Text

Enclosure 2: Draft Response to RAI NP-15-x with SAR Markups
	ML19095B552
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	04/03/2019
From:	; Consolidated Interim Storage Facility
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML19095B557	List: ML19095B551; ML19095B552; ML19095B553;
References
	E-53941
	Download: ML19095B552 (70)
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Enclosure 2 Draft Response to RAI NP-15-x with SAR M*arkups

RAls and Responses Enclosure X to E-XXXX Safety Analysis Report (SAR}, Chapter 15, "Materials Evaluation" RAJ NP-15-1:

~

Clarify the following statements in WCS CISF SAR Appendix A, B, C and D, S~.4.6, "Material Selection."

1. Provide an applicable reference for the following statement:

The DSC and cask materials are resistant to corrosion and ar:

galvanic reactions. Studies under severe marine environm.

shell materials used in the DSC shells are expected to during an 80-year exposure.

2. Clarify the range of environmental conditions exp internals referenced in the following statement:

The DSC internals are enveloped in a dry, he/ium-inerte all postulated environmental condition.

The NRC staff note t t

WCS CISF applica G

UFSAR indicates a service life of 50 years for the DSCs, TCs, mine compliancewith 10 CFR 72.24(c).

Qreparatio

@li e CoC 1029 application, TN Americas :CEGI was requested by the lead

, epar a h culation describing the expected life of the various NUHOMS sed for use at San Onofre Nuclear Generating Station. This calculation shows a life expectancy of various stainless steels for the DSC shell that is 00 years for the worst case assumed marine environment (Kure Beach, NC data).

"Suitability of Materials for a Dry Storage Facility for 100 Years Service in a Marine Atmosphere Environment" also provides evaluations for the materials used for HSMs.

Page 41 of 119

RAls and Responses Enclosure X to E-XXXX if he evaluation* prepared in 2002.:. '"Suitability :of Materials for**a* *Bry Storag~: Facility for 1 Od~

r:ears)Seryic~ irt~. M.~fi_mtAtmosBhere JSnvironment" SCE:-Ot.,.0.1 t0-01, Revision.1 an*d *a CJ>BYJ§ attached. toth1s :RAJ res~

The differences in the reported life expectancy between the Rancho Seco Site lie general licenses for CoC 1004 and Coe 1029 can be explained by the time fra was written and the purpose for each.

The Rancho Seco Site License application was written in the early 199 the initial NRC approved issue of CoC 1004. As a Site Specific lice were for a dry, non-marine site with very little moisture. Based on th owledge the early 1990s, a life expectancy of greater than 50 years was to justify and far the anticipated time required to store the spent fuel before it be removed from sit DOE. This is in contrast for general license applications s s CoC 1004 and CoC 102 which can be used at any site in the U.S. varying from e site sue s San Onofre, California, located within 500 ft of the Pacific Ocean, mi-arid sit as Palo Verde, located outside Phoenix, Arizona.

Under these very variable environments, a calculation of Ii cy for any component in the NUHOMS system would have to be based on a set of e ntal assumptions that would not be applicable to any specific

o, with current ge regarding corrosion and crack propagation rates vs environ en shown th "fe expectancy of the most susceptible component of the NU e DSC, a exceeds the 60 years accepted by the NRC in the Licens f CoC

4. Based on the Time Limited Aging Analysis (TLLA) and tH ent Reviews (AMR) and Aging Management Programs (AMP), the o have a much greater life expectancy than curren

d.

Americas p.::~ was requested by the lead lation describing the expected life of the osed for us an Onofre Nuclear Generating Station.

life. ~pectancy of the 5/8" tbick*316Lstainl~ss1 t

j,voi;§'tcas'e asst1mea,m~rine:renvii:t>nm~ht.l be transported from their present storage sites, and the life expectancy at the WCS facility will vary depending on the conditions at the parent nto service.

Page 42 of 119

RAls and Responses Enclosure X to E-XXXX M. this time, there are no plans for neutralizing any salt deposits that might result in ci,loride induced stress corrosion cracking (CISCC) present on the DSC shells due to storage at the parent site upon receipt at the WCS facility. As such, the life expectancy of each DSC for storage at the parent facility plus the WCS facility is estimated on the assumption th t the original storage conditions will continue after receipt of the DSC in Texas. As the 11s SC is not expected to arrive at the WCS facility until 20;30, this means that some OS

1 have spent almost ~-Q years at the parent site before being~-shlpped. This will result in a timated life expectancy from receipt at the WCS facility varying from several decades, a"JB,,.,ximately 80 years depending on when and from where the DSCs are received.

lmpact:

SAR Sections A3.4.6, 8.3.4.6, C.3.4.6, response.

Page 43 of 119

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim A.3.4.6 Material Selection Materials are selected based on their corrosion resistance, susceptibility to stress corrosion cracking, embrittlement properties, and the environment in whi they operate during normal, off normal and accident conditions. The confi boundary for the DSC materials meet the requirements of ASME B Vessel Code,Section III, Article NB-2000 and the specification Section II, Part D [A.3-7], with the listing of ASME Code exc and the cask provided in Appendix A "ASME Code Exce and FO, FC, and FF DSC's" of the "Rancho Seco Indep Installation Safety Analysis Report [A.3-1]. The D resistant to corrosion and are not susceptible to ot under severe marine environments have demon the DSC shells are expected to demonstrate exposure. The DSC internals are envelope are designed to withstand the loads from all conditions. The HSM is a reinforced concrete support structure that is fabricated to ACI and AI durability well beyond a desi

of 80 years.

A.3.4.7 Operating Procedures ring an 80-year ed environment and and accident ith an internal DSC 187 Cask System in e

e storage pad, insertion Page A.3-9 trieval and shipping. Throughout Chapter e steps where special notice is needed to

e DSC, or protect the public and/or ITS k System.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim For the DSCs, a combination of fixed poison in the basket and geometry are relied on to maintain criticality control. The structural analysis shows that there is no deformation of the basket under accident conditions that would increase reactivity.

B.3.4.6 Material Selection B.3.4.7 Materials are selected based on their corrosion resistance, suscep

corrosion cracking, embrittlement properties, and the environ operate during normal, off normal and accident conditions.

boundary for the DSC materials meet the requirements of Vessel Code,Section III, Article NB-2000 and the sp ation requireme Section II, Part D [B.3-8] with the listing of ASM Alternatives for the provided in Table 3.1-14 of the "Advanced Horizontal Modular Sto System Safety Analysis Report" [B.3-1]. Th and cask corrosion and are not susceptible to other marine environments have demonstrated tha shells are expected to demonstrate minimal co The DSC internals are enveloped in a dry, helium-designed to withstand the loa m all normal, off-The AHSM is a reinforced c onent with an that is fabricated to ACI and

ments. B an 80-year exposure.

vironment and are and accident conditions.

1 DSC support structure durability well The seque System*

insert*

r the Standardized Advanced NUHOMS d transfer of the DSCs to the storage pad, ions, and retrieval and shipping.

T s are provided at the steps where special ect the contents of the DSC, or protect the andardized ~dvanced NUHOMS System.

Page B.3-9

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.3.4.6 Material Selection Materials are selected based on their corrosion resistance, susceptibility to stress corrosion cracking, embrittlement properties, and the environment in whi operate during normal, off normal and accident conditions. The confi boundary for the DSC materials meet the requirements of ASME B

Vessel Code,Section III, Article NB-2000 and the specification Section II, Part D [C.3-7], with the listing of ASME Code alte provided in Tables K.3.1-2 and K.3.1-3 of the "Standardiz Modular Storage System Safety Analysis Report" [C.3-applicable to the MP197HB Cask are provided in Ap

[C.3-10]. The DSC and cask materials are resistan susceptible to other galvanic reactions. Studies have demonstrated that the shell materials us demonstrate minimal corrosion during an enveloped in a dry, helium-inerted environm loads from all normal, off-normal and accident concrete component with an internal DSC support and AISC Code requirements.

have durability years.

