless steel DSC pressure boundary Loss of Criticality Control Loss of criticality control due to boron depletion - Boral Tables C-3, C-4, C-5 and C-6 (new ISFSI FSAR Tables 9.8-3 through 9.8-6) summarize the results of the AM R for the FO, FC, FF and GTCC DSCs, respectively. These tables include for each in-scope subcomponent the

material, intended function, the environment, the associated aging effects requiring management, and the resulti ng aging management activity. C.2.4.2 FSAR Section 9.8.3.2 - Resu lts of Aging Management Review - HSM The evaluation boundary for the HSM includes the entire HSM concrete structure and the steel support struct ure for the DSCs, which perform the following intended functions: HT Provides heat transfer RE Provides retrievability of DSC SH Provides radiation shielding SS Provides structural s upport (structural integrity)

The materials of construction fo r the subcomponents of the HSM are presented in the AMR tables listed in this section, and consist of reinforced concrete, carbon steel, Nitronic 60 stainless steel, plain concrete and stainless steel. The following aging effects and mechanisms for HSM concrete components are applicable:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-9 Loss of Material Aggressive chemical attack, includ ing microbiological chemical attack Corrosion of embedded steel Cracking Corrosion of embedded steel Reactions with aggregates Change in Material Properties Leaching of Ca(OH) 2 Aggressive chemical attack The following aging effects/mechanism s for HSM steel and other metal components are applicable:

Loss of Material Loss of material due to general corrosion - carbon steel Loss of material due to galvanic corrosion - Nitronic 60 DSC support rail plates Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Cracking Stress Corrosion Cracking - welds attaching Nitronic 60 rail plate.

Table C-7 (new ISFSI FSAR Table 9.8-7) summarizes the results of the AMR for the RS HSMs. C.2.4.3 FSAR Section 9.8.3.3 - Results of Aging Management Review - Concrete Basemat The basemat is a NITS reinforced concre te structure designe d to support the HSMs and constructed to plant-specific site conditions.

Long-term settlement of the ISFSI basemat is a credibl e aging mechanism that may affect retrievability of the DSC.

Therefore, the basemat is within scope of renewal for monitoring for pad settlement. There are no other credible failure modes of the basemat that could prevent the HSM safety functions from being fulfilled. The basemat is evaluated in support of the following intended function: Provides HSM structural/functional support.

The material of construction for t he basemat is reinforced concrete.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-10 The following aging effects and mechanisms are applicable for the concrete basemat: Loss of Material Delayed Ettringite Formation (DEF) Aggressive chemical attack, includ ing microbiological chemical attack Corrosion of embedded steel Cracking Reactions with aggregates Settlement Change in Material Properties Leaching of Ca(OH) 2 Aggressive chemical attack, includ ing microbiological chemical attack The portion of the AMR associated with the concrete in Table C-7 (new ISFSI FSAR Table 9.8-7) is also applicable to the concrete basemat. C.2.4.4 FSAR Section 9.8.3.4 - Result s of Aging Management Review - Transfer Cask This section summarizes the resu lts of the AMR for the in-scope subcomponents of the NUHOMS MP187 Transfer Cask (MP187 TC). The evaluation boundary for the TC includes the TC subcomponents, which

perform the following intended functions: HT Provides heat transfer RE Provides retrievability of DSC SH Provides radiation shielding SS Provides structural support (i mpact resistance, lifting, etc.)

The materials of construction for the subcomponents of the TC are presented in the AMR tables listed in this secti on, and consist of stainless steel, carbon steel, Elastomer O-rings, NS-3 neutron shielding, lead gamma shielding, and Nitronic 60 canister rails. Note: All of the Rancho Seco SFAs and GTCC waste have been loaded and placed into the HSMs for interim storage.

The MP187 TC is currently stored in a sheltered environment and the only remaining MP187 TC function is to retrieve the DSCs when they are to be shipped offsite.

The MP187 TC is a cylindrical vesse l with a welded bottom assembly and a bolted top cover plate. The TC is constr ucted from three concentric cylindrical shells to form an inner and outer annulus. The TC is normally stored in a Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-11 sheltered environment between uses and duri ng staging activities prior to each use. The total time exposure of the TC to the spent fuel pool environment (during prior loading operations) and to the external environment (during transfer operations) repres ents a negligible fraction of its total life span, including PEO. Hence, the only environment considered for the TC AMR is the sheltered environment. The following aging effects and mechanisms for steel components are applicable:

Loss of Material Loss of material due to general corrosion - carbon steel Loss of material due to crevice co rrosion - carbon steel and stainless steel Loss of material due to pitting corro sion - carbon steel and stainless steel Loss of material due to galvanic corrosi on - stainless steel rail, inner shell, and bottom end closure.

Cracking Cracking due to thermal fatigue - carbon steel and stainless steel Table C-8 (new ISFSI FSAR Table 9.8-8) summarizes the results of the AMR for the TC. C.2.4.5 FSAR Section 9.8.3.5 - Results of Aging Management Review - Spent Fuel Assemblies The SFA principal function during dry st orage is to maintain proper geometry and position of radioactive material through confinement. Although fuel cladding provides a confinement barrier, no credit is taken in the safety analysis for the fuel cladding as a confinement boundary. The evaluation boundary for the SFA includes the fuel cladding and end plugs, guide tubes, grid assemblies, upper nozzle, and bottom nozzle, which perform the following intended functions: CC Provides criticality control HT Provides heat transfer PB Directly or indirectly mainta ins a pressure boundary (confinement) SS Provides structural s upport (structural integrity)

The materials of construction of the SFA hardware consist of zirconium-based alloys, stainless steel and nickel-based alloys.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-12 The AMR for the SFAs focuses primarily on the fuel rod cladding as it is considered the limiting component of t he fuel assembly hardware because it serves as a barrier to fission prod ucts, provides defense-in-depth, and maintenance of its structural integrity ensures its retr ievability from the DSC.

The environments that affe ct the subcomponent s of each DSC, both externally and internally, are those that are normally (continuously) experienced as

described below: External For SFAs, external environment refers to the internal DSC atmosphere. The storage atmosphere is predominantly hel ium with trace amounts of water vapor and air.

Internal For SFAs, internal environment refers to the fuel rod interior. The fuel rod internal environment is assumed to be a combination of the original helium fill gas (during manufacturing) and fissi on products produced during reactor operation.

The materials inside the DSC, includi ng the SFAs, cannot practically be inspected in-situ due to radiation levels and accessibility (i.e., DSC is seal welded). In preparation for dry storage, the DSC inte rnals are vacuum dried and backfilled with helium to establish an inert gas environment in the DSC cavity. The DSC is leak tested to ensur e that the inert gas environment is maintained so that the SFAs wil l not become subject to age-related degradation mechanisms during the stor age period. A demonstration project provides the basis for the assertion that the SFAs will not degrade to unacceptable levels during the PEO. Therefore, no aging management program or activities are credited during the PEO for the Rancho Seco low burnup SFAs and associated subcomponents. C.2.5 FSAR Section 9.8.4 - Summary of Time-Limited Aging Analyses Time-limited aging analyses are prepared to assess SSCs that have a time-dependent operating life to demonstrate that the existing licensing basis remains valid and that the intended func tions of the SSCs in scope of renewal are maintained during the PEO. Time dependency may entail fatigue life (cycles), change in a mechanical proper ty, such as fracture toughness or strength of materials due to irradiation, or time-limited operation of a subcomponent. C.2.5.1 FSAR Section 9.8.4.1 - DSC Time-Limited Aging Analyses The following are summary descriptions of the TLAAs that were identified and prepared based on the AMR of the DSC.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-13 A. Fatigue Evaluation of the DSCs This TLAA documents the evaluation of the DSC pressure boundary subcomponents for pressure and temper ature fluctuations in accordance with the provisions of NB 3222.4(d) of the ASME B&PV Code,Section III, Division 1, 1992 Edition, with Addenda through 1993, [C-3]. As provided by NB 3222.4(d) of the ASME B&PV Code, fatigue effects need not be specifically evaluated prov ided the six criteria in NB 3222.4(d) are met.

This evaluation is performed consi dering a 60-year se rvice life using maximum bounding initial DSC pre ssures and temperatures (at the beginning of storage). This evaluation s hows that the six criteria of NB 3222.4(d) are met. B. Boron Depletion This TLAA performs an analysis to determine the amount of boron depletion in the FO and FC DSC poi son plates during the PEO. Although the license renewal period is for 40 years, this evaluation takes into account the initial 20 years of stor age period and an additional 80 years of storage period, for a total of 100 years. Over a period of 100 years, the eval uation considers a bounding neutron irradiation rate, and indicates t hat the amount of B-10 depleted is negligible. C.2.5.2 FSAR Section 9.8.4.2 - HSM Time-Limited Aging Analyses No TLAAs are used to manage any expected aging effects of HSM components. C.2.5.3 FSAR Section 9.8.4.3 - Trans fer Cask Time-Limited Aging Analyses The following are summary descriptions of the TLAAs that were identified and prepared based on the AMR of the TC. Fatigue Evaluation of the TC This TLAA documents the thermal fatigue analysis of the TC for pressure and temperature fluctuations in accordance with the provisions of NB 3222.4(d) of the ASME BP&V Code. As provided by NB 3222.4(d), fatigue effects need not be specifically evaluated provided the six criteria in NB 3222.4(d) are met. This evaluation is performed considering a 60-year service life using maximum bounding initial TC pressures and temperat ures (at the beginning of storage).

This evaluation shows that all the six criteria of NB 3222.4(d) are met. C.2.5.4 FSAR Section 9.8.4.4 - ISFSI Basemat Time-Limited Aging Analyses No TLAAs are used to manage any expec ted aging effects of the basemat components.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-14 C.2.6 FSAR Section 9.8.5 - Summa ry of Aging Management Programs Aging management programs are developed for managing the effects of aging. As appropriate, an AMP was created to summarize the activities or procedures implemented to monito r and manage the aging effects. C.2.6.1 FSAR Section 9.8.5.1

- DSC Aging Manage ment Program The DSC External Surfaces AMP is employed to manage the aging effects and mechanisms for the DSC. The scope of the DSC AMP, parameters to be monitored, the criteria fo r selecting a DSC for the AMP, the detection of aging effects and the acceptance criteria ar e described in Table C-9 (new ISFSI FSAR Table 9.8-9). Rancho Seco will implement the first (baseline) DSC inspections under this AMP on the selected DSCs in accordance with the program schedule as descr ibed in the table. C.2.6.2 FSAR Section 9.8.5.2

- HSM Aging Management Program The following program is employed to manage the aging effects and mechanisms for the HSM concrete and steel components: HSM Aging Management Program for External and Internal Surfaces (applicable to HSM, DSC support structures)

The scope of the HSM AMP, parameters to be monito red, the criteria for selecting an HSM for the AMP, th e detection of aging effects and the acceptance criteria are described in Table C-10 (new ISFSI FSAR Table 9.8-10). Rancho Seco will implement the fi rst (baseline) HSM inspections under this AMP on the selected HSM in accordance with the program schedule as described in the table. C.2.6.3 FSAR Section 9.8.5.3

- TC Aging Management Program The TC AMP is employed to manage the aging effects and mechanisms for the TC components. The scope of the TC AMP, param eters to be monitored, the detection of aging effects and the acceptance criteria are described in Table C-11 (new ISFSI FSAR Table 9.8-11). Rancho Seco will perform the inspections and monitoring activities de scribed in this AMP prior to use to identify areas of degradation. Eval uation of this information during preparations for DSC retrieval and transfer provides adequate predictability and allows time for corrective action, if required, in order fo r the TC to perform its intended functions.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-15 C.2.6.4 FSAR Section 9.8.5.4 - ISFS I Basemat Aging Management Program The Rancho Seco ISFSI Basemat AMP is employed to manage the aging effects and mechanisms for the basemat concrete. The scope of the ISFSI basemat AMP, the detection of aging effe cts, and the acceptance criteria are described in Table C-12 (new ISFSI FSAR Table 9.8-12). Rancho Seco will implement the first (baseline) basemat inspections under this AMP in accordance with the program schedule as described in the table. C.2.7 FSAR Section 9.8.6

-Aging Management Tollgates The AMPs listed in Secti on 9.8.5 are subject to modification under 10 CFR 72.48 as new OE accumulates. For these AMPs, Rancho Seco will implement a program that is consistent with t he guidelines of a generic AMP tollgate process described below.