C.3.4.7 Operating Procedures

, -61BT System in Chapter s to the storage pad, insertion into the and shipping. Throughout Chapter 5, steps where special notice is needed to e DSC, or protect the public and/or ITS Page C.3-9

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim D.3.4.6 Material Selection Materials are selected based on their corrosion resistance, susceptibility to stress corrosion cracking, embrittlement properties, and the environment in whi they operate during normal, off normal and accident conditions. The confi boundary for the DSC materials meet the requirements of ASME B

d Pressure Vessel Code, Section Ill, Article NB-2000 and the specification N," ments of Section II, Part D [D.3-7], with the listing of ASME Code alte,

,, the DSCs provided in Tables T.3.1-2 and T.3.1-3 of the "Standardize Modular Storage System Safety Analysis Report" [D.3-applicable to the MP197HB Cask are provided in Ap

[D.3-10]. The DSC and cask materials are resista rrosion and are not susceptible to other galvanic reactions. Studies Iil,. severe marine environmen have demonstrated that the shell materials us, *,,

e DSC sheJ are expected to demonstrate minimal corrosion during an

- e r exposure SC internals are enveloped in a dry, helium-inerted environm, a, are. :, *. ed to withstand the loads from all normal, off-normal and accident, il,,,

concrete component with an internal DSC support,

and AISC Code requirements.

have durability years.

D.3.4.7 Operating Procedures i, NUH

i~ -61BTH Type 1 System in the DSCs to the storage pad, insertion retrieval and shipping. Throughout Chapter e steps where special notice is needed to e DSC, or protect the public and/or ITS

, 1 System.

PageD.3-9

RAls and Responses Enclosure X to E-XXXX RAI NP-15-2:

Provide the following for the MP-187 system:

1. Drawings or a table that indicates the safety classification of the MP187 syst lil'il systems, and components (SSCs).

None of the drawings for the MP-187 system includes a safety clas components of the DSCs or the MP-187. Drawings for the MP-18,

are in the Rancho Seco SAR part 2 pages 813-830 (Docket N.

or GTCC canister is included. The Model 80 HSM is in App No HSM drawings are included in either the Rancho Sec

2. The complete set of drawings for the greater-than-C at Rancho Seco.

The internal structure and contents of the Rancho S the drawings in the WCS CISF SAR Appendix H. In a and standards for the design and construction of the Ran including code alternatives.

Response to RAI NP-15-2:

1. ISP has updated S to SAR Appendix Page 44 of 119

RAls and Responses Enclosure X to E-XXXX

2. The applicable drawings of the internal structur:e and contents are TN Americas drawings 11221-1000 Revision 1 and 11221-1002 Revision 0. The internal structure and contents are not-important-to-safety as the internal structure was used to facilitate loading, keep occupational exposures PJ...ARA during the loading and sealing of the canister a SMUD, and to enable efficient draining and vacuum drying of the canister. D.r:~'{J1h,9 t1df~1~ill2~~a;;r{,QQ~M~e~i~J.Ciir\\ii<lll1$re::atta~hed'tr/J:.1t~i\\:l'f{~,.r~s:Ptis Per note 2 on Drawing 13302-1005 Revision 0, "fabrication includi procedures, welders and welding shall be performed in accorda,

the gimi ments of AWS D1.1-98, AWS D1.6-99 (as applicable) or ASME Code S ct1 n IX."

The design report (Drawng 13302-0102 Revision canister specifically states that "[t]he design analysis, Subsection NB are not applicable." Therefore, no code canister.

Impact:

SAR Appendix A3.1 and Table 3-4 have Tables A3-3 through A3-6 have also bee Page 45 of 119

. I

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 3-4 References for WCS CISF Storage System Components Important-to-Safety Storage System NUHOMS - MP187 Cask System Section in WCS CISF SAR Appendix A.3.1 with Table A.3-2, Table A.3-3, Table A.3-4, Table A.3-5, and Table A.3-6 Standardized Advanced Appendix B.3.1 Table NUHOMS System B.3-2 Standardized NUHOMS-61-BT System Standardized NUHOMS-61BTH Type 1 System Appendix C.3.1 Table C.3-2 Appendix G.3.1.2.1 Section in Specific License or Certificate SAR Section 3.4 and Table 3-11 ofRef. [A.3-1]

Drawings o aining ITS It n T.2.3 and Table Drawings listed in

-15 ofRef. [D.3-1]

AppendixD.4.6 and Section 2.3.1 and Table 2.3-1 ofRef. [E.4-1]

Section 2.3.1 and Table 2.3-2 of Ref. [E.4-1]

Section 2.A.3.1 and Table 2.A.3-1 of Ref.

[E.4-1]

Section 2.3.1 and Table 2.3-1 ofRef. [F.4-1]

Section 2.4.1 and Table 2.4-1 of Ref. [F.4.-1]

C.4.6 numbers 8 through 12 inclusive and Appendix A.4.6 numbers 5 through 13 inclusive Drawings listed in Appendix E.4.4 Drawings listed in Appendix E.4.4 Drawings listed in Appendix E.4.4 Drawings listed in Appendix F.4.3 Drawings listed in Appendix G.4.3 Page 3-33

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim A.3.1 SSCs Important to Safety The classifications of the NUHOMS-MP187 Cask System systems, structures and components are discussed in Section 3.4 of Volume 1 and Section 3.2 of endix C of the "Rancho Seco Independent Spent Fuel Storage Installation Safe Report" [A.3-1]. These classifications are summarized in Table A.3 convenience. Because the bill of materials (BOM) for the drawi reference for the PO-, FC-, and FF-DSCs do not list the Quali item, this information is provided in Table A.3-3 and Table listed in the tables correspond to the item number in the drawing incorporated by reference in Appendix A.4.6 :

ilarly, Table A.

Table A.3-6 provide the Quality Category for eac * ; e items that make up t MPl 87 cask as listed on the BOM for the draw*, ;s. corporated by reference in Appendix A.4.6 for the MP187 cask.

A.3.1.1 FO-, FC-, FF-DSCs and GTCC Canister A.3.1.2

asemat and Approach Slab must be prevented. The t boundary for canister, are nditions identified in t and approach slabs for the HSMs are considered NITS and are designed, ed, maintained, and tested to ACI-318 [A.3-5] as commercial-grade items.

Page A.3-2

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table A.3-3 Quality Classification for Items on Drawing NUH-05-4004 (FO-and FC-DSCs) 2 Pages Item No.

Nomenclature Or Description 52 Plate 51 Plate, Stiffening 50 Bottom Plug Side Casing 49 Bottom Plug Top Casing 48

, Plate,.085 Thk B

47 Stop Plate,.50 X 1.00 X.12 Thk B

46 B

45 ANGLE, 1 1/4 X 1 1/4 X 1/4" Thk B

44 Spacer Sleeve, 3.625 LG.

A 43 Spacer Sleeve, 4.25 LG.

A 42 Spacer Sleeve, 4.50 LG.

A 41 Spacer Sleeve, 4.75 LG.

A 40 A

39 A

38 A

37 A

36 B

35 B

B B

B A

A A

B B

A 24 Lifting Lug B

23 Quick Connect, 1/2" Male NITS 22 Male Connector, 3/4" Tube X 3/4" MNTP NITS Page A.3-17

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim TableA.3-3 Quality Classification for Items on Drawing NUH-05-4004 (FO-and FC-DSCs) 2Pa es 21 Siphon Tubing, 3/4 OD X.05 Wall 20 Siphon & Vent Block 19 Key 18 Extension Plate 17 Shear Key 16 Support Rod A

15 (Not Used) 14 Neutron Absorber Sheet (BORALTM)

A 13 Spacer Disc - Type "B" A

12 Oversleeve A

11 Guide Sleeve A

10 Spacer Disc - Type "A" A

9 Spacer Disc-Type "C" A

8 (Not Used) 7 B

6 A

5 B

4 B

J B

2 A

A Page A.3-18

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim TableA.3-4 Quality Classification for Items on Drawing NUH-05-4005 (FF-DSC) 2Pa es Item No.

Nomenclature Or Description 44 Plate, Stiffening 43 Plate 42 Plate, Stiffening 41 Bottom Plug Side Casing 40 Bottom Plug Top Casing 39 Side lid Plate 38 Cover Plate, 11 GA (.12) Thk B

37 Spacer Bar B

36 Washer Plate B

35 6 X 6 Mesh.047 Wire Dia. 2.50 Dia.

B 34

Top Lid Lifting Pintle A

33 Bottom Lid Adapter Plate A

32 Top Lid Cover Plate A

31 Shear Key B

30 A

29 A

28 27 B

26 B

25 B

B A

A A

B B

NITS NITS NITS iphon & Vent Block A

14 (Not Used) 13 (Not Used) 12 Bottom Plug Post B

Page A.3-19

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 11 10 9

8 7

6 5

4 3

2 1

TableA.3-4 Quality Classification for Items on Drawing NUH-05-4005 (FF-DSC) 2Pa es Lead Shielding Outer Support Plate Inner Support Plate Top Spacer Disc, 2.0 Thk Spacer Disc, 2.0 Thk Inner Bottom Cover Grapple Ring Support Grapple Ring B

Key B

Outer Bottom Cover A

Cylindrical. Shell A

Page A.3-20

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim TableA.3-5 Quality Classification for Items on Drawing NUH-05-4001 (MP187 Cask) 2 Pa es Item No.

Nomenclature Or Description 53 Tube I.D. Sized to Fit Items 33 & 34 (

Similar) 52 10 GA Sheet 51 Screw Thread Insert 2-12UN-2B X 5.50 LG X (2.27) 0 50 Screw Thread Insert 1-8UNC-2B X 2.00 LG X (1.18 49 NSP Support Angle, Inner 48 Space Washer 47 Screw Flat Hd Cap Screw 1/2-13UNC-2A 46 Lower Trunnion Plug Shielding Block 45 44 Tapered Pin 43 Test Port, Plug 42 Vent/Drain Port, Plug 41 40 39 38 37 36 D X.28 Thk Max Hd Soc, 1-8UNC-2A 4.5 LG

.5 ID); Ram Closure Plate: Cross-Section.425" (19.4 ID); Ram Closure Plate: Cross-Section.248" crew, Cap Hd Soc, 2-12UN-2A X 8.16 LG 26 0-Ring (71.4 ID); Top Closure Plate: Cross-Section.425" 25 0-Ring (69.6 ID); Top Closure Plate: Cross-Section.425" 24 Top Closure Plate PageA.3-21 A

NITS B

B B

NITS B

B B

A A

A B for Transport C for Storage A

A B

A A

A C for Storage B for Transport A

B A

A

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9

8 7

6 5

4 3

TableA.3-5 Quality Classification for Items on Drawing NUH-05-4001 (MP187 Cask) 2 Pa es Ram Closure Plate Castable Neutron Shielding Material Rails,.120 ThkX 4.0 Wide Upper Trunnion Plug Bottom Plate Neutron Shield Shell Plugs Rupture Plug.036 (20 GA) Thk NSP Support Angle, Outer A

NSP Bottom Support Ring, Plate A

NSP Top Support Ring, Plate A

Tie Bar A

Bearing Block A

Pad Plate A

Lower Trunnion Sleeve A

Upper Trunnion Sleeve A

Upper Trunnion Plug Side Plate B

B B

A A

A Page A.3-22

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim TableA.3-6 Quality Classification for Items on Drawing NUH-05-4003 (MP187 cask)

Item No.

Nomenclature Or Description 21 Hardened Washer, LS OD X.177 Thk 20 Key Plug Bottom Plate 19 Key Plug Side Plate 18 Trunnion Back, 1/4" Thk Plate 17 Upper Trunnion 16 Lower Trunnion 15 Screw, Socket Head Cap 1-8UNC-2A X 5.1 A

14 Flat HD Hex Socket Cap Screw 1/2-13UN B

13 Key Plug Cover Plate NITS 12 Plate, 1/2" Thk X 3.25 Sq NITS 11 Outer Plug Support Bracket NITS 10 BOLT, 1-8UNC-2A X 9.75 NITS 9

Lifting Eyes, Drop Forged NITS 8

NITS 7

NITS 6

NITS 5

NITS 4

NITS 3

NITS 2

NITS B

Page A.3-23

RAls and Responses Enclosure X to E-XXXX RAI NP-15-3:

Clarify whether the 24PT1 canisters from San Onofre included in the WCS CISF S include the GTCC canister. If the GTCC canister from San Onofre is included in the SAR

li0 "de drawings for this GTCC canister.

The NRG staff note that there are currently 17 24PT1 canisters loaded wi Onofre. One of the canisters is loaded with GTCC from San Onofre 1.

,e approved contents of the 24PT1 DSC in the 72-1029 CoC (i.e., not i

cl in t specifications for the 72-1029 system (NRG ADAMS ML 15054A51 )).

This information is needed to determine compliancewith 10 Response to RAI NP-15-3:

ISP is not requesting approval in this application to s stored at San Onofre.

Impact:

No change as a result of this RAI.

Page 46 of 119

RAls and Responses Enclosure X to E-XXXX RAJ NP-15-4:

Provide the complete set of drawings for the GTCC canisters currently stored at Mai Yankee-Rowe, Connecticut-Yankee, and Zion.

The drawings in WCS CISF SAR Appendix Hare only of the multi-purpose basket or the contents. In addition, provide the applicable codes and stan and construction of these GTCC canisters.

This information is needed to determine compliance with 10 CFR Response to RAJ NP-15-4:

vision of the s contain the and the complete

-MPC at Yankee-Rowe STO R at Zion are

sting NAC storage and icitly listed in SAR port SAR, and sig nstruction of the canisters te for the NAC-UMS system is addressed tion can be found in sections 1.3.1.1.2, ing of GTCC waste for the NAC-MPC ign information can be found in sections 5, and 3.4.2.5; Table 4.1-1; and sections STOR system, the canister loading of

. The design information can be found in

.4.1.1, 4.0,.,.8.11, 6.1.1, 6.2.3, and 8.1.2.

tared in the same storage overpacks used to store SNF age systems used at WCS CISF (Table 1-1). In addition, ers used for each storage system have external characteristics that are st cases identical, to the canisters used for SNF. The drawings CC containers, internal basket designs, and applicable design codes h of the storage systems in Section H.4.8. Additional descriptions of the rs and internals can be found in the references listed in Section H.3.1.1.

SAR Section H.3 has been revised as described in the response.

Page 47 of 119

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim H.3 PRINCIPAL DESIGN CRITERIA This section describes the principal design criteria, which are unique to the canisterized GTCC waste storage program at the WCS CISF. All GTCC be stored in the same storage overpacks used to store SNF canisters fo storage systems used at WCS CISF (Table 1-1 ). In addition, the G for each storage system have external characteristics that are sim

identical, to the canisters used for SNF. The drawings describ

containers, internal basket designs, and applicable design c es re lis.,

the storage systems in Section H.4.8. Additional descri tio of the GT and internals can be found in the references listed in

, *t n H.3.1.1.

Since the design criteria fort design criteria. used for storag

~

criteria for each of GTCC stora

Page H.3-1 are the same1 as the e0 arison of the design

, tions would be the

RAls and Responses Enclosure X to E-XXXX RAI NP-15-5:

Clarify the quality category of the MP197HB cask used for transportation and transi r operations for the 61 BT and 61 BTH DSCs.

WCS CISF SAR Appendix C.4.2.3 (61 BT DSC) states that the MP197HB is Safety (ITS) Quality Category C component, whereas Appendix D.4.2.3 (

that the MP197HB is an ITS Quality Category A component.

This information is needed to determine compliance with 10 CFR Response to RAI NP-15-5:

Impact:

SAR Sections A4.2.3, B.4.2.3, and C.4.

Page 48 of 119 I

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim A.4.2.2 Design Description The FO-, FC-and FF-DSCs and GTCC waste canister are stainless steel flat head pressure vessels that provides confinement that is designed to withstand a ormal condition loads as well as the off-normal and accident condition loads

~a cl by earthquakes, tornadoes, flooding, and other natural phenomena.

A.4.2.3 Safety Considerations Page A.4-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The MP 187 cask, in the transfer configuration, is used to transfer the canisters from the CHB to the storage pad where the cask is mated to the AHSM. The cask is designed to withstand all normal condition loads as well as the off-normal and accident condition loads created by earthquakes, tornadoes, flooding, an, er natural phenomena.

B.4.2.3 Safety Considerations The NUHOMS-24:PTl canisters are Important-to-Safety components.

The AHSM is an important-to-safety (ITS), Quali MP187 cask is an ITS, Quality Category A com Page B.4-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.4.2.2 Design Description The NUHOMS 61BT DSCs are stainless steel flat head pressure vessels that provide confinement that is designed to withstand all normal condition loads as w as the off-normal and accident condition loads created by earthquakes, tornadoes

@, ing, and other natural phenomena.

The HSM Model 102 is a low profile, reinforced concrete stru withstand all normal condition loads as well as the off-nor.=-*-

loads created by earthquakes, tornadoes, flooding, and othe, tural phe.. "'""=""~

HSM is also designed to withstand off-normal and ac *, e, t condition load1 °'S postulated to occur during design basis accident co 1* i s such as a complete ©.S ventilation.

C.4.2.3 Safety Considerations components.

fety (ITS), Quality Category B component.

tegory A component.

Page C.4-6

RAls and Responses Enclosure X to E-XXXX RAI NP-15-6:

Identify the code exceptions for the 72-1029 system components designed and fabri ated in accordance with the ASME code in WCS CISF SAR Appendix B, Section B.3.4.6. '

erial Selection." These are listed in 72-1029 UFSAR (R-6) Table.3.1-14.