The following definitions are reproduced from NEI 14-03, Format, Content and Implementation Guidance for Dr y Storage Operations-Based Aging Management, [C-4]:

Tollgate: A requirement included in a renewed ISFSI license and associated UFSAR for the licensee to perform and document an assessment of the aggregate impact of aging-related dry cask storage (DCS) OE, research, monitoring, and inspections at specif ic points in time during the renewed operating period.

Tollgate Assessment: A written evaluation, performed by licensees at each tollgate, of the aggregat e impact of aging-related DCS OE, research, monitoring, and inspections on the int ended functions of in-scope DCS SSCs.

Tollgate assessments are in tended to include non-nuclear and international operating information on a best-effort basis. Corrective or mitigative actions arising from tollgate assessments are managed through the corrective action programs of the licensee, the ce rtificate holder, or both.

Corrective actions may include Modification of TLAAs Adjustment of the scope, frequency, or bot h of AMPs Repair or replacement of SSCs Rancho Seco will assess new information relevant to aging management, as it becomes available, in accordance wit h normal corrective action and OE programs. Tollgates are an opportunity to seek out other information that may be available and perform an aggregate assessment.

Tollgate assessments are not stopping points. No action other than performing an assessment is required to continue NUHOMS dry storage system operation.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-16 SMUD will perform tollgate a ssessments during the PEO of the Rancho Seco ISFSI, spanning the period from June 30, 2020 through June 30, 2060 or the date the last licensed material is removed from the Rancho Seco ISFSI, whichever occurs sooner. Tollgate asse ssments for the Rancho Seco ISFSI will be performed as shown in Table C-13 (new ISFSI FSAR Table 9.8-13).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-17 C.3 Proposed Revised Rancho Seco ISFSI FSAR Sections The Rancho Seco ISFSI FSAR was re viewed for proposed changes required to reflect the change in the license term from the original 20 years to 60 years as a result of the additi onal 40 years of the PEO, plus some revised analyses to address this extended license term. C.3.1 FSAR Volume I, Section 1.1 - Introduction Revise the second paragraph to reflect renewal of the ISFSI license for an additional 40 years: Consistent with Rancho Seco PSDAR, the Independent Spent Fuel Storage Installation (ISFSI) is intended to prov ide dry storage capacity for Rancho Seco spent nuclear fuel and Greater than Class C (GTCC) radioactive waste. The storage system was designed for 50 year service, and initially licensed for 20 years in accordance with 10 CFR

72. On [mm/dd/yy], the NRC approved renewal of the ISFSI license (SNM-2510) for an additional 40 years. The aging management activities associated with this renewal applies to Amendment 4. Any future amendments will include an aging management review (AMR) and any associated required aging management activities. The current aging management results are detailed in Chapter 9, Section 9.8. The original ISFSI FSAR chapters indicate design life and service life values of 50 years
1. The new design life is 60 years. Time-limited aging-analyses (TLAAs) to assess SSCs that have a time-dependent operating life to demonstrate that the existing licensing basis remains valid and that the intended functions of the SSCs in scope of renewal are maintained during the period of extended operation (PEO) to 60 years are detailed in Chapter 9, Section 9.8.4. Construction of the Rancho Seco ISFSI was completed during 1996 and the initial license was received on June 30, 2000. All fuel was in dry storage at the ISFSI in August 2002 and the single GTCC waste canister was loaded at the ISFSI in August 2006.

1The terms design life and service life are equivalent and interchangeable. C.3.2 FSAR Volume I, Section 1.2 -General Description of the Installation Revise the principal ISFSI design criter ia summary for design life in the 5th paragraph to reflect a design life of 60 years for the DSC: The efficacy of the neutron absorber panels throughout the 50 60-year design life of the DSC is demonstrated in the following manner:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-18 C.3.3 FSAR Volume I, Section 3.3.4.1.

1 -Fuel-Only (FO) DSC Design Features Revise the design life of the DSC for the neutron absorber panels used for nuclear criticality safety and the boron depletion results in the fifth paragraph to reflect a design life of 60 years: The efficacy of the neutron absorber panels throughout the 50 60-year design life of the DSC is demonstrated in the following manner: 1. Acceptance tests are performed on the panels during fabrication as described below and in compliance with Section 8.1.8 of the NUHOMS-MP187 TC transportation SAR [3.6]. The neutron absorber plates are verified to have the minimum total B 10 per unit area (areal density) of the sandwiched material as specified on the drawings in Volume IV. Samples from each sheet of the neutron absorber are retained fo r testing and record purposes.

The minimum areal B 10 content and the uniformity of dispersion within a panel are verified by wet chemical analysis and/or neutron attenuation testing. All mate rial certifications, lot control records, and test records are maintained to assure material traceability. 2. Depletion of the poison material over the storage period is negligible. Using the results of the canister shielding models described in Volume III, Chapter 7 and in Reference Calculation 2069.0503, the maximum neutron flux in the DSC during storage is 2.6x10 5 neutrons/sec/cm

2. Conservatively applying the thermal neutron capture cross-section for B 10 of 3837 barns and using a B 10 number density in the absorber panels of 6.634x10-3 atoms/b-cm, the total B 10 depletion over the 50-year DSC design life is then 1.0x10 8 atoms B 10/b-cm. This represents less than 0.0002% of the total B 10 inventory in the absorber panels. A new calculation was performed using the Monte Carlo N-Particle computer code. The maximum B 10 depletion ratio calculated is

[ ] This represents a

[ ] depletion over a period of 100 years, which envelops the 60-yr total storage period with the additional PEO.

C.3.4 FSAR Volume I, Section 8.1.1.9 -Thermal Cycling of the Cask Add an additional par agraph after the 1 st paragraph for the thermal cycling of the cask to reflect a design life of 60 years:

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-19 The largest mean daily change of temperature at the Rancho Seco site is conservatively assumed equal to the largest mean daily change of temperature in the United States of 47°F, occurring in Reno, Nevada. Because of the large thermal mass of the cask, a period of approximately 1 day is needed to obtain steady state temperatures and a steady st ate thermal gradient. For conservatism, it is assumed that the 47°F maximum daily change could produce a steady state gradient every day for 50 years, for a total of 18,250 thermal cycles. From the S-N curve, a temperature fluctuation of up to 49

°F, corresponding to 10 6 cycles is acceptable. Fatigue effects, including that from thermal cycling, were originally analyzed for a design life of 50 years. A new analysis was performed to address the six criteria from ASME B&PV Code,Section III, [C-3]

1 , Subsection NB-3222.4 affecting fatigue for the DSCs and TC at Rancho Seco. The criteria are: 1) Atmosphere-to-Service Pressure Cycle; 2) Normal Service Pressure Fluctuation; 3) Temperature Difference - Startup and Shutdown; 4) Temperature Difference - Normal Service; 5) Temperature Difference - Dissimilar Materials; and 6) Mechanical Loads. The results of the analysis indicate that the limits of peak stress intensities, as governed by fatigue, have been satisfied by compliance with these six criteria and that no additional analysis is required for the PEO.

1 Reference # for [C-3] in FSAR Volume I, Section 8.1.1.9 should be changed to existing reference [8.8].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-20 C.4 References Add the following references to FSAR Volume I, Section 9.7:

C-1 Rancho Seco Independent Spent Fuel St orage Installation Materials License SNM-2510 Amendment 4, November 2017 (Docket 72-11). C-2 U.S. Nuclear Regulatory Commission, NUREG-1927, Revision 1, "Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nu clear Fuel," June 2016. C-3 ASME B&PV Code,Section III, Division 1, 1992 Edition, wit h Addenda through 1993. C-4 Nuclear Energy Institute, "Format, Content and Implementation Guidance for Dry Storage Operations-Based Aging Management," NEI 14-03 Revision 2, 2016.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-21 Table C-1 (New Rancho Seco ISFSI FSAR Table 9.8-1)

Scoping Evaluation of Ra ncho Seco ISFSI SSCs

[Insert Final LRA Table 2-1]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-22 Table C-2 (New Rancho Seco ISFSI FSAR Table 9.8-2)

Scoping Evaluation Results for Spent Fuel Assemblies

[Insert Final LRA Table 2-9]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-23 Table C-3 (New Rancho Seco ISFSI FSAR Table 9.8-3)

Rancho Seco FO-DSC Intended Functions and AMR Results

[Insert Final LRA Table 3-3]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-24 Table C-4 (New Rancho Seco ISFSI FSAR Table 9.8-4)

Rancho Seco FC-DSC Intended Functions and AMR Results

[Insert Final LRA Table 3-4]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-25 Table C-5 (New Rancho Seco ISFSI FSAR Table 9.8-5)

Rancho Seco FF-DSC Intended Functions and AMR Results

[Insert Final LRA Table 3-5]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-26 Table C-6 (New Rancho Seco ISFSI FSAR Table 9.8-6)

Rancho Seco GTCC DSC Intended Functions and AMR Results

[Insert Final LRA Table 3-6]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-27 Table C-7 (New Rancho Seco ISFSI FSAR Table 9.8-7)

Rancho Seco HSM Intended Functions and AMR Results

[Insert Final LRA Table 3-8]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-28 Table C-8 (New Rancho Seco ISFSI FSAR Table 9.8-8)

Rancho Seco TC Intended Functions and AMR Results

[Insert Final LRA Table 3-10]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-29 Table C-9 (New Rancho Seco ISFSI FSAR Table 9.8-9) DSC External Surfaces Aging Management Program

[Insert Final LRA Table B-1]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-30 Table C-10 (New Rancho Seco ISFSI FSAR Table 9.8-10)

HSM Aging Management Program for External and Internal Surfaces

[Insert Final LRA Table B-2]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-31 Table C-11 (New Rancho Seco ISFSI FSAR Table 9.8-11)

TC Aging Management Program

[Insert Final LRA Table B-3]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-32 Table C-12 (New Rancho Seco ISFSI FSAR Table 9.8-12)

ISFSI Basemat Aging Management Program

[Insert Final LRA Table B-4]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix C - Changes to the Rancho Seco ISFSI FSAR Page C-33 Table C-13 (New Rancho Seco ISFSI FSAR Table 9.8-13)

Rancho Seco ISFSI Tollgates

[Insert Final LRA Table 3-11]

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix D - Proposed License/Technical Specifications Changes Page D-i APPENDIX D PROPOSED LICENSE/TECHNICAL SPECIFICATIONS CHANGES CONTENTS D.1 Introduction

..................................................................................................... D-1 D.2 Proposed License Condi tion Changes ......................................................... D-2 D.2.1 Revised License Conditions

................................................................... D-2 D.2.2 New License C onditions

........................................................................ D-2 D.3 Proposed Technical Specifi cations Changes .............................................. D-3 D.4 References ...................................................................................................... D-4

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix D - Proposed License/Technical Specifications Changes Page D-1 D.1 Introduction As recommended in Section 1.4.7 of NUREG-1927, Standard Review Plan for Renewal of Specific Licenses and Cert ificates of Compliance for Dry Storage of Spent Nuclear Fuel [D-1], and cons istent with the guidance of NEI 14-03, Format, content and Implementation Gui dance for Dry Stor age Operations-Based Aging Management

[D-2], the independent spent fuel storage installation (ISFSI) license renewal appl ication (LRA) should provide proposed changes to the specific license and Technical Specifications (TS) associated with the license renewal fo r the period of extended operation (PEO). The Rancho Seco ISFSI license (SNM-2510), including the TS in the appendix, have been reviewed and proposed changes are provided below.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix D - Proposed License/Technical Specifications Changes Page D-2 D.2 Proposed License Condition Changes D.2.1 Revised License Conditions Consistent with NUREG-1927, Section 1.4.4, Sacramento Municipal Utility District (SMUD) proposes the following editorial changes in license conditions associated with this renewal licensing action: 1. Revise License Condition #2 to change reference to the facility from the "Rancho Seco Nuclear Generating Station" to the "Rancho Seco

Independent Spent Fuel Stor age Installation." 2. Because the Part 50 operating license has been terminated, License Condition #20 related to fuel and cask movement and handling activities being performed in the Rancho Seco Nuclear Generating Station (RSNGS) Fuel Storage Building under the requirements of the Operating License (DPR-54) and associated TS is no longer needed. Therefore, SMUD requests that License Condition #20 be deleted. D.2.2 New License Conditions The following new license conditions are proposed associated with renewal:

commitments resulting from the review and approval of the renewal of the license.

  • Programs or procedures shall be revised, or new ones created for implementing the activities in the aging management programs (AMPs) described in the updated FSAR within 180 days after the license renewal becoming effective, or prior to S eptember 28, 2021 (i.e., 180 days after the 20 th anniversary of the loading of the first dry storage system at the Rancho Seco ISFSI site), whichever is later.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix D - Proposed License/Technical Specifications Changes Page D-3 D.3 Proposed Technical S pecifications Changes NUREG-1927, [D-1] indicates that an application for license renewal should include any TS changes or additions that are necessary to manage the effects of aging during the PEO. A review of t he information provided in this LRA and the Rancho Seco ISFSI TS confirms that no changes to the ISFSI TS are necessary to manage aging effects. Therefor e, no changes to the existing TS are proposed.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix D - Proposed License/Technical Specifications Changes Page D-4 D.4 References D-1 U.S. Nuclear Regulatory Commission, NUREG-1927, Revision 1, "Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nu clear Fuel," June 2016. D-2 Nuclear Energy Institute, NEI 14-03, Revision 2, "Format, Content and Implementation Guidance for Dry Cask Storage Operations-Based Aging Management," December 2016.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-i APPENDIX E ENVIRONMENTAL REPORT SUPPLEMENT CONTENTS E.1 Introduction

...................................................................................................... E-1 E.1.1 Purpose and Need for Proposed Acti on.................................................. E-1 E.1.2 Proposed Action ..................................................................................... E-1 E.1.2.1 Licensing History ....................................................................... E-2 E.1.2.2 Operations ................................................................................. E-3 E.1.3 Environmental Report Supplement Scope and Methodology

.................. E-4 E.1.4 Applicable Regulatory Requ irements, Permits, and Required Consultations .......................................................................................... E-5 E.1.4.1 Threatened and Endangered Spec ies Consultation .................. E-5 E.1.4.2 Historic Preservation Consultation ............................................ E-6 E.2 Alternatives ...................................................................................................... E-7 E.2.1 No-Action Alternative .............................................................................. E-7 E.2.2 Other Alternatives ................................................................................... E-7 E.2.2.1 Ship Fuel to a Permanent Federal Repository

........................... E-7 E.2.2.2 Ship Fuel to an Offsite In terim Storage Facility ......................... E-8 E.3 Affected Environment ..................................................................................... E-9 E.3.1 Site Location ........................................................................................... E-9 E.3.2 Land Use ................................................................................................ E-9 E.3.3 Transportation ....................................................................................... E-10 E.3.4 Geology, Soils, and Se ismology ........................................................... E-10 E.3.5 Water Resources .................................................................................. E-11 E.3.6 Ecological Resources ........................................................................... E-12 E.3.6.1 Natural Communities ............................................................... E-12 E.3.6.2 Special-Status Species

............................................................ E-12 E.3.7 Meteorology, Climatology , and Air Quality ............................................ E-13 E.3.8 Noise ..................................................................................................... E-13 E.3.9 Historical and Cultur al Resources ......................................................... E-13 E.3.10 Visual and Scenic Resources ............................................................... E-15 E.3.11 Demography and Soci oeconomics ....................................................... E-16

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-ii E.3.11.1 Demography ............................................................................ E-16 E.3.11.2 Environmental Justice ............................................................. E-16 E.3.11.3 Socioeconom ics ......................................................................

E-17 E.4 Environmental Impacts ................................................................................. E-18 E.4.2 Impacts from Refurbishm ent and Constr uction ..................................... E-18 E.4.3 Occupational and Public Radiolog ical Health Impacts .......................... E-19 E.4.3.1 Occupational Dose .................................................................. E-19 E.4.3.2 Public Dose ............................................................................. E-19 E.4.4 Other Operational Impacts .................................................................... E-20 E.4.5 Accident Impacts .................................................................................. E-22 E.5 Mitigation M easures ...................................................................................... E-23 E.6 Environmental Measurement and Monitoring ............................................. E-24 E.7 Summary of Environmental Consequences

................................................ E-25 E.7.1 Unavoidable Advers e Impacts .............................................................. E-25 E.7.2 Irreversible and Irretrievable Commitment of Resources ...................... E-25 E.7.3 Short-Term Uses, Maintenanc e, and Enhancement of Long-Term Productivity .................................................................................. E-25 E.8 References ..................................................................................................... E-26 LIST OF TABLES Table E-1 Cross-Reference Table for En vironmental Requirements of 10 CFR 51 ............................................................................................ E-28 Table E-2 Regulatory Requirements, Pe rmits, and Consultations ........................ E-29 Table E-3 Special Status Species ......................................................................... E-30 Table E-4 Nearest Major Population C enter Demographics .................................. E-31 Table E-5 Estimated 2015 Populations ................................................................. E-32 Table E-6 Minority and Low-Income Demographics .............................................. E-33 Table E-7 Environmental Impacts of Rancho Seco ISFSI License Renewal ......... E-34

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-iii LIST OF FIGURES Figure E-1 Location of Rancho Seco Site

............................................................... E-35 Figure E-2 Rancho Seco Owner-C ontrolled Ar ea ...................................................

E-36 Figure E-3 Rancho Seco ISFSI Site ....................................................................... E-37

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-1 E.1 Introduction E.1.1 Purpose and N eed for Proposed Action The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of Independent Spent Fuel Storage Installations (ISFSIs) for storing power reactor spent fuel and associated radioactive materials. The NRC issues licenses in accordance with the Atomic Energy Act of 1954 (42 United States Code (USC) 2011, et seq.) and NRC implementing regulations (10 Code of Federal Regulations (CFR) Part 72). On June 30, 2000, the NRC issued Sacramento Municipal Utility District (S MUD) a specific license (SNM-2510) valid for 20 years to receive, possess, store, and transfer the Rancho Seco Nuclear Generating Station (RSNGS) spent fuel to sealed storage canisters at an Independent Spent Fuel St orage Installation (ISFSI) located on the Rancho Seco site.

The ISFSI was constructed to facilitate decommissioning of the RSNGS. The ISFSI provides interim storage for the spent nuclear fuel 1 that had been stored in the RSNGS Spent Fuel Pool, and thereby allowed SMUD to proceed with decommissioning of the spent fuel pool and associated systems. By contract, the U.S. Department of E nergy (DOE) has the ultima te responsibility for the permanent disposition of t he spent fuel stored at RSNGS. Interim storage for the RSNGS spent fuel was necessary because there was no operational DOE facility for permanent disposal or storage for irradiated spent nuclear fuel at the time the RSNGS was being decommissioned.

Extended operation of t he Rancho Seco ISFSI is necessary, since SMUD must be able to store spent fuel until t he DOE has removed all spent fuel from the Rancho Seco site. E.1.2 Proposed Action The proposed action is to renew the specific license, SNM-2510, for the Rancho Seco ISFSI. The current specific license will expire on June 30, 2020. SMUD proposes to extend the Rancho Seco ISFSI license for 40 years beyond the current specific license te rm, through June 2060, in accordance with 10 CFR 72.42. Extendi ng the specific license for the ISFSI will allow SMUD to maintain safe storage of the spent fuel until its acceptance by DOE for removal from the Rancho Seco site.

1 The Rancho Seco ISFSI also stores one DSC containing GTCC waste.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-2 E.1.2.1 Licensing History In June of 1989, the RSNGS ceased operation, and the reactor was completely defueled in December of 1989. SMUD's decommissioning plan

called for storing the spent fuel in a site specific ISFSI until the spent fuel was accepted by the DOE. On October 21, 1991, SMUD submitted Supplement to Rancho Seco Environmental Report - Post Operating License Stage, [E-1].

The Supplement provided an assessment of the environmental effects of decommissioning RSNGS, and provided a comparison of t hose impacts with the NRC's Generic Environmental Im pact Statement (GEIS), NUREG-0586, Final Generic Environmental Impact Statement on decommissioning of Nuclear Facilities: Supplement 1, R egarding the Decommissioning of Nuclear Power Reactors, [E-2].

On October 4, 1991, SMUD submitted an application, Rancho Seco Independent Spent Fuel Storage License Installation Application and Safety Analysis Report, [E-3] for a NRC license to construct and operate a dry cask ISFSI under 10 CFR Part 72, of the Commi ssions regulations. As part of the specific license process, SMUD subm itted a revised Environmental Report, Revision 1 to the Rancho Seco Independent Spent Fuel Storage Installation Environmental Report, [E-4] on June 16, 1993. In August 1994, the NRC issued an, Environmental Assessment related to the Construction and Operation of the Rancho Seco Independent Spent Fuel Storage Installation, [E-5] for the Rancho Seco ISFSI. The Environmental Assessment concluded that the ISFSI would not significant ly affect the quality of the human environment and an environmental impact statement was not warranted. The NRC issued SMUD a specific 10 CFR Part 72 materials license (SNM-2510)

on June 30, 2000.

SMUD completed the construction of the Rancho Seco ISFSI in 1996 and all spent fuel from the RSNGS was placed in dry storage by August 2002.

On July 19, 2004, SMUD submitted a License Amendment Request (LAR), Rancho Seco Independent Spent Fuel Storage Installation Request for Exemption From 10 CFR 72.44(d)(3) and Proposed License Amendment No.

1, [E-6] to eliminate the requirement for an annual report specifying the quantity of principal radionuclides released to the environment in liquid and gaseous effluents during the previous 12 months of ISFSI operations. The NRC found that the propos ed action was an administrative change that would not significantly affect the qualit y of the human environment and an environmental impact statem ent was not warranted, Exemption From 10 CFR 72.44(d)(3) for Dry Spent Fuel Storage Activities with Conforming Amendment (TAC Nos. L23752 and L23753), [E-7] and, Sacramento Municipal Utility District; Rancho Seco Independent Spent F uel Storage Installation; Issuance of Environmental Assessment and Finding of No Signifi cant Impact Regarding a Proposed Exemption and Conforming Amendment, [E-8].

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-3 On July 29, 2004, SMUD submitted a LA R for storage of Greater Than Class C waste at the Rancho Seco ISFS I, Rancho Seco Independent Spent Fuel Storage Installation Proposed License Am endment No. 2 fo r the Storage of Greater than Class C Waste, [E-1].