This information should be included and specifically referenced in the app *,ati0 See the reference to code exceptions in WCS CISF SAR Appendix A Section

..,,, "m'la rial Selection," as an example.

This information is needed to determine compliancewith 10 CF Response to RAI NP-15-6:

Section B.3.4.6 in Appendix B of the WCS CISF S approved ASME Code Alternatives for 24PT1 DSC c of the 72-1029 UFSAR.

Impact:

SAR Section B.3.4.6 has been revised Page 49 of 119

WCS C9ns0Iidated Interim Storage Facility Safety Analysis Report Revision 3 Interim For the DSCs, a combination of fixed poison in the basket and geometry are relied on to maintain criticality control. The structural analysis shows that there is no deformation of the basket under accident conditions that would increase reactivity.

B.3.4.6 Material Selection B.3.4.7 Materials are selected based on their corrosion resistance, suscepti.¥>.

corrosion cracking, embrittlement properties, and the environ.,

operate during normal, off normal and accident conditions.

boundary for the DSC materials meet the requirements of Vessel Code,Section III, Article NB-2000 and the sp

, ation requireme Section II, Part D [B.3-8] with the listing of AS Alternatives for the provided in Table 3.1-14 of the "Advanced Horizontal Modular Stor System Safety Analysis Report" [B.3-1]. Th and cask corrosion and are not susceptible to other marine environments have demonstrated tha shells are expected to demonstrate minimal co The DSC internals are enveloped in a dry, helium-.~,-=

designed to withstand the load m all normal, off-and accident conditions.

The AHSM is a reinforced c, ~

onent with an ~

SC suppo. rt structure that is fabricated to ACI and

.,

ments. Bo,, a e durability well beyond a design life of 80 year or the Standardized Advanced NUHOMS d transfer of the DSCs to the storage pad, ions, and retrieval and shipping.

s are provided at the steps where special ect the contents of the DSC, or protect the andardized Advanced NUHOMS System.

PageB.3-9

RAls and Responses Enclosure X to E-XXXX RAI NP-15-7:

Specify the Quality Category of the coatings for the NAC-MPC vertical concrete cas and transfer cask identified in WCS CISF SAR Appendix E Sections E. 7.1.10 and E. 7

~,

The NRC staff note that the NAC-MPC UFSAR Section 3.8 and 3.A8 do no the coatings are ITS. In contrast, the NRC staff note that the NAC-UMS U Section 3.8 has a statement indicating that the coatings are Not lmpo Similarly, the NAC-1\\/lAGNASTOR UFSAR Section 8.6.2 has a state coatings are NITS.

This information is needed to determine compliancewith 10 Response to RAI NP-15-7:

The NAC-MPC system was approved by the NRC su lil'il i ing the classifications for each bill of materials item on each lie e

aw*

NAG-MPG Final Safety Analysis Report, Chapter 2, Table.@-

and concrete sealers are listed as NQ. They are not importa t category classifications for the following:

Drawing 455-864, "Shield Plug,

No. 5, "Coating System".

age 2.3-10, Item FR)," FSAR [1] Page 2.3-15, Item No. 22, Page 50 of 119

RAls and Responses Enclosure X to E-XXXX RAI NP-15-8:

Provide additional information to justify the classification of the 130-ton Crane and t Beam as NITS Components based on the NUHOMS system transfers being limit less than 80 inches:

Rancho Seco FSAR Appendix B, "Standardized SAR References," Sectio The height of 80 inches is chosen as this envelopes the maximum v cask Vvhen secured to the transport skid/trailer assembly.

The transfer operation (shown in WCS CISF SAR Figure AS-incoming railcar to the NUHOMS Transfer Trailer that take building (shown in WCS CISF SAR Figure 1-7) appears that is greater than 80 inches because the underside horizontal position as shown in Figure AS-1) will be II on the MP187 Transfer Trailer. As described, the dimen *

the MP187 Cask, and the description of the WCS canister operation do not support a lift height of no more than 80 inch This information is needed to determin and 72.24(h).

Response to RAI NP-15-8:

), 72.24(d)(1) and (2),

fer casks can be moved from the railcar s above 80 inches above the floor of the ranee study. ISP reviewed the drawings for ble for use in transporting these casks. Of

~Iii casks and contents, ISP chose the 1 2 inches above the floor of the CHB.

F has an adjustable deck height. During the r trailer the deck height is set at 35 inches ary of the clearance study performed using solidworks models eights showing the distance between the bottom of the the lift heights required to clear the skids and allow free om the transportation skid attached to the railcar to the transfer skid railer. As shown in Figure RA/ NP-15-8-1, the cask must be lifted position on the transportation skid to allow it to clear the key way and This results in the cask being lifted to less than 76 inches from the floor e cask onto the transfer trailer, it can be lowered to just over 66 inches t0 e transfer skid and then set down on the trunnion towers as shown in mr.lv.=lll"l!!!I" 8-1.

SAR Figures AS-1, 8.5-1, C.5-1, and D.5-1 have been updated to reduce the apparent height that the cask is lifted off the ground during transfer from the rail car to the transfer trailer.

Page 51 of 119

RAls and Responses Enclosure X to E-XXXX Impact:

SAR Figures AS-1, B.5-1, C.5-1, and D.5-1 have been revised as described in the response.

Page 52 of 119

RAls and Responses AFTER RECIEPT INSPECTION AND LOCATION INSIDE THE CASK G)

HANDLING BUILDING TRANSFER CASK IMPACT LIMITERS ARE REM VED AND THE CASK IS ENGAGED TO THE LIFT BEAM SSEMBL TOP OF RAIU" l CONCRETE

\\

THE TRANSFER CASK IS ON THE OVERHEAD BRIDGE CRANE. MOVE TRANSFER TRAILER UNDER THE TRANSFER CASK Figure RAI NP-15-8-1 Clearance Study Page 53 of 119 r-TOP OF RAIU I COOCRETE LIFT BEAM ASSEMBLY TRANSFER TRAILER USING THE OVERHEAD BRIDGE CRANE THE CASK IS LOWERED ONTO THE TRANSFER TRAILER

WCS Consolidated Interim Storage Facility Safety Analysis Report CD Figure A.5-1 NUHOMS-MP187 System Operations Page A.5-9 HS\\.1 OCX)R: JS INSTA1 ! FD

-CAf>K RALCAf!

Revision 3 Interim

WCS Consolidated Interim Storage Facility Safety Analysis Report CD

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A..;;:TER RECEIPT INSPECTION ANO LOCAHON INS!D!: rHE CASK HANDLING BUILDING, TRANSFER CASK IMPACT LUAITERS ARE REMOVED AND ThE CASK IS ENGAGED TO TI1E UH SEAM ASSEM8L V Figure RS--1 Standardized Advanced NUHOMS System Loading Operations Page B.5-9 Revision 3 Interim

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AHSM OOCR !S INSTALLE:0

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim CD HS\\I r100R IS INSTALi FD Figure C.5-1 Standardized NUHOMS-61 BT System Loading Operations Page C.5-9

WCS Consolidated Interim Storage Facility Safety Analysis Report CD

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Figure D-5-1 Standardized NUHOMS"'-618TH Type I System Loading Operations Page D.5-9 Revision 3 Interim

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AAlCAA MS\\l i)OOR '$ INSTAU.ED

RAls and Responses Enclosure X to E-XXXX RAJ NP-15-9:

Provide information to show that the design criteria for the GTCC storage systems a e the same as or bounding with respect to the WCS CISF site specific conditions.

The WCS CISF SAR Appendices A through G provide a comparison of the criteria of the spent fuel storage systems to the conditions of the WCS Cl such comparison was provided for the GTCC storage systems in the W This information is needed to determine compliancewith 10 CFR Response to RAJ NP-15-9:

All GTCC canisters will be stored in storage overpacks storage overpacks used to store SNF canisters for e CISF (see SAR Table 1-1). In addition, the GTCC ca external characteristics that are similar, and in most cas SNF.

The design criteria used for WCS CISF.Aa!IM....,..:.

Chapter 3 of the SAR. A comparison tffi the WCS CISF design criteria is given i in Tables A.3-1, trate that the design esign criteria.

8.3-1, C.3-1, D.3-1, E.3-1, F.3-1, and G.