On March 24, 2005, the NRC issued an Issuance of Environmental Assessment and Finding of No Significant Impact of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI)

Request for Proposed License Amendm ent (TAC. No. L23757), [E-9] for Amendment 2 to license SNM-2510, conc luding that the ISFSI would not significantly affect the quality of the human environment and an environmental impact statement was not warranted.

On November 5, 2008, SMUD submitt ed a LAR, Rancho Seco Independent Spent Fuel Storage Installation Proposed License Amendment No. 3, [E-10] to allow storage of six fuel assemblies wit h known or suspected cladding defects greater than hairline cracks or pinhole leaks to be stored in five different FC-DSCs (Dry Shielded Canisters containing Fuel and Control Components). The NRC found that the proposed action requested in Amendment 3 qualified for the categorical exclusion listed in 10 CFR 51.22(c)(11) and no further environmental review was required [E-11].

On January 17, 2017, SMUD submitted Rancho Seco Independent Spent Fuel Storage Installation Proposed License Amendment No. 4. The amendment was seeking NRC approval to transfer the licensing for one Sr-90 radioactive source currently possessed by SMUD under its 10 CFR 50 License (DPR-054, Docket 50-312), to its 10 CFR 72 license. This is necessary since the 10 CFR 50 license is in the process of being terminated and SMUD is committed to

maintaining a radioactive source for t he purpose of calibrating instrumentation in order to monitor the ISFSI and fo r use in emergency response. The NRC found that the proposed action to transfe r the source to the Part 72 license was acceptable. No further environm ental review was required [E-22].

E.1.2.2 Operations The Rancho Seco ISFSI consists of a dry fuel storage system that includes a reinforced concrete pad, sealed dry shield ed canisters (DSCs), and reinforced concrete horizontal storage modules (HSMs). The system provides radiation shielding and passive decay heat removal. The system provides adequate heat removal capacity to maintain safe fuel clad temperatures without active cooling systems. The Rancho Seco ISFS I Final Safety Analysis Report (FSAR), Rancho Seco Independent Spent Fuel Storage Installation Final Safety Analysis Report, [E-12] contains a detailed description of the dry fuel storage system.

The Rancho Seco ISFSI is located within a secure area on the former RSNGS site.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-4 The onsite SMUD staff currently performs daily activities associated with the operation of the ISFSI facility, which primarily involve security, routine maintenance, and monitoring. No major changes in staffing levels are anticipated during the period of extended operation (PEO). The passive nature of the facility requires little periodic maintenance and surveillance. Radioactive waste is not generated during routine operation at the ISFSI.

No major construction or refurbishment projects are currently planned for the ISFSI during the PEO. Due to the delay in DOE removing the waste from the site, the spent nuclear fuel from the RSNGS reactor will be stored onsite for an extended period. The ISFSI will be subj ect to aging management activities to ensure the continued performance of t he DSCs, Transfer Cask, HSMs, and Basemat during the ISFSI PEO. The aging management programs are summarized in Appendix B of the LRA. E.1.3 Environmental Report Supplement Scope and Methodology SMUD has prepared this supplemental Environmental Report as part of its application to the NRC to renew the specific ISFSI license in accordance with the following NRC regulations:

  • 10 CFR Part 72, Licensing Requir ements for the Indepen dent Storage of Spent Nuclear Fuel, High Level Radioactive Waste, and Reactor-Related Greater than Class C Waste 10 CFR 72.34, Environmental report; and 10 CFR 72.42, Duration of license, renewal.
  • 10 CFR Part 51, Environmental Protection Requirements for Domestic Licensing and Related Regulatory Functions 10 CFR 51.45, Environmental report; and 10 CFR 51.60, Environmental report-materials licenses. NRC regulation 10 CFR 72.42 provides for ISFSI license renewal, and regulation 10 CFR 72.34 requires an application to include an Environmental Report that meets the requi rements of 10 CFR 51, Subp art A. In Subpart A, 10 CFR 51.60 requires that the Environm ental Report be a separate document entitled "Supplement to Applicant's En vironmental Report" and specifies the Environmental Report contents. The regulation focuses on presenting any significant environmental change from the previously submitted Environmental Report. NUREG-1927 [E-14], Section 1.4.3 specifies submittal of a supplemental environmental report with the LRA.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-5 In determining what information to include in the ISFSI supplement Environmental Report, SMUD has relied on guidance provided in Environmental Review Guidance for Licensing Actions Associated with NMSS

Programs, NUREG-1748, [E-13] and NRC guidance pr ovided in Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel, NUREG-1927, [E-14]. This indicates that license renewal is not an exercise in re-licensing and is not intended to impose requirements beyond those that we re met by the facility when it was initially licensed. SMUD asse mbled a team to review the Environmental Report submitted with the original Rancho Seco ISFSI license application and NRC's subsequent environmental analysis to ident ify areas that require updating to meet the expectations of NUREG-1748. The review included evaluation of any significant changes during the initial licensing period and considered whether significant changes are anticipated during the PEO.

SMUD has prepared Table E-1 to verify conformance with the regulatory requirements. Table E-1 provides the lo cations of supplemental Environmental Report content that respond to regulatory requirements. E.1.4 Applicable Regulatory Requirements, Permits, and Required Consultations Continued operation of the Rancho Seco ISFSI does not require any additional permits, licenses, or approval s other than the renewal of the NRC materials license. Table E-2 lists the aut horizations and consultations that are related to the Rancho Seco ISFSI license renewal application. This section discusses the consultations in more detail.

E.1.4.1 Threatened and Endangered Species Consultation Section 7 of the Endangered Species Ac t (16 USC 1531 et seq.) requires federal agencies to ensure that their actions are not likely to jeopardize the continued existence of species that ar e listed, or proposed for listing, as endangered or threatened.

Depending on the type of action and potential effects involved, the Act requires consulta tion with the U.S. Fish and Wildlife Service (USFWS) regarding effects on terr estrial and freshwater species, and with the National Marine Fisheries Se rvice (NMFS) regarding effects on anadromous and marine species. USFWS and NMFS have issued joint procedural regulations at 50 CFR Part 402, Subpart B, that address consultation, and USFWS maintains the joint list of threatened or endangered species at 50 CFR Part 17.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-6 A federal agency is not required to consul t with the USFWS and/

or NMFS if it determines an action will not affect lis ted endangered or threatened species, or their designated critical habitat. The agency is required to consult if it determines that the action may affect listed species or critical habitat, even if the effects are expected to be beneficia

l. If the agency determines that the action is not likely to adversely affe ct listed endangered or th reatened species or their critical habitat, it can request the concurrence of the USFWS and/or NMFS with that determination. Ther efore, whether and how the NRC may choose to request consultation with USFWS and NMFS will depend upon the

determination as to potential effect.

As discussed in Section E.4.4, SMUD expects that there will be a "no-effect" determination. The NRC may choose to solicit comments from the California Department of Fish and Wildlife, and California Native Plant Society regarding species listed in California prior to renewing the ISFSI license. E.1.4.2 Historic Preservation Consultation Section 106 of the National Historic Preservation Act (16 USC 470 et seq.)

requires that federal agencies having the authority to license any undertaking, prior to issuing the license, take into account the effect of the undertaking on historic properties and a fford the Advisory Council on Historic Preservation (ACHP) the opportunity to comment on the undertaking. The ACHP regulations provide for establishing an agreement with any State Historic Preservation Office (SHPO) to substitu te state review for council review (36 CFR 800.2). Therefore, the NRC may request comments from the California SHPO to ensure that the proposed action will not impact historic properties.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-7 E.2 Alternatives E.2.1 No-Action Alternative Under the no-action alternative, the NRC would not renew the specific license for the Rancho Seco ISFSI. The license would expire on June 30, 2020, at

which time SMUD would no longer be able to legally store spent fuel at the

ISFSI. SMUD would need to remove the st ored fuel from the ISFSI, transport the fuel to another licensed storage fa cility, and decommission the ISFSI associated with SNM-2510. There is no f ederal repository or other federal disposition path available for the spent fuel presently stored under SNM-2510.

Therefore, the no-action alternative is not a reasonable alternative. E.2.2 Other Alternatives In the original ISFSI license applic ation Environmental Report (Reference

[E-4], SMUD evaluated the following alternatives to constructing the Rancho Seco ISFSI in addition to the no-action alternative:

  • Ship spent fuel from Rancho Seco to a reprocessing facility.
  • Store spent fuel in other dry storage technologies.
  • Ship spent fuel to other utility's spent fuel pools.
  • Continue to store spent fuel wet in the spent fuel pool.
  • Ship spent fuel to a permanent federal repository.

There are still no commercial reprocessing facilities operating in the United States. Transferring the spent fuel to another dry storage system would not alleviate the need to renew the Rancho Seco specific ISFSI License. There are no utilities storing fuel from other utilities in their spent fuel pools.

Continued storage of dischar ged spent fuel in the Rancho Seco spent fuel pool is not a viable alternative, bec ause the spent fuel pool and associated facilities have been decommissioned.

An updated evaluation of the alternative of shipping spent fuel to a permanent Federal repository along with a new alter native of shipping fuel to an offsite interim storage facility are discussed in the following sections. E.2.2.1 Ship Fuel to a Permanent Federal Repository SMUD and the NRC intend for storage at the Rancho Seco ISFSI to be interim pending availability of a f ederal repository. There is uncertainty regarding when a federal repository will be licensed and the schedule under which it will be available to accept spent fuel ship ments. This uncertainty supports the need for Rancho Seco ISFSI specific license renewal. The repository schedule

drives the ISFSI duration; the longer it takes for the repository to begin accepting spent fuel shipments, the l onger the ISFSI must store spent fuel.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-8 Availability of a geological repository to accept nuclear fuel is not yet known and it is reasonable to assume a repository will not be ready prior to expiration of the Rancho Seco ISFSI license in 2020. The shipment of Rancho Seco

spent fuel to a permanent federal repository is not a viable alternative to the ISFSI license renewal. E.2.2.2 Ship Fuel to an Offsite Interim Storage Facility Commercial entities have expressed interest in establishing a consolidated interim storage facility (CISF) for away-from-reactor storage of spent nuclear fuel. Two locations in the southwestern U.S., the Eddy-Lea Alliance facility in New Mexico and the Waste Control Spec ialists (WCS) facility in Andrews County, Texas have been proposed. WCS submitted its CISF application to the NRC in April of 2016, License Application to Construct and Operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews C ounty, Texas, [E-15]; and Revision 1 of the application in March of 2017, Licens e Application to Construct and Operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas, [E-16]. Holtec International submitted its CISF application for the Eddy-Lea Alliance facility to the NRC in March 2017, Holtec International

HI-STORE CIS (Consolidated Interim Stor age Facility) License Application, [E-17]. Because the availability of a CISF is un likely in time to eliminate the need for the Rancho Seco ISFSI license renewal (i.e., by 2020), the shipment of the spent fuel to a CISF is not a r easonable alternative at this time.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-9 E.3 Affected Environment E.3.1 Site Location The Rancho Seco ISFSI is located wit hin the Owner Controlled Area of the Rancho Seco site, which is owned and operated by SMUD. The Rancho Seco site comprises approximately 2,480 acres in Sacramento County, California.

The Rancho Seco site occupies all or parts of Sections 27, 28, 29, 32, 33, and 34 of Township 6 North, Range 8 Eas

t. The site is approximately 26 miles north-northeast of Stockton and 25 miles southeast of Sacramento, as shown in Figure E-1. More generally, the Rancho Seco site is located between the Sierra Nevadas to the east and the Coast Range along t he Pacific Ocean to the west in an area of flat to lightly rolling terrain at an elevation of approximately 200 feet above mean sea level. To the east of the site, the land becomes hilly, rising to an elevation of 600 feet at a distance of about seven miles, and increasing in elevation thereafter approaching the Sierra Nevada foothills.

The approximate coordinates of the site are 38°-20'-40" North Latitude and 121°-07'-10" West longitude, or 4245500 Mn and 664400 Me Universal Transverse Mercator coordinates. The Rancho Seco Owner-Controlled Area is shown in Figure E-2. As shown in Fi gure E-3, the Rancho Seco ISFSI is located west of the site's Industrial Area, approximately 600 feet west of the Interim Onsite Storage Building. The Ranc ho Seco ISFSI pad is approximately 225 feet by 170 feet in size, and contained within an approximately 14 acre licensed area. E.3.2 Land Use Surrounding the ISFSI site to the north, east and south are rolling hills vegetated with naturalized annual grasses. Seasonal wetlands, swales, and intermittent drainages are present thr oughout much of this surrounding area.

Further to the north are agricul tural uses. The area includes the decommissioned RSNGS, Rancho Seco Photovoltaic Solar Project, Cosumnes Power Plant (CPP), Rancho Seco Lake and associated recreational facilities, and Amanda Blake Memorial Wildlife Refuge. The Rancho Seco Photovoltaic Solar Project is a 10-MW power facility located within the boundary of t he former RSNGS. The CPP is a 500 MW combined-cycle gas fired power plant located approxim ately 0.5 miles south of the ISFSI.

In the early 1970s, a small pond locat ed on the Rancho Seco property was expanded into a 160-acre lake (Ranch Seco Lake). The current lake and surrounding park facilities (developed area) are located east of the ISFSI site.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-10 In 1995, SMUD entered into a lease agr eement with the Performing Animal Welfare Society to establish the Amanda Blake Memorial Wildlife Refuge. The refuge is a 75-acre sanctuary that houses rescued animals. The refuge is located southeast of the ISFSI site.

On October 1, 2002, a Memorandum of Agreement was recorded between SMUD and the Nature Conservancy for construction and maintenance of a foot trail that would extend through a portion of SMUD's property. In June 2006, SMUD, working cooperatively with t he Nature Conservancy, dedicated the Howard Ranch Nature Trail, a se ven-mile-long trail through its property and the adjoining Howard Ranch.

E.3.3 Transportation As shown in Figure E-2, State Route 104 (T win Cities Road) runs just north of the site in a general east-west direct ion and connects with State Route 99 to the west and State Route 88 to the east. There are no public highways that traverse the Rancho Seco IS FSI site. Route 104 is travelled primarily by local traffic. The Twin Cities Access Road is the main access road to the ISFSI and to the nearby Rancho Seco Recreational Park. There is a Union Pacific railroad line north of the site tha t, at one point, comes within one-half mile of the Rancho Seco ISFSI. The track runs roughly parallel to State Route 104, and is used to haul a variety of commodities. Rail access to the Rancho Seco site is available via a rail spur from the existing Union Pacific Rail road line described above. E.3.4 Geology, Soils, and Seismology The Rancho Seco site is about 25 miles southeast of Sacramento in the low hills at the edge of the Sierra Nev ada Mountains. The site is founded on the Pliocene Laguna Formation and is underlain by approximately 1,500 to 2,000 feet of tertiary or older sediments deposited on a basement complex of granitic to metamorphic rocks. Detailed field mapping, auger holes, soil samples, and geophysical refraction profiles indicate t he unfaulted nature of the sediments.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-11 There is no indication of faulting beneath the site. The nearest fault system, the Foothill Fault System, is about 10 mile s to the east of the site. It has been inactive since the Jurassic Period, some 135 million years ago. The nearest active faulting along which historic large earthquake shocks have originated are the Hayward and San Andreas Faults, some 70 and 89 miles to the west, respectively, and the faults over 80 miles to the east beyond the Sierra Nevada Range. Earthquake shaking will occur as the result of shocks along distant faults, but because of their distant origin and the nature of the foundation material beneath the site, gr ound accelerations greater than 0.05g should not occur during the life of the Rancho Seco ISFSI. Conservative

values of 0.25g horizontal and 0.17 g vert ical were used for the design basis earthquake for the Rancho Seco ISFSI.

As part of the Rancho Seco ISFSI site selection process, SMUD had borings analyzed from the proposed Rancho Seco IS FSI sites. Based on the results of the boring analyses, SMUD performed appropr iate remedial measures (e.g., compaction and/or replacement of soil) to ensure adequate structural support for the Rancho Seco ISFSI.

A detailed discussion of the geology, soils and seismology of the Rancho Seco ISFSI site may be found in Sections 2.5 and 2.6 of the Rancho Seco ISFSI FSAR, [E-12]. E.3.5 Water Resources The site is bounded on the north by Hadselville Creek, which intercepts all drainage from the site and empties into Laguna Creek to the west. The flow is continued westerly by Laguna Creek Sout h, a tributary of the Consumnes River, and into the Mokelumne River. T he Mokelumne is a tributary of the southerly flowing Sacramento River and enters the Sacramento River approximately 20 miles south of the city of Sacramento.

Storm water runoff at the Rancho Seco site is controlled primarily by surface ditches. Generally, overland flows will be intercepted by the ditches and

diverted around the ISFSI to natural st ream channels. When this is not possible, runoff will be diverted down cut slopes in culvert pipes and

discharged to the plan t drainage ditch system.

Pumping tests conducted in explorator y holes indicated the presence of ground water underlying the Rancho Seco site approximately 150 feet below the original ground surfac

e. The water is of good quality and is readily extracted by wells.

Groundwater in this area occurs under fr ee or semi-confined conditions as a part of the Sacramento Valle y Groundwater Basin. The water is stored chiefly in the Mehrten Formation. The sand and gr avel zones of that formation yield water readily to wells.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-12 Galt and Lodi are the closest communities with public groundwater supplies to the south and west. They are supplied by the City of Galt Water System, the Lodi Municipal Water Works, and the No rth San Joaquin Water Conservation District (Lodi area). The wells supplyin g Galt and Lodi penet rate a number of aquifers. The Lodi wells draw water from recent alluvium, th e Victor Formation, the Laguna Formation, and probably the Mehr ten Formation. The Galt wells tap the Laguna Formation and probabl y the Mehrten Formation. E.3.6 Ecological Resources E.3.6.1 Natural Communities Renewing the ISFSI license does not involve refurbishment or new construction. Therefore, the area of potential ecological impact for continued operations of the ISFSI is limited to the area immediately surrounding the ISFSI potentially disturbed by securi ty personnel and operations staff associated with periodic monitoring, inspections, and maintenance.

The ISFSI site is located at the eastern edge of the Central Valley grassland in the vegetation type known as the Califo rnia prairie or the California annual grasslands. These grasslands are distinguished as land that is relatively well

drained, not containing areas of st anding water, and dominated by grasses and forbs (broad-leaved plants) characteristic of annual grassland. The grassland ecosystem in the area appears to be the same as other sections of grazed annual grassland along the east side of the Central Valley, except for the areas of vernal pools found within 1-1/2 to 2 miles to the south and east. The vernal-pool areas (designated as Crit ical Habitat) correspond to the extent of hardpan Redding soil. The vernal-pool areas consist of rolling topography underlaid by hardpan. Winter rains fill the depressions to begin the annual cycle of vernal pool development. The plant species of vernal pools are quite unique to this kind of habitat, and the ver nal pools tend to retain their unique character except when insufficient ra infall allows typical annual grassland species to successfully invade the vernal pool areas. Often vernal pool basins will remain bare or have only a few non-ve rnal species during the dry season.

E.3.6.2 Special-Status Species Table E-3 provides a list of special stat us species within a five-mile radius of the Rancho Seco ISFSI. The list was obt ained from the California Natural Diversity Database (CNDDB).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-13 E.3.7 Meteorology, Clim atology, and Air Quality The climate of the Rancho Seco ISFSI site is generally that of the Great Central Valley of California. Summers are hot and cloudless and the winters

are mild. The rainy season occurs bet ween October and May with more than two-thirds of the annual rainfall occurri ng in December through March. Heavy fog occurs in mid-winter, primarily in December and January, and may last for several days. The most important controlling geographical influence on the climate results from the mountains that surround t he valley to the west, north, and east.

During the winter, storms that pass through the area are moderated by the mountains that collect much of the prec ipitation. The rains that occur in the valley are usually accompanied by south to southeast winds. The cold north

and northwest winds pass over the mountai ns to the north where the air is warmed dynamically by descent into the valley resulting in comparatively warm, dry winds. A similar condition occurs infrequently in the summer when a steep northerly pressure gradient dev elops, producing a pronounced heat wave. The Central Valley warms greatly during the day resu lting in a marked thermal contrast between the valley and the air over the Pacific. The Coast Range separates the marine air from the valle y air except for a gap through the range formed by the Sacramento and San J oaquin Rivers. The heavy marine air flows through this gap and splits into a northerly flow into the San Joaquin

Valley and a southerly flow into the Sacramento Valley.

E.3.8 Noise Storage of irradiated fuel and associated materials at the ISFSI involves use of a passive system that does not generate noise. Audible noise directly attributable to operation of the ISFSI is generally limited to occasional vehicle traffic to and from t he ISFSI during routine oper ations and maintenance activities. E.3.9 Historical and Cultural Resources As a federal undertaking, Rancho Seco ISFSI license renewal requires compliance with the National Historic Preservation Act through the Section 106 process of identification, evaluation, and mitigation of effects to historical cultural resources. Subsequent to the s ubmitting of the original Environmental Report, [E-4], additional studies a nd surveys have been performed. The following summary of the cultural res ources for the area is taken from the Initial Study and Mitigated Negative Declaration for the Rancho Seco Photovoltaic Solar Project (Section 5 of Appendix A of Reference E-1).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-14 The entire proposed (solar) project site lies within the ethnographic area once occupied by the Plains Miwok Tribe.

The Plains Miwok occupied the lower Mokelumne and Cosumnes Rivers and the Sacramento River from Rio Vista to Freeport. Because very few Plains Miwok were alive when ethnographers began working with Native Americans in the early 1900s, the most comprehensive study of the Miwok was done using Spanish mission records, diaries, and journal

s. The Miwok were probably not the earliest inhabitants of this area. They are believed to hav e entered California from the north, sometime around A.D. 500. Before that time, the area may have been occupied by Hokan-speaking people.

According to available written information, explorers, fur tr appers, and others (e.g., ranchers) settled in the north va lley. The immediate impact of these early contacts was the decimation of the native population through the introduction of diseases. By the late 1700s, Spanish explorers seeki ng potential inland mission sites had entered the Central Va lley. During the historical period (approximately 1850 to the pr esent), the project site and its surroundings were part of the Alabama Townsh ip, which extended west from the Arroyo Seco Land Grant to the Central Pacific Railr oad's Amador Branch Line that ran from Galt to Ione. In the 1800s, ranching and agriculture flourished. After the discovery of gold in 1848, the influx of people into California changed the subsequent history of the region. The decades following the Gold Rush are marked by Native American displacem ent, gold mining, agriculture, and commerce. Rail lines were established to transport people and goods more

efficiently. Sacramento was the western end of the transcontinental railroad, which was completed in 1869. The railroad helped carry California's

agricultural products throughout the c ountry, and further established the Sacramento region as a productive agricultural hub. By the mid to late 1800s, the Central Pacific Railroad owned lar ge portions of land in the Alabama Township. The nearest settlement to the proposed project site was Clay Station, which was along the Galt-Ione Amador Branch Line of the railroad system. Clay Station hosted a post office , store, and blacksmith shop by the later 1870s. The Chinese placer mined in the region of the proposed project site during the late 1800s.