Thes criteria used for the storage systems are b mm ed by Since the design criteria fo design criteria used fo

,...f0....,11-illi.

sat WCS CISF are the same as the Table 1-1, a comparison of the design ms with WCS site conditions would be the age systems iri SAR Appendices A-G.

criteria for GTCC s same as the co een revised to include the following text:

l!IS e summarized in Table 1-2 and discussed in

-- 'R. A comparison of the design criteria for each of the storage CISF design criteria is given in Appendices A-F (specifically in 1, D.3-1, E.3-1, F.3-1, and G.3-1). These comparisons criteria used for the storage systems are bounded by the criteria for the GTCC canisters at WCS CISF are the same as the ed for storage systems listed in Table 1-1, a comparison of the design of GTCC storage systems with WCS CISF conditions would be the mparisons already shown for the storage systems in Appendices A and E d are not repeated in this chapter.

SAR Section H.3 has been revised as described in the response.

Page 54 of 119 I

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim H.3 PRINCIPAL DESIGN CRITERIA This section describes the principal design criteria, which are unique to the canisterized GTCC waste storage program at the WCS CISF. All GTCC be stored in the same storage overpacks used to store SNF canisters fo storage systems used at WCS CISF (Table 1-1 ). In addition, the G for each storage system have external characteristics that are si

identical, to the canisters used for SNF. The drawings describ

containers, internal basket designs, and applicable design c

es re lis,

the storage systems in Section H.4.8. Additional descri tio of the GT and internals can be found in the references listed in

, n H.3.1.1.

The design criteria used for WCS CISF are sum Chapter 3 of this SAR. A comparison of the systems with the WCS CISF design criteri in Tables A.3-1, B.3-1, C.3-1, D.3-1, E.3-1, demonstrate that the design criteria used for the WCS CISF design criteria.

Since the design criteria fort,*.

design criteria used for storag criteria for each of GTCC stora e Page H.3-1 are the same as the arison of the design

, tions would be the s in Appendices A and

RAls and Responses Enclosure X to E-XXXX RAI NP-15-10:

Provide the following information for ASTM A572 Grade 50 steel: (1) modulus of ela ticity, (2) coefficient of thermal expansion, and (3) density.

This material is identified in WCS CISF SAR Section 15.3.2, "Canister Trans Section 15.3.3, "Vertical Cask Transporter." These property specifications rre WCS CISF SAR Sections 15.3.2 and 15.3.3.

This information is necessary to assure compliance with 1 O CFR 7.2.

Response to RAI NP-15-10:

While these parameters were specified in the applicatio, tffi The corresponding values have now been added to t ASTM materials have been corrected within SAR Se *,

15.4 has recently been revised. Reference 15-3 is now calculation is being provided via this submittal.

Impact:

SAR Sections 15.3.2, 15.3.3, and 15.4 In addition, an updated copy of calculation ~

is also provided for your information.

Page 55 of 119 e response.

WCS Consolidated Interim Storage Facility Safety Analysis Report Yield Strength eksi):

Modulus of Elasticity, E ex 106 psi):

Coefficient of Thermal Expansion, a ex 1 o-6 in/in/°F)

Density (lbrn/in3}

15.3.2.2 ASTMA514 - CTS Header Plate [15-4]

Ultimate Strength eksi):

Yield Strength eksi):

15.3.2.3 ASTMA693/564, Type 630 - Lift Pin [15-3]

Ultimate Strength eksi):

Yield Strength eksi):

Modulus of Elasticity, E ex 106 psi)

Coefficient of Thermal Expansion, a ex 10-6 in/i Density (lbrn/in3) 15.3.2.4 ASTMA516 Gr 70 - Canister Ultimate Strength eksi):

Yield Strength eksi :

15.3.2.5 Class B -Pins 15-2 15.3.2.8 ASTMA572, Grade 50 [15-3]

Ultimate Strength eksi):

Page 15-8 Revision 3 Interim 50.0 29.3 105.0 28.5 5.9 0.29 70.0 38.0 29.2 6.4 0.284 170.0 135.0 120.0 92.0 170.0 135.0 65.0

WCS Consolidated Interim Storage Facility Safety Analysis Report Yield Strength (ksi):

15.3.2.9 ASTMA36 [15-3]

Ultimate Strength (ksi):

Yield Strength (ksi):

15.3.2.10 ASTMA490 [15-1]

Ultimate Strength (ksi):

Yield Strength (ksi):

15.3.3 Vertical Cask Transporter 15.3.3.1 15-4 e 630 - Lift Pin 15-3 aJ es at Temperature (70°F)

Ultimate Strength (ksi):

Yield Strength (ksi):

Modulus of Elasticity, E (x 106 psi):

Page 15-9 Revision 3 Interim 50.0 58.0 36.0 150.0 65.0 50.0 29.3 6.5 0.284 110.0 100.0 135.0 105.0 28.5

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 15.4 References 15-1 ASME NOG-1-2010, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)," The American Society ofMechanica 2010.

15-2 ASTM A311/ A311M - 04 (Reapproved 2010), "Standard Specific Drawn, Stress-Relieved Carbon Steel Bars Subject to Mechanic Requirements," ASTM International, West Conshohocken, P 15-3 "Structural and Thermal Material Properties-MAGNAS System," NAC Calculation 71160-2101 Rev. 9, NAC 15-4 ASTM A514/A514M- 05 (Reapproved 2009) "S Yield-Strength, Quenched and Tempered Allo West Conshohocken, PA, 2009.

15-5 ANSI Nl4.6-1993 American National Stan Lifting Devices for Shipping Containers Weig *, *

More," 1993.

Page 15-11

RAls and Responses Enclosure X to E-XXXX RAI NP-15-12:

Clarify whether the NUHOMS MP187 Multi-Purpose Cask will potentially be used to contain a failed NUHOMS Dry Shielded Canister (DSC) such as a FO-, FC-, or FF-DSC c em ly in use at Rancho Seco or the 24PT1 DSCs that are in use at the San Onofre ISFSI.

Procedures for placement of a DSC into the metal cask for storage at an o s1 described in Section 7.1.6 of the NUHOMS MP187 Multi-Purpose Cas (ADAMS Accession No. ML063520505).

This information is needed to determine compliance with 10 CF Response to RAI NP-15-12:

ISP is not requesting authorization to contain failed ca Multi-Purpose Cask as part of this licensing action.

Impact:

Page 56 of 119 MP187

RAls and Responses Enclosure X to E-XXXX RAI NP-15-13*:

Clarify the incorporation of approved aging management programs for the 61 BT an DSCs that are part of CoC No. 1004. CoC No. 1004 was renewed in December 2 The CoC holder has developed NRC approved aging management program 72-1004 SSCs including the DSCs. WCS CISF SAR Section 1.1 page 1-3 systems approach 20 years of service time, their applications for Licens Aging Management Program (AMP) requirements, vvi/1 be submitted approval." However, the WCS CISF application does not include This information is needed to determine compliance necessa CFR 72.42(a)(2) and 72.240(c)(3).

Response to RAI NP-15-13:

In accordance with the proposed license condition 20(1,

AMPs committed to in the approved License Renewal of Fuel Canisters and storage overpacks." Interim Storage Pa AMPs from the Renewed CoC 1004 [1]

NUHOMS DSC ix C, Section C.13, SCs and the Model f the FO, FC, FF, and ompo valuated in the renev,.,ed ctivity (AMA) is required or that the AMPs HSM was explicitly included as an SSC in Page 57 of 119

RAls and Responses Enclosure X to E-XXXX The aging management programs (AMPs) for the SSCs at the WSC CISF site have been added to Appendix C ( SAR Section C.13). These AMPs are based on the approved AMPs for the renewed CoC 1004 [1 ]. Note that the Standardized NUHOMS 61 BT system was explicitly included as an SSC in the scope of the renewed CoC 1004. Therefore, the AMPs i the renewed CoC 1004 are applicable to the 61 BT system proposed for storage at th S CISF.

The following changes have been made to the AMPs in the rene111.ed CoC [1] t at the WSC CISF:

Did not included the high burnup (HBU) AMP Explanation/Justification - ISP application explicitly stored. Therefore, there is no need/requirement for a tilation AMP transport the DSCs ansfer the DSCs from aintenance performed 004 submittal states that the focus of the I ckage (Section 6A6.5.1 of [1 ]). The need ience of rust on the bird screens leading to vents. However, the bird screens on the HSM vents at the WSC tainless steel and will not be subject to general corrosion that to blo a~ of the vents. Therefore, there are no aging mechanism/effects d to b el{a

e of the vents arid no AMP is required.

ces to ewal and the CoC 1004 Amendments 1cation - ISP is requesting specific license for the WCS CISF ISFSI not appropriate to discuss the applicability of the AMPs to the CoC ts or to refer to renewed CoC.

ded period of operation

/Justification - ISP is requesting a specific license for a 40-year period.

e"!.I., the AMPs are to be implemented after the DSCs and HSMs have been in serv e for 20 years. To be consistent with the terminology used in the renewed Coe 1004 AMPs, the phrase "period of extended operation" is defined to reflect SSCs that have been in service for greater than 20 years.