The North Central Information Center (NCIC) of the California Historical Resources Information System located at California State University, Sacramento, was contacted in 2010, and provided the results of a record search dated March 29, 2010. Within a one-mile radius of the project site, 15 surveys were archived and 20 prehistoric or historic sites had been recorded.

Seven of the recorded sites are prehistor ic and are dispersed throughout the one-mile search radius. The historic sites are related to either placer mining or agriculture. The mining locations are prim arily south of the [s olar] project site.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-15 In February 2015, the NCIC was again contacted requesting records search for any surveys or site recordation si nce the 2010 record search. One survey southeast of the project site had been done in 2011, with no new prehistoric or historic records. A placer mining depression complex south of the project site near Clay East Road recorded in 2008 was identified and updated as a result of the 2011 survey. The Native American Heritage Commissi on was contacted in 2010 and replied that there were no known Sa cred Sites in the area.

On March 20, 2015 a pedestrian survey of the project site was undertaken. No cultural resources were located during the 2015 survey. Previous surveys of the area included a cultural resource survey of the proposed project site, plus a 250-foot bu ffer, conducted in 2010. This survey identified a small cluster of gold mini ng depressions located at the southern edge of the buffer area. These depressions were recorded and submitted to the North Central Information Center in Sacramento. No other cultural resources were located during the 2010 su rvey. Additionally, portions of the project site were surveyed in 1982 (approximately 20 acres within the northern half of the project site) and in 1994 (appr oximately 5 acres in the northernmost portion of the project site).

Neither of these survey discovered prehistoric or historic cultural resources. Visual and Scenic Resources

The ISFSI is located within the boundaries of the former RSNGS, a site that is generally characterized by industrial buildings, fences, parking lots, and

ornamental landscaping. The site is not considered to be a scenic vista. Viewsheds for motorists tr aveling east or west on Twin Cities Road (Highway 104) provide views of row crops (vineyards) on the northern side of Twin Cities Road; and open grazing land, small clus ters of trees, and structures associated with the former Rancho Se co Nuclear Generat ing Station (the cooling towers) to the south. Viewsheds for motorists traveling along Clay East Road primarily consist of open grazing lands and industrial facilities associated

with the Cosumnes Power Plant and the former Rancho Seco Nuclear

Generating Station. While the openness of the terrain and rows of grapevines offer scenic value, and the twin cooling towers from the former Rancho Seco Nuclear Generating Facility offer some distinctive scenic quality for visitors traveling in the vicinity of the proj ect site, general views lack an abundance of cohesive, scenic resources that would c ontribute to creating a viewpoint that provides expansive views of a highly valued landscape.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-16 E.3.10 Demography and Socioeconomics The original Rancho Seco ISFSI En vironmental Report, [E-4] provided population estimates based on 1989 data along with development plans for the nearby counties and cities. Sect ions E.3.11.1 thr ough E.3.11.3 below describe the current demographic and economic characteristics for the geographic areas of influence. The dem ographic data was obtained from the U.S. Census Bureau. State, county and ci ty specific population estimates were obtained using the Census Bureau's Qu ickfacts software. The data within a specified radius of the ISFSI was obtained using the Circular Area Profiling (CAP) system from the Missouri Census Data Center with their Block-based Inclusion Algorithm. For tracts (or census block groups) that are not entirely within the specified radius, the algorit hm uses block-level populations within the specified radius to determine an "

apportioning factor," which is applied to the tract or block group data to dete rmine the aggregate data. The coordinates of the ISFSI used with the CAP so ftware were 38.20.40 Latitude and 121.07.10 Longitude.

E.3.10.1 Demography The nearest major population centers to the ISFSI are shown in Table E-4.

The 2010 Census Population and the 2016 Estimate Population were obtained using the Census Bureau's Quickf acts software. The 2060 Projected Population estimates the population at the end of the ISFSI's period of extended operation, assuming the rate of increase from 2010 to 2016 remains constant.

Table E-5 provides the population esti mate within a 2-, 4-, 10-, and 50-mile radius of the ISFSI. The information was obtained using the Missouri Census Data Center's Beta Version caps16a cs (April 2016) using 2011-2015 data with the block-based apportioning algorithm to apportion block group data. E.3.10.2 Environmental Justice The original Environmental Report , [E-4] did not address environmental justice, so this section has been added to provide information on minority and low-income populations. Appendix C of NUREG-1748, [E-13] provides guidance on the methodology to identif y the locations of minority and low-income populations of interest. The guidance suggests that a 4-mile radius could reasonably be expected to contain t he area of potential effect and that the state and county are consider ed the appropriate geographic areas for comparative analysis. U.S. Census Bureau demographic data provide the necessary information on race, ethnicity, and poverty.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-17 The guidance in [E-13] defines minor ity categories as: American Indian or Alaskan Native; Asian; Native Hawaii an or other Pacific Islander; African American (not of Hispanic or Latino origin); some ot her race; and Hispanic or Latino ethnicity (of any race). There is also a "Multiracial" category. This includes individuals th at identify themselves as more than one race. Low-income is defined as being below the poverty level as defined by the U.S.

Census Bureau.

The guidance indicates that the area of assessment has a significant minority or low-income population if either of the following two conditions is met:

  • The minority or low-income population of the block groups in the area for assessment exceeds 50 percent of the total population.
  • The minority or low-income populati on percentage of the block groups in the area for assessment is significantly greater (typically at least 20 percentage points) than the minority or low-income population percentage in the geographic areas chosen for comparative analysis.

Table E-6 provides minority and low-income percentages for each of the geographic comparison areas (4-mile radius, state, and counties). The results of the analysis indicate that the 4-m ile radius does not have significant percentages of minority or low-income populations, as identified above. E.3.10.3 Socioeconomics During the PEO, the workforce at the Rancho Seco ISFSI will continue to consist of security personnel and an operations staff to conduct periodic monitoring and inspections. The size of the work force is not expected to significantly change for ISFSI operations during the PEO.

As a municipal utility, SMUD does not pay property taxes related to the Rancho Seco ISFSI property.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-18 E.4 Environmental Impacts The following sections discuss environm ental consequences associated with continued operations of the Rancho Seco ISFSI. SMUD considered the specific resource areas that have potential impacts associated with the ISFSI operations over the PEO. On September 19, 2014, the NRC published a revised rule in the Federal Register for 10 CFR 51.23, "Environment al Impacts of Continued Storage of Spent Nuclear Fuel Beyond the Licensed Li fe for Operations of a Reactor" (the "Continued Storage Rule"), Environmental Impacts of Continued Storage of Spent Nuclear Fuel Beyond the Licensed Life for Operations of a Reactor, [E-18]. The NRC rule codifies the generic impact determinations in NUREG-

2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, NUREG-2157, September 2014 (Accession Number ML 14196A105), [E-19]. Formerl y known as the Waste Confidence Decision and Rule, the revised rule adopts the generic impact determinations made in NUREG-2157, and codifies the NRC's generic determinations

regarding the environmental impacts of continued storage of spent fuel beyond a reactor's operating license (i.e., those im pacts that could occur as a result of the storage of spent fuel at a reactor, or away-fro m-reactor site, between the time a reactor's licensed operation ends and a permanent repository becomes available). The updated Continued St orage Rule and NUREG-2157 provide the National Environmental Policy Act analyses of human health and environmental impacts of continued storage of spent fuel beyond the licensed life of a reactor that are needed to suppor t renewal of the Rancho Seco ISFSI license. The analysis in NUREG-2157 concluded t hat the potential impacts of at-reactor storage during the short-term time frame (no more than 60 years after the expiration of the reactor's license to operate) would be small in Section 4.20 of [E-19]. Furthermore, the analysis in NUREG-2157 stated that disposal of the spent fuel in a DOE repository by the end of the short-term time frame is the most likely outcome (Reference E-19, Section 1.2). As described in the following sections, impacts from the proposed renewal of the Rancho Seco ISFSI license are primarily occupational and public health impacts associated with radiological exposure. Cumulative im pacts would occur if multiple sources for radiological exposure a ffect the same population.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-19 E.4.1 Impacts from Refu rbishment and Construction The Proposed Action does not include re furbishment or new construction.

Impacts for construction of the Rancho Seco ISFSI were addressed in the original Environmental Asse ssment, [E-5]. As described in Section E.1.2.2, no refurbishment is planned. Only ro utine monitoring and maintenance is expected over the proposed 40-year PEO. Therefore, there are no environmental impacts from refurbishment or construction beyond those analyzed in the original Environmental Assessment, [E-5]. E.4.2 Occupational and Public R adiological Health Impacts No liquid or gaseous effluents are rel eased to the environment from operation of the ISFSI. Therefore, only external radiation fr om the sealed dry storage canisters could affect workers or members of the public. The design and operational features of the NUHOMS system, along with the station's radiological protection progr am, mitigate radiological impacts as described in Section 7 of [E-12]. Potential occu pational and public ISFSI doses are addressed separately below. E.4.2.1 Occupational Dose As discussed in Section E.

1.2.1, all the fuel from RSNGS has been transferred to dry storage in the ISFSI. Therefore, it is not expected that any additional DSCs will need to be loaded. The occupational dose is, thus, limited to the

dose the staff receives while performi ng inspections and monitoring of the ISFSI. Section 7.4.2 of [E-12] discusses the dose to the staff while performing surveillances at the ISFSI. The annual dos e for HSM air inlet vent inspections is estimated to be 1.2 Rem. This value is derived by assuming that one inspector performs an inspection once every day, walking around the HSMs at a distance of 20 feet. T he amount of time required for the inspection is assumed to be 10 minutes, and it is furt her assumed that the inspector is exposed to a dose rate of 20 mrem/hr. E.4.2.2 Public Dose Table 7-4, footnote number 2 of [E-12]

presents a calculation of the annual dose from ISFSI external radiation to the nearest permanent resident as 0.16 mrem per year, which is below the 25 mrem/yr limit imposed by 10 CFR

72.104(a). The collective dose is calculated as if all the individuals within 2 miles of the site boundary live at t he location of the nearest permanent resident. Using the 2-mile radius popul ation of 256 persons (determined in Section E.3.11), the resulting colle ctive dose is 0.041 person-rem. The assumption of locating all the resi dents at the loca tion of the nearest permanent resident is conservative.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-20 E.4.3 Other Operational Impacts The routine operation of the ISFSI involves dry storage of spent nuclear fuel in sealed containers. With the excepti on of inspections and maintenance, storage operation is passive. There are no liquid or gaseous effluents.

Accordingly, no impacts are expected other than those from radiation as described in Section E.4.3. NUREG-1748 [E-13] identifies the types of environmental impacts to be analyzed for a materials license Environmental Report. Each identified discipline or resource area is briefly addressed below.

Conclusions drawn from the original NRC ISFSI environmental assessment (Reference E-5) are adopted, where available and still appropriate. Land Use: The land occupied by the IS FSI was committed when the ISFSI was constructed. It is located within the developed Rancho Seco Nuclear Plant site area. No additional land use impacts are expected from continued operation of the ISFSI beyond those describ ed in the original environmental assessment, [E-5] Section 6.2.3.1.

Transportation: No significant changes in staffing are anticipated to manage the ISFSI during the PEO, and no new radwaste shipments or related activities are expected. Therefore, no impacts to transportation are expected.

Geology and Soils: Impacts to geology and soils occurred when the ISFSI was constructed. There are no construction activities associated with renewing the ISFSI license. Therefore, no impacts to the geology or soil are expected.