Page 58 of 119

RAls and Responses Enclosure X to E-XXXX Changed reference from Part 50, Appendix B program to TN Americas 10 CFR Part 72, Subpart G Program Explanation/Justification - ISP is requesting a specific license and thus will not have a Part 50, Appendix B QA program. As stated in Chapter 6, ISP has adopted e TN Americas CFR 72, Subpart G quality assurance program. Therefore, the P.2 should reference to TN Americas QA program rather than a general licensee's a Appendix B program.

Changed reference from general licensees to ISP Explanation/Justification - ISP is requesting a specific licens refore, ~

need to be applicable to the specific license and not a ge al

art 72 licen Removed reference to 72.212 report Explanation/Justification - As a specific license, I document various evaluations. However, the re, was not removed.

1004 AMPs [1] provided a graduated pections for general licensees who loaded However, the grace period for those mpleted by 2021f.Section,1.1 of.the ISR

F is not planned to begin until July 2023.

for the initial AMP inspections.

"Standardized NUMOMS dry storage system" ion - It is ISP intention to have a single set of AMPs for all ems. Therefore, the specific name "Standardized NUMOMS een removed.

ce for Ii nsees not committed to ACI 349.3R 1cation - ISP has elected to apply the inspection and acceptance

I.3R [3] to the basemat. Therefore, the allowance to use site specific ded.

ous

, it7f1al changes oria/ changes were made to improve readability of the AMPs and to reflect 1s reasonable for implementing the AMPs rather than a general licensee.

Page 59 of 119

RAls and Responses Enclosure X to E-XXXX Section D.13 has been added to Appendix D to require the AMPs in Appendix C, Section C.13, to be applied to the 61 PTH system. Note that the Standardized NUHOMS 618TH system was explicitly included as an SSC in the scope of renewal of Coe 1004. Therefore, the AMPs in Appendix C ( SAR Section C.13) are applicable to the SSCs of the 618TH system pr. posed for storage at the WCS CISF.

References:

1. Letter E-46190 from Jayant Bondre (AREVA Inc.) to Document Co "Response to Re-Issue of Second Request for Additional lnformat a AR Reriewal application for Standardized NUHOMS System - C C 1 4 (Docket CAC No. L24964)," September 29, 2016, (ADAMS Accessi,

mber ML 16279A

2.

Licenses and Certificates of Compliance," U.S. Nuc June 2016.

3. ACI 349.3R, "Evaluation of Existing Nuclear Safety-Concrete Institute, 2002.

Impact:

SAR Sections A 13, 8.13, C.13, and D.

Page 60 of 119

RAls and Responses Enclosure X to E-XXXX Table RAJ 15-13-1 FO, FC, FF DSCs I

(5 pages)

FO& FC FF FO,FC,FF Coe 1004 DSC Subcomponent Drawing Drawing FO& FC or FF Coe 1004 Applicability ofCoC 1004 AMR and AMP to Parts NUH-05-4004 NUH-05-4005 Material Safety

& AMR Results Material 24PT1 Item No.

Item No.

Classification Table While the FO & FC material is SA-537 CL2, and the 24PT2 material is SA-533 GR B CL 1, they FO, are both cartlon steel. Since they are both FC-SA-537 cartlon steel and see the inert gas emnronment, CL2 24PT2S and SA-533, GR no AMA is required. The material of the FF Spacer Discs 9, 10, 13 7,.8 ITS 24PT2L B, CL 1 None Required DSCs is SA-240 Type XM19, i.e., stainless steel, FF -SA-240 Table 1C-12 which has no aging effects in an inert Type XM19 em,ronment requiring aging management.

Therefore, the CoC 1004 AMR results are applicable to the FO, FC, & FF DSCs and no AMA is required.

24PT2S and While the stop plate for the FO & FC is classified Stop Plate 47 NIA SA-240 Type ITS 24PT2L NIA as important to safety, it is made of stainless 304 Table 1C-12 steel and is in an inert gas emnronment.

Therefore, no AMA is required.

FO, FC-Support These components for the FO, FC, and 24PT2 Rod Assembly FO, DSCs are made of the same material. The with Spacer 16, 37, 38,39, FC-SA-564 material for the FF DSC is SA-240 XM19, but Sleew (all 40, 41, 42, 43, 9, 10 Type 630 Inert Gas None Identified None Required that is also a stainless steel material. Since they spacer sleews) are all stainless steel and see the same type of 44 FF -SA-240 emMonment, the Coe 1004 AMR results are FF - Inner and Type XM19 applicable to the FO, FC, & FF DSCs and no Outer Support AMA is required Plate Loss of NUHOMS These components are made of the same Cylindrical Shell ITS Inert Gas I

Material, Aging material and see the same type of emironment.

Sheltered Cracking Management Therefore, the Coe 1004 AMR results and AMP Program (AMP) are applicable to the FO, FC, FF DSCs.

Loss of These components are made of the same Outer Bottom 2

ITS Sheltered

Material, NUHOMS AMP material and see the same type of emnronment.

Cowr Plate Therefore, the Coe 1004 AMR results and AMP Cracking are applicable to the FO, FC, FF DSCs.

These components are made of the same Bottom Shield 27 24PT2S A36 NITS11l Embedded/

None Identified None Required material and see the same type of em,ronment.

Plug Table 1C-12 Encased Therefore, the CoC 1004 AMR results and AMP are applicable to the FO, FC, FF DSCs.

24PT2S and Loss of These components are made of the same Grapple Ring 4

4 24PT2L A240 Type ITS Sheltered

Material, NUHOMS AMP material and see the same type of em,ronment.

304 Therefore, the CoC 1004 AMR results and AMP Table 1C-12 Cracking are applicable to the FO, FC, FF DSCs.

Page 61 of 119

RAls and Responses EnclosureX to E-XXXX Table RAJ 15-13-1 FO, FC, FF DSCs (5 pages)

FO& FC FF FO,FC,FF Coe 1004 DSC Subcomponent Drawing Drawing FO&FCorFF Coe 1004 Applicability of Coe 1004 AMR and AMP to Parts NUH-05-4004 NUH-05-4005 Material Safety

& AMR Results Material 24PT1 Item No.

Item No.

Classification Table 24PT2S and These componenls are made of the same Grapple Ring 5

5 SA-240 Type ITS 24PT2L A240 Type material and see the same type of em.ironment.

Support 304 Table 1C-12 304 Therefore, the CoC 1004 AMR results and AMP are applicable to the FO, FC, FF DSCs.

These components are made of the same Inner Bottom SA-240 Type 24PT2S and material and see the same type of em.ironment.

Cm.er Plate 6

6 304 ITS 24PT2L None Required Therefore, the Coe 1004 AMR results are Table 1C-12 applicable to the FO, FC, FF DSCs and no AMA is required.

These components are made of the same Shear Key 17 31 SA-240 Type ITS 32PT NUHOMS" AMP material and see the same type of em.ironment.

304 Table 1E-10 Therefore, the CoC 1004 AMR results and AMP are applicable to the FO, FC, FF DSCs.

These components are made of the same Key 19 3

SA-240 Type ITS None Identified None Required material and see the same type of em.ironment.

304 Therefore, the CoC 1004 AMR results and AMP are applicable to the FO, FC, FF DSCs.

SA-240 Type While the FF DSC lists SA-182 GR F304 or 304 F304N, SA-479 Type 304 as optional materials, Siphon & Vent (Options for FF there are stainless steel. Since these Block 20 15

-SA-182 GR Inert Gas None Identified None Required components are all stainless sleel and see lhe F304 Or same type of em.ironment, the Coe 1004 AMR F304N, SA-479 results are applicable to the 24PT1 and no AMA Type 304) is required AISl-304 Siphon Tubing 21 16 NITS NIA NIA NIA A non-important to safely item thal is not in-scope. Therefore, no AMA is required.

Swagelok 22, 23 SST NITS NIA NIA N/A A non-important to safety item that is not Connections in-scope. Therefore, no AMAis required.

These components are made of the same 32PT A240 Type material and see the same type of em.ironment.

Lifting Lug 24 ITS Inert Gas None Identified None Required Therefore, the Coe 1004 AMR results are Table 1E-10 304 applicable to the FO, FC, FF DSCs and no AMA is required.

Page 62 of 119

RAls and Responses EnclosureX to E-XXXX Table RAI 15-13-1 FO, FC, FF DSCs (5 pages)

FO& FC FF FO,FC,FF Coe 1004 DSC Subcomponent Drawing Drawing FO&FCorFF Coe 1004 Applicability of CoC 1004 AMR and AMP to Parts NUH-05-4004 NUH-05-4005 Material Safety

& AMR Results Material 24PT1 Item No.

Item No.

Classification Table SA-240 Type SA-240 Type These components are made of the same Support Ring, 304 32PT 304 or material and see the same type of em.ironment.

Plate 25 20 (Option for FF -

ITS Table 1E-10 SA-479 Type Therefore, the Coe 1004 AMR results are SA-479 Type 304 applicable to the FO, FC, FF DSCs and no AMA 304) is required.

These components are made of the same 24PT2S material and see the same type of em.ironment.

Top Shield Plug 26 NIA A36 ITS Table 1C12 None Required Therefore, the Coe 1004 AMR results are applicable to the FO, FC, FF DSCs and no AMA is required.

These components are made of the same Outer Top Cm.er 29 22 SA-240 Type ITS 24PT2S NUHOMS" AMP material and see the same type of em.ironment.

Plate 304 Table 1C-12 Therefore, the CoC 1004 AMR results and AMP are applicable to the FO, FC, FF DSCs.

These components are made of the same Siphon & Vent SA-240 Type material and see the same type of em.ironment.

30 23 ITS None Identified None Required Therefore, the Coe 1004 AMR results are Port Co\\er Plate 304 applicable to the FO, FC, FF DSCs and no AMA is required.

Embedded These components are made of the same Inner Top Co\\er SA-240 Type (Top Surface material and see the same type of em.ironment.

Plate 28 21 304 Only)

None Identified None Required Therefore. the Coe 1004 AMR results are Inert Gas applicable to the FO, FC, FF DSCs and no AMA (Balance) is required.

These components are made of the same material and see the same type of em.ironment.

Guideslee\\e 11 NIA ITS Inert Gas None Identified None Required Therefore, the Coe 1004 AMR results are applicable to the FO, FC, FF DSCs and no AMA is required.

These components are made of the same Neutron Boral material and see the same type of em.ironment.

Absorber S heel 14 ITS Inert Gas None Identified None Required Therefore, the CoC 1004 AMR results are applicable to the FO, FC, FF DSCs and no AMA is required.

These components are made of the same 24PT2S and SA-240 Type material and see the same type of em.ironment.

O\\erslee\\e 12 NIA 24PT2L ITS Inert Gas None Identified None Required Therefore, the CoC 1004 AMR results are Table 1C-12 304 applicable to the FO, FC, FF DSCs and no AMA is required.

Page 63 of 119

RAls and Responses Enclosure X to E-XXXX Table RAI 15-13-1 FO, FC, FF DSCs (5 pages)

FO& FC FF FO,FC,FF Coe 1004 DSC Coe 1004 Subcomponent Drawing Drawing FO & FC or FF Coe 1004 Applicability of Coe 1004 AMR and AMP to Parts NUH-05-4004 NUH--05-4005 Material Safety

& AMR Results Material 24PT1 Item No.

Item No.

Classification Table These components are made of the same Shim Plate SA-240 Type 24PT2S and A-240 Type material and see the same type of emAronment.

(Extension plate) 18, 48 NIA 304 ITS 24PT2L 304 Therefore, the Coe 1004 AMR results are Table 1C-12 applicable to the FO, FC, FF DSCs and no AMA is required.

Lead Shielding These components are made of the same (For Top and 24PTL material and see the same type of emAronment.

Bottom Shield 3

11 829 Lead ITS Table 1C-12 None Required Therefore, the CoC 1004 AMR results are Plug applicable to the FO, FC, FF DSCs and no AMA Assemblies) is required.

These components are made of the same Top Shield Plug 24PTL material and see the same type of emironment.

Assembly 31, 32, 33, 34 24, 25, 26, 27 A36 ITS Table 1C-12 None Required Therefore, the CoC 1004 AMR results are applicable to the FO, FC, FF DSCs and no AMA is required.

Bottom Shield 7, 49, 50, 51, 12,40, 41,42, These components are made of the same Plug Assembly 52 43 SA-240 Type Embedded/

material and see the same type of emAronment.

and Shield Plug (and 36 for top (and 44 for top 304 Encased None Identified None Required Therefore, the CoC 1004 AMR results are Stiffeners shield) shield) applicable to the FO, FC, FF DSCs and no AMA is required.

Failed Fuel Can These components are made of the same (Liner, Bottom 29, 30, 32, 33, material and see the same type of en~ronment.

Lid, Top Lid NIA 34 SA-240 304 Inert Gas None Identified None Required Therefore, the CoC 1004 AMR results are Liner and Top applicable to the FO, FC, FF DSCs and no AMA Plate) is required.

Washer Plate, These components are made of the same spacer bar, material and see the same type of en~ronment.

NIA ITS Inert Gas None Identified None Required Therefore, the Coe 1004 AMR results are co\\er plate side applicable to the FO, FC, FF DSCs and no AMA plate is required.

These components are made of the same 24PTH Stainless material and see the same type of en~ronment.

Mesh NIA Table 1J-13 Steel ITS Inert Gas None Identified None Required Therefore, the CoC 1004 AMR results are applicable to the FO, FC, FF DSCs and no AMA is required.

Page 64 of 119

RAls and Responses Subcomponent Parts Angle and Plate Not Used FO& FC Drawing NUH-05-4004 Item No.

45, 46 8, 15, 35 FF Drawing NUH-05-4005 Item No.

NIA 13, 14, 28 FO & FC or FF Material Item 45 -SA-479 Type 304 Item 46 -SA-240 Type 304 NIA FO, FC, FF Safety Classification ITS NIA (1) Failure of this NITS item would prewnt fulfillment of an important to safety function.

Coe 1004 DSC

& AMR Results Table NIA NIA Enclosure X to E-XXXX Table RAl 15-13-1 FO, FC, FF D5Cs (5 pages)

Coe 1004 Material NIA Page65 of119 NIA NIA NIA Applicability of Coe 1004 AMR and AMP to 24PT1 While the renewal of CoC 1004 did not explicitly ewluate this component, it is made of stainless steel and is in an inert environment. Therefore, no AMA is required.

NIA

RAls and Responses Subcomponent Parts Cylindrical Shell Outer Bottom Cowr Plate Bottom Shield Plug12>

Grapple Ring Grapple Ring Support Basket Key Swagelok Connections GTCC Drawing 13302-1005 Item No.

7 2

3 4

8 14 GTCC Material SA-240 Type 304 SA-240 Type 304 SA-240 Type 304 SA-240 Type 304 SA-240 Type 304 GTCC Safety Classification ITS ITS ITS ITS Coe 1004 DSC

& AMR Results Table 24PT2S and 24PT2L Table 1C-12 24PT2S and 24PT2L Table 1C-12 32PT Table 1E-10 Enclosure X to E-XXXX Coe 1004 Material Table 15-13-2 GTCCDSC (2 pages)

Coe 1004 Safety Classification SA-240 Type 304 ITS SST NITS Page 66 of 119 Sheltered Sheltered Inert Gas NIA Loss of Material, Cracking Loss of Material, Cracking None Identified NIA NUHOMS" AMP NUHOMS"' AMP NUHOMS" AMP NUHOMS" AMP Applicability of CoC 1004 AMR and *AMP to 24PT1 components are made of the same material d see the same type of en\\ironment. Therefore, the Coe 1004 AMR results and AMP are applicable to the GTCC DSC.

While the GTCC DSC calls SA-240, and 24PT2 calls for A240, both materials are stainless steel. These components are made of the same type of material, i.e., stainless steel, and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the GTCC DSC.

While the GTCC DSC calls SA-240 Type 304, and 32PT calls for SA-182 Type F304, both materials are stainless steel. These components are made of the same type of material, i.e., stainless steel, and see the same type of en\\ironments. Therefore, the CoC 1004 AMR results and AMP are applicable to the GTCC DSC While the GTCC DSC calls SA-240, and 24PT2 calls for A240, both materials are stainless steel. These components are made of the same type of material, i.e., stainless steel, and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the GTCC DSC.

While the GTCC DSC calls SA-240, and 24PT2 calls for A240, both materials are stainless steel. These components are made of the same type of material, i.e., stainless steel, and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the GTCC DSC.

While the GTCC DSC calls A-240, and 24PT2 calls for SA-240, both materials are stainless steel. These components are made of the same type of material, None Required i.e., stainless steel, and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results are applicable to the GTCC DSC and no AMA is required NIA A non-important to safety item that is not in-scope.