Water Resources: The ISFSI does not require water for its operation, and does not discharge effluents to surface or groundwater. Based on the size of the ISFSI work force, mini mal sanitary waste is generated. It is disposed in a septic system. No impact to water resources is expected from continued

operation beyond those described in t he original environmental assessment, [E-5] Section 6.2.3.2. Ecological Resources: Any ecological impacts occurred when the ISFSI was constructed. The original environm ental assessment asserted that ISFSI operation would have minimal impact on loca l wildlife, [E-5] Section 6.2.3.1.

Fences provided for other purposes prevent wildlife access to the ISFSI. No ecological impact is expected fr om continued operation beyond those described in the original environmental assessment, [E-5] Section 6.2.3.1.

Air Quality: The ISFSI does not releas e airborne emissions. Any air quality impacts occurred when the ISFSI was c onstructed, [E-5] Section 6.1.3.

Therefore, no impacts on air qual ity are expected during the PEO.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-21 Noise: Storage of irradiated fuel and associated materials at the ISFSI involves use of a passive system that does not generate noise. Audible noise directly attributable to operation of the ISFSI is generally limited to occasional vehicle traffic to and from the ISFSI during routine operations and maintenance activities. No noise impact is expected from continued operation beyond those described in the original environmental assessment, [E-5]

Section 6.2.3.3. Historical and Cultural Resources: C ontinued operation does not involve any land disturbance. Therefore, no historical or cultural resource impact is expected from continued operation of the ISFSI.

Visual and Scenic: Structures at the IS FSI have limited or no visibility from locations outside of the controlled area, because of the view obstruction created by terrain or by other existing st ructures on the plant site. The visible evidence of ISFSI operation that could be observed by public viewers is limited to occasional vehicle (passenger cars and light-duty trucks) traffic to and from the ISFSI during routine operations and maintenance activities. Therefore, no adverse visual impact is expected from continued operation of the Rancho Seco ISFSI. Socioeconomics: Any changes to the local economy as a result of the construction and operation of the IS FSI occurred when the ISFSI was constructed. NRC concluded the Socioeconomic impacts associated with the construction were expected to be minimal, [E-5] Section 6.1.4. Therefore, no socioeconomic impacts are expected fr om continued operat ion beyond those described in the original environmental assessment.

Environmental Justice: Based on re view of minority and low-income populations near the Rancho Seco ISFSI, no minority or low-income populations are located in a way to be disproportionately affected by Rancho Seco ISFSI license renewal. In addition, the analyses of impacts for all resource areas indicate that the impact of RSNGS ISFSI license renewal would be small. Therefore, based on the analysis in this Supplemental Environmental Report, SMUD cons iders that there would be no disproportionately high and adverse impacts to any minority or low-income population from the cont inued operation of the Rancho Seco ISFSI.

Public and Occupational Health: Radiological public and occ upational health is addressed in Section E.4.3. As discu ssed above, ISFSI storage operation is passive with no liquid or gaseous effluent s, and therefore, no impact to non-radiological public health. Non-radiolog ical occupational health effects at the Rancho Seco ISFSI are managed through SMUD's safety and health program.

No adverse health impact is expected fr om continued operation of the ISFSI.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-22 Waste Management: The original envir onmental assessment stated that operation of the ISFSI would not result in the generati on of gaseous, liquid, or solid radioactive wastes Section 5.3 of, [E-5]. No non-radioactive wastes are associated with the operation of the ISFSI. No addition al sanitary or other wastes are generated as a result of t he operation of the ISFSI. Therefore, no waste management impacts expected from continued ISFSI operation. E.4.4 Accident Impacts NRC regulation 10 CFR 72.106(b) prescr ibes dose limits at the nearest boundary of the controlled area from a design basis accident. The SAR for the

Rancho Seco ISFSI Volume I, Section 8.

2 of [E-12] examines five design basis accidents: 1. Accident cask drop 2. DSC leakage

3. Accident pressurization
4. Earthquake
5. Fire The only event with radiological consequences is the postulated DSC leakage event. While the DSC shell is designed as a pressure retaining containment

boundary to prevent leakage of contaminat ed materials, i.e., DSC leakage is considered a non-credible event, the postulated DSC leakage event provides

the bounding case for radiological c onsequences, and demonstrates that the radiation dose from an accident or natural phenomena event does not exceed the limits in 10 CFR 72.106(b).

As specified in Interim Staff Guidance No. 5 (ISG-5) Revision 1, U.S. Nuclear Regulatory Commission, Spent Fuel Project Office, Interim Staff Guidance - 5, Revision 1, "Confinement Evaluation," [E-20], an accident release is postulated assuming all of the fuel rods in a single DSC are breached and leak to the environment at a specified rate. The whole body dose at the Rancho Seco ISFSI controlled area boundary is computed to be 0.195 rem, as reported in Section 8.2.2.3 of [E-12], which is within the 10 CFR 72.106 limit of 5 rem. All other organ doses are also well below the remaining 10 CFR 72.106 limits.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-23 E.5 Mitigation Measures As presented in Section E.4, the only impact of the proposed action is radiological dose to workers and t he public. SMUD adopted measures to mitigate for those potential impacts in conjunction with construction and operation of the ISFSI under the original license, as discussed below. SMUD will continue to implement t hese measures th roughout the PEO. Workers in the ISFSI Radiologically Controlled Area wear personnel radiation monitoring devices and dose is recor ded and tracked for analysis. Dosimetry is used to monitor direct radiation around the ISFSI. If m easured doses were to significantly exceed historical levels, SMUD would perform analyses to determine the cause and would estab lish mitigation measures. The SMUD Radiological Protection As Low As Reasonably Achievable (ALARA) program is an effective method for ensuring that doses to workers and the public are as low as can be achieved by reasonable, cost-effective methods. In addition to

monitoring the radiation environment around the ISFSI, inspection and maintenance activities of the ISFSI equi pment are performed to ensure that no degradation of equipment could lead to increased radiation levels.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-24 E.6 Environmental Measurement and Monitoring The RSNGS structures, systems, and components have been decommissioned and the ISFSI is a passive operation that does not release radioactive effluents into the environment. The only environmental monitoring performed is related to direct radiation. SMUD has placed dosimetry around the ISFSI to monitor direct radiation.

There are no prescribed physical, chemical, or ecological monitoring requirements, beyond those described abov e, to support operations of the ISFSI. The proposed action does not in volve any changes to the ISFSI Technical Specifications, refurbishment of the ISFSI, or changes in ISFSI operation that would impact the effect iveness or validity of the radiation measurement program. Therefore, t he current monitoring program would continue through the PEO, and no additiona l environmental measurements or monitoring would be required.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-25 E.7 Summary of Environmental Consequences This Supplemental Environmental Report describes the proposed action, which is renewal of the license of the Rancho Seco ISFSI for 40 years, and the associated impacts. Table E-7 identifies the non-radiological and radiological environmental impacts of Rancho Seco ISFSI license renewal. Based on this

evaluation, Rancho Seco ISFSI license renewal would involve no significant environmental impact. E.7.1 Unavoidable Adverse Impacts As presented in Section E.4, the only adverse impacts of the proposed action are radiological dose to workers and radiological dose to the public. Although SMUD employs inspections, maintenance, monitoring, and ALARA principles (Section E.5) to mitigate these impacts, some impact is unavoidable. However, as indicated in Section E.4, the impac t of the extended oper ation of the ISFSI to both occupational workers and member s of the public is within regulatory limits (e.g., radiation protecti on standards of 10 CFR 72.104(a)). E.7.2 Irreversible and Irretrievable Commitment of Resources The continued operation of the Rancho Seco ISFSI for the PEO would result in no additional irreversible or irretrievable resource commitments beyond those committed during the initial licensing (as discussed in References E-4 and E-5) which cannot be recovered or recycled, or those that are consumed or reduced to unrecoverable forms. E.7.3 Short-Term Uses, Maintenance, and E nhancement of Long-Term Productivity The current balance between short-term use and long-term productivity of the environment would be unchanged by the renew al of the specific license for the Rancho Seco ISFSI. The ISFSI is a temporary storage facility. Once the spent nuclear fuel is moved to a permanent repository, the DSCs, Transfer Cask, HSMs, concrete pads, and fencing may be removed. The land may then be used for another purpose. Extended operat ion of the ISFSl would postpone restoration of the site and its potential availability for uses other than fuel storage for up to an additional 40 years.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-26 E.8 References E-1 Letter from Sacramento Municipal Utility District to NRC, "Supplement to Rancho Seco Environmental Report- Post Operating License Stage," Letter Number DAGM/NUC 91-0136, Docket No. 50-312, October 21, 1991 (a copy maybe found as an attachment in Accession Number ML063200069). E-2 NUREG-0586, "Final Generic En vironmental Impact Statement on decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," 1988. E-3 Letter from Sacramento Municipal Utility District to NRC, "Rancho Seco Independent Spent Fuel Storage License Installation Application and Safety Analysis Report," Docket No. 72-11, October 4, 1991. E-4 Letter from Sacramento Municipal Utility District to NRC, "Revision 1 to the Rancho Seco Independent Spent Fuel St orage Installation Environmental Report," Letter Number DAGM/NUC 93-088, Docket No. 72-11, June 16, 1993. E-5 U.S. Nuclear Regulatory Commission, "E nvironmental Assessment related to the Construction and Operation of the R ancho Seco Independent Spent Fuel Storage Installation," Docket 72-11, Offi ce of Nuclear Material Safety and Safeguards, Washington, D.C., Augus t 1994 (Accession Number ML123480187). E-6 Letter from Sacramento Municipal Utility District to NRC "Rancho Seco Independent Spent Fuel Stor age Installation Request for Exemption From 10 CFR 72.44(d)(3) and Proposed License Am endment No. 1," July 19, 2004 (Accession Number ML042150015). E-7 NRC, "Exemption From 10 CFR 72.44(d)(3) for Dry Spent Fuel Storage Activities with Conforming Amendment (TAC No

s. L23752 and L23753)," March 21, 2005 (Accession Number ML050810333). E-8 Federal Register, 70 FR 1911, "Sacramento Municipal Utilit y District; Rancho Seco Independent Spent Fuel Storage Inst allation; Issuance of Environmental Assessment and Finding of No Significant Impact Regarding a Proposed Exemption and Conforming Am endment," January 11, 2005. E-9 U.S. Nuclear Regulatory Commission, "Issuance of Environmental Assessment and Finding of No Significant Impact of the Rancho Seco Independent Spent Fuel Storage Installati on (ISFSI) Request for Prosed License Amendment (TAC.

No. L23757)," March 24, 2005 (A ccession Number ML050830420). E-10 Letter from Sacramento Municipal Utility District to NRC "Rancho Seco Independent Spent Fuel Stor age Installation Propos ed License Amendment No.

3," November 5, 2008 (Accession Number ML083190249). E-11 NRC, "Applicability of the General Categorical Exclusi on in 10 CFR 51.22(c)(11) to Proposed Amendment 3 to SNM-2510 for the Rancho Seco Independent Spent Fuel Storage Installation,"

April 30, 2009 (Accession Number ML091210088).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-27 E-12 Rancho Seco Independent Spent Fuel Stor age Installation Final Safety Analysis Report, Revision 6, August 2016. E-13 Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, NUREG-1748, Offi ce of Nuclear Material Safety and Safeguards, Washington, D.C., August 2003 (Accession Number ML032450279). E-14 Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel, NUREG-1927, Revision 1, Office of Nuclear Material Safety and Safeguards, Washington, D.C., June 2016 (Accession Number ML16179A148). E-15 Letter from Waste Control Specialists LLC to NRC, "License Application to Construct and Operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas, Docket 72-1050," April 28, 2016 (Accession

Number ML16132A533). E-16 Letter from Waste Control Specialists LLC to NRC, "Revision 1, License Application to Construct and Operate a C onsolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas, Docket 72-1050," March 16, 2017 (Accession Number ML17082A007). E-17 Letter from Holtec International to NRC, "Holtec International HI-STORE CIS (Consolidated Interim Storage Facility) License Application," March 30, 2017 (Accession Number ML17115A418). E-18 10 CFR 51.23, "Environmental Impacts of Continued Storage of Spent Nuclear Fuel Beyond the Licensed Life for Operat ions of a Reactor," September 19, 2014 (79 FR 56238-56264). E-19 Generic Environmental Impact Stat ement for Continued Storage of Spent Nuclear Fuel, NUREG-2157, September 2014 (Accession Number ML

14196A105). E-20 U.S. Nuclear Regulatory Commission, Spent Fuel Project Office, Interim Staff Guidance - 5, Revision 1, "Confinement Evaluation." E-21 Letter from Sacramento Municipal Utility District to NRC, "Rancho Seco Independent Spent Fuel Stor age Installation Propos ed License Amendment No.

2 for the Storage of Gr eater than Class C Waste," July 29, 2004 (Accession Number ML042460723). E-22 Letter from Sacramento Municipal Utility District to NRC "Rancho Seco Independent Spent Fuel Stor age Installation Propos ed License Amendment No.

4," November 24, 2017 (Accession Number ML17290A008).

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-28 Table E-1 Cross-Reference Table for En vironmental Requirements of 10 CFR 51 Regulatory Requirement Section/Title of Supplemental ER 10 CFR 51.60(a) Entire Supplemental ER 10 CFR 51.45(a) Entire Supplemental ER 10 CFR 51.45(b), description of proposed action E.1.2, Proposed Action 10 CFR 51.45(b), statement of purposes E.1.1, Purpose and Need for Proposed Action 10 CFR 51.45(b), affected environment E.3, Affected Environment 10 CFR 51.45(b)(1), impact of proposed action on the environment E.4, Environmental Impacts 10 CFR 51.45(b)(2), adverse environmental effects that cannot be avoided E.7.1, Unavoidable Adverse Impacts 10 CFR 51.45(b)(3), alternatives to the proposed action E.2, Alternatives 10 CFR 51.45(b)(4), short-term use versus long-term productivity of environment E.7.3 Short-Term Uses, Maintenance, and Enhancement of Long-Term Productivity 10 CFR 51.45(b)(5), irreversible and irretrievable commitments of resources E.7.2, Irreversible and Irretrievable Commitment of Resources 10 CFR 51.45(c), environmental effects, impact of alternatives, and alternatives for reducing or avoiding effects E.2, Alternatives; E.3, Affected Environment; E.4, Environmental Impacts; and

E.5, Mitigation Measures 10 CFR 51.45(d), status of compliance E.1.4, Applicable Regulatory Requirements, Permits, and Required Consultations

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-29 Table E-2 Regulatory Requirements, Pe rmits, and Consultations Agency Authority Requirement Remarks U.S. Nuclear Regulatory Commission Atomic Energy Act (42 USC 2011 et. Seq.)

ISFSI License Renewal Supplemental Environmental Report submitted in support of the ISFSI license renewal application. U.S. Fish and Wildlife Service Endangered Species Act (ESA) Section 7 (16 USC 1536) Consultation Requires the federal agency issuing a license to consult with USFWS if the action may affect species listed under the ESA. California Office of Historic Preservation National Historic Preservation Act Section 106 (16 USC 470f) Consultation Requires the federal agency issuing a license to consult with State Historic Preservation Officer if the action may affect historic properties.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-30 Table E-3 Special Status Species Common Name Scientific Name Federal Status State Status Plants Dwarf Downingia Downingia Pusilla None None Legenere Legenere Limosa None None Pincushion Navarretia Navarretia Myersii ssp. Myersii None None Sacramento Orcutt Grass Orcuttia Viscida Endangered Endangered Invertebrates California Linderiella Linderiella Occidentalis None None Midvalley Fairy Shrimp Branchinecta Mesovallensis None None Vernal Pool Fairy Shrimp Branchinecta Lynchi Threatened None Vernal Pool Tadpole Shrimp Lepidurus Packardi Endangered None Amphibians California Tiger Salamander Ambystoma Californiense Threatened Threatened Western Spadefoot Spea Hammondii None None Reptiles Giant Gartersnake Thamnophis Gigas Threatened Threatened Western Pond Turtle Emys Marmorata None None Birds Bald Eagle Haliaeetus Leucocephalus Delisted Endangered Burrowing Owl Athene Cunicularia None None Swainson's Hawk Buteo Swainsoni None Threatened Tricolored Blackbird Agelaius Tricolor None Candidate Endangered

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-31 Table E-4 Nearest Major Population Center Demographics City Distance from ISFSI Direction From ISFSI 2010 Census Population 2016 Estimate Population % Change 2010 to 2016 2060 Projected Population Lodi 17 miles South-Southwest 291,707 307,072 5.3% 447,562 Sacramento 25 miles Northwest 466,488 495,234 6.2% 768,123 Stockton 26 miles South-Southwest 291,707 307,072 5.3% 447,562

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-32 Table E-5 Estimated 2015 Populations Radius (miles) 2015 Data 2 256 4 943 10 24,087 50 3,777,755

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-33 Table E-6 Minority and Low-Income Demographics Within 4 mile radius (1) State of California(2) Amador County (2) San Joaquin County (2) Sacramento County (2) Total population 943 39,250,017 37,383 733,709 1,514,460 American Indian

and Alaska Native 0% 1.7% 2.4% 2.0% 1.6% Asian 3.3% 14.8% 1.5% 16.3% 16.2% Native Hawaiian and Other Pacific Islander 0% 0.5% 0.3% 0.8% 1.3%

African American 0.4% 6.5% 2.1% 8.2% 10.9% Hispanic or Latino 17.9% 38.9% 13.6% 41.2% 23.0% Two or More Races 3.9% 3.8% 3.3% 5.2% 6.1% Persons below Poverty 5.3% 14.3% 13.1% 17.5% 16.9% (1) Obtained using the Missouri Census Data Center's Beta Version caps16acs (April 2016) using 2011-2015 Data with the block-based apportioning algorithm to apportion block group data. (2) Obtained using U.S. Census Bureau QuickFacts, population estimates, July 1, 2016.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-34 Table E-7 Environmental Impacts of Rancho Seco ISFSI License Renewal Resource Environmental Impacts Land Use NONE Transportation 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 Environmental Justice SMALL - Impacts on all other resources are small Nonradiological Occupational Health Effects SMALL. Any non-radiological health effects would be the result of normal workplace hazards (i.e.,

moving heavy objects, etc.) Occupational Dose from Normal Operations SMALL. Workers conducting inspection and maintenance operations would receive an annual collective dose of 1.2 person-rem. Dose to the Public from Normal Operations SMALL. The maximum dose to the nearest potential resident is 0.16 mrem per year. The total collective off-site dose for persons within a 2-mile radius is calculated to be 0.041 person-rem/year. Dose to the Public from Accidents SMALL. Even a non-credible DSC leakage event results in a site boundary accident dose rates below 5 rem to the whole body or any organ as specified in 10 CFR 72.106(b). Waste Management NONE

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-35 Figure E-1 Location of Rancho Seco Site Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-36 Figure E-2 Rancho Seco Owner-Controlled Area

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix E - Environmental Report Supplement for the Rancho Seco ISFSI Page E-37 Figure E-3 Rancho Seco ISFSI Site

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix F - ISFSI Decommissioning Funding Plan Update Page F-i APPENDIX F ISFSI DECOMMISSIONING FUNDING PLAN UPDATE CONTENTS F.1 Discussion / Status Update ............................................................................ F-1 F.2 References ....................................................................................................... F-3

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix F - ISFSI Decommissioning Funding Plan Update Page F-1 F.1 Discussion / Status Update Pursuant to 10 CFR 72.30(c), at the time of license r enewal and at least every three years, the Decommissioning Funding Plan must be updated with

adjustments, as necessary, to account for changes in costs and the extent of contamination. The most recent report on the Decommissioning Funding Status was provided by Sacramento M unicipal Utility District (SMUD) on March 22, 2017, Rancho Seco Report on Decommissioning Funding Status, [F-1]. Rancho Seco has been in the process of decommissioning since

February 1997, after being shutdown permanently in June 1989. An "External Sinking Decommissioning Trust Fund" was set up and continues to be

maintained by Wells Fargo Bank, on behalf of SMUD. Contributions were made to this Trust Fund through 2008, at which time it was considered to be

fully funded. No future contributions to the Trust Fund are planned; however, SMUD will continue to monitor and update the costs and provide contributions if the estimate to complete decommi ssioning exceeds the available funds.

The 2016 Decommissioning Cost Estimate included in [F-1] indicates that the remaining projected cost to complete decommissioning of Rancho Seco (both Part 50 and Part 72 licenses) is $5.82 million. As noted in the 2016

Decommissioning Cost Estimate, independent spent fuel storage installation (ISFSI) decommissioning costs are mi nor compared to the costs of decommissioning the reactor facility. Having completed Phase II

decommissioning in 2017, SMUD requested termination of its Part 50 license on September 21, 2017, Termination of the Rancho Seco 10 CFR Part 50 License, Number DPR-54, [F-2].

Updated Information Required by 10 CFR 72.30(c)

The Decommissioning Funding Plan updat e required by 10 CFR 72.30(c) must consider the effect of the follo wing events on decommissioning costs:

  • Spills of radioactive material produc ing additional residual radioactivity in onsite subsurface material
  • Facility modifications
  • Actual remediation costs that ex ceed the previous cost estimate Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix F - ISFSI Decommissioning Funding Plan Update Page F-2 Changes associated with the first three bulleted events are not anticipated at Rancho Seco. Neither liquid spills of substances containing radioactive material, nor those that may come in contact with radioactive material are considered credible at this stage of decommissioning, since the remaining radioactive material is in solid form and not dispersible. Because decommissioning tasks are only associat ed with dismantling any remaining facilities, there are no additional significant facility modifications expected. In addition, no change in authorized possession lim its for spent fuel is anticipated until the final Part 72 license termination, which occurs after the spent fuel is transferred to the U.S. Depar tment of Energy and shipped offsite for disposal. Since the 2016 Decommissioning Cost Es timate last provided [F-1], there have been no changes in the expected remaining remediation costs. No additional decommissioning costs will be incurred as a result of the implementation of aging m anagement programs at the ISFSI. In addition, the increase in the possession limits aut horized by Amendment 4 for one radioactive byproduct Sr-90 source (trans ferred from the Part 50 license to the Part 72 license) will have no impact on the total decommissioning costs. The only change in the decommissioning estimate is an inflationary adjustment for 2017. With available funds of $8.41 millio n in the Decommissioning Trust Fund as of December 31, 2017, the rema ining costs projected to complete decommissioning of $5.82 million can be paid from the available Trust Fund balance.

Rancho Seco ISFSI License Renewal Application Revision 1 / June 2018 Appendix F - ISFSI Decommissioning Funding Plan Update Page F-3 F.2 References F-1 Sacramento Municipal Utility District (SMUD), "Rancho Seco Report on Decommissioning Funding Status," DPG 17-051, March 22, 2017 (Dockets 50-312 and 72-11). F-2 Sacramento Municipal Utility District (SMUD), "Termination of the Rancho Seco 10 CFR Part 50 License, Number DP R-54," DPG 17-164, September 21, 2017 (Docket 50-312 ).