Therefore, no AMA required.

RAls and Responses Subcomponent Parts Top Shield Plug Outer Top Co.er Plate Siphon & Vent Port Co.er Plate Top shield Plug Alignment Key 0-Ring Basket Assembly GTCC Drawing 13302-1005 Item No.

5 6

12 9

10, 11 13 (11221-1000 11221-1002)

GTCC Material A36.

SA-240 Type 304 A36 A240-Type 304 Park er #2-326 A240, stainless steel, A276, A269 GTCC Safety Classification ITS ITS ITS NITS NITS NITS (1) Failure of this NITS item would pre.en! fulfillment of an important to (2) The bottom shield plug for the GTCC DSC is configured the same as Coe 1004 DSC

& AMR Results Table 24P12S Table 1C12 24P12S Table 1C-12 24PT2S and 24P12L Table 1C-12 Enclosure X to E-XXXX Coe 1004 Material A36 Table 15-13-2 GTCCDSC (2 pages)

Coe 1004 Safety Classification SA-240 Type 304 Page 67 of 119 NIA NUHOMS AMP None Required NIA NIA N/A NIA NIA Applicability of CoC 1004 AMR and AMP to 24PT1 components are made of the same material nd see the same type of emnronment. Therefore, the CoC 1004 AMR results are applicable to the GTCC DSC and no AMA is required.

These components are made of the same material and see the same type of emAronmenl. Therefore, the CoC 1004 AMR results and AMP are applicable

to the GTCC DSC.

While the GTCC material is carbon steel (A36) and the 24P12 is stainless steel (SA-240 Type 304) both are in an embedded and inert emironmenl.

Therefore, no AMA is required.

A non-important to safely item that is not in-scope.

Therefore, no AMA required.

A non-important to safety item that is not in-scope.

Therefore, no AMA required.

A non-important to safety items in an inert gas.

Therefore, no AMA required.

RAls and Responses Subcomponent Parts Spacer Discs Stop Plate Support Rod Assembly with Spacer Sleew (all spacer sleews)

Pin Cylindrical Shell Outer Bottom Cowr Plate Bottom Shield Plug Grapple Ring 24PT1 SAR Drawing NUH.05-4010 Item No.

1, 2 3

4, 5, 6, 7, 8, 9, 10, 11, 12 13 14 15 16 17 24PT1 SAR Drawing NUH.05-4010 Material SA-537, CL 2 SA-240 Type 304, OrA240 Type 304 SA-564 Type 630 A276 Type 304 SA-240 Type 316 A240 Type 316 24PT1 Safety Classification ITS NITS ITS ITS ITS Coe 1004 DSC

& AMR Results Table 24PT2S and 24PT2L Table 1C-12 24PT2S and 24PT2L Table 1C-12 24PT2S and 24PT2L Table 1C-12 EnclosureX to E-XXXX Table RAJ 15.13-3 24PT1 DSC Coe 1004 Material SA-533, GR 8, CL 1 A240 Type 304 (5 pages)

Coe 1004 Safety Classification ITS NITS11 >

ITS Page 68 of 119 Inert Gas/

Sheltered Sheltered Embedded/

Encased Sheltered Loss of Material, Cracking Loss of Material.

Cracking None Identified Loss of Material, Cracking None Required NIA None Required None Required NUHOMS Aging Management Program (AMP)

NUHOMS AMP None Required NUHOMS AMP Applicability of CoC 1004 AMR and AMP to 24PT1 the 24PT1 material is SA-537 CL2, and the T2 material is* SA-533 GR B CL 1, they are both carbon steel. Since they are both carbon steel and see the same type of emironment, the Coe 1004 AMR results are the applicable to the 24PT1 and no Aging Management Acti\\ity (AMA) is required.

A non-important to safety item that is not in-scope.

Therefore, no AMA is required.

These components are made of the same material and see the same type of en\\ironment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

While the 24PT1 material is Type 316 and the 24PT2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of en\\ironment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 24PT2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of en\\ironment, the Coe 1004 AMR results and AMP are applicable to the 24PT1.

These components are made of the same material and see the same type of en\\ironment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

While the 24PT1 material is Type 316 and the 24PT2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of en\\ironment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

RAls and Responses Subcomponent Parts Grapple Ring Support Inner Bottom Cowr Plate Shear Key Basket Key Siphon & Vent Block Siphon Tubing Swagelok Connections Lifting Lug 24PT1 SAR Drawing NUH-05-4010 Item No.

18 19 20 21 22 23 24, 25 26 24PT1 SAR Drawing NUH-05-4010 Material A240 Type 316 SA-240 Type 316 A240 Type 316 A240 Type 316 SA-240 Type 316 24PT1 Safety Classification ITS ITS ITS ITS ITS Coe 1004 DSC

& AMR Results Table 24Pl2S and 24Pl2L Table 1C-12 24Pl2S and 24Pl2L Table 1C-12 32PT Table 1E-10 Enclosure X to E-XXXX Table RAJ 15.13-3 24PT1 DSC Coe 1004 Material A240 Type 304 A240 Type 304 (5 pages)

Coe 1004 Safety Classification ITS NITS NITS ITS Page 69 of 119 Inert Gas Inert Gas N/A NIA Inert Gas None Identified None Identified NIA NIA None Identified Applicability of CoC 1004 AMR and AMP to 24PT1 the 24PT1 material is Type 316 and the 24Pl2 aterial is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of en\\1ronment, the Coe 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 24Pl2 material is Type 304, they are both stainless steel.

None Required Since they are both stainless steel and see the same type of en\\1ronment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

NUHOMS" AMP Since they are both stainless steel and see the same type of en'.1ronment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

None Required Since they are both stainless steel and see the same type of em,ronment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required.

While the 24PT1 material is Type 316 and the 24Pl2 material is Type 304, they are both stainless steel.

None Required Since they are both stainless steel and see the same type of en\\1ronment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required NIA NIA A non-important to safety item that is not in-scope.

Therefore, no AMA is required.

A non-important to safety item that is not in-scope.

Therefore, no AMA is required.

While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

None Required Since they are both stainless steel and see the same type of em,ronment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required

RAls and Responses Subcomponent Parts Support Ring.

Plate Top Shield Plug Outer Top Cm.er Plate Siphon & Vent Port,Cover Plate Inner Top Cover Plate Guidesleeve Neutron Absorber Sheet Oversleeve 24PT1 SAR Drawing NUH.05-4010 Item No.

27 28 29 30 31 32 33 34 24PT1 SAR Drawing NUH.05-4010 Material SA-479 Type 316 A36 SA-240 Type 316 SA-240 Type 316 SA-240 Type 316 24PT1 Safety Classification ITS ITS ITS ITS ITS Coe 1004 DSC

& AMR Results Table 24Pl2S and 24Pl2L Table 1C-12 24Pl2S Table 1C12 24Pl2S Table 1C-12 Enclosure X to E-XXXX coc 1004 Material Table RAI 15.13-3 24PT1 DSC (5 pages)

Coe 1004 Safety Classification SA-240 Type 304 ITS ITS ITS SA-240 Type 304 ITS Page 70 of 119 Embedded (Top Surface Only)

Inert Gas (Balance)

Inert Gas Inert Gas Inert Gas None Required None Required NUHOMS" AMP None Identified None Required

-None Identified None Required None Identified None Required None Identified None Required None Identified None Required Applicability of CoC 1004 AMR and AMP to 24PT1 the 24PT1 material is SA-479 Type 316 and the material is SA-240 Type 304, they are both stainless steel. Since they are both stainless steel and see the same type of emironment. the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required These components are made of the same material and see the same type of emironment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

While the 24PT1 material is Type 316 and the 24Pl2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of emironment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 24Pl2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of emironment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required While the 24PT1 material is Type 316 and the 24Pl2 material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of emironment, the CoC 1004 AMR results are applicable to the 24PT1 and no AMA is required These components are made of the same material and see the same type of emironment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

These components are made of the same material and see the same type of emironment. Therefore, the results of the Coe 1004 AMR are applicable to the 24PT1 and no AMA is required.

These components are made of the same material and see the same type of emironment. Therefore, *the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

RAls and Responses Subcomponent Paris Shim Plate Liner. Bottom Lid, Top Lid Liner and Top Plate (and other failed fuel can subcomponents)

Washer Plate Mesh Spacer Bar Top and Bottom Spacers Not used Test Port Plug Bottom Shield Plug Outer Casing 24PT1 SAR Drawing NUH-05-4010 Item No.

35 36, 37. 38. 39.

40. 41 42 43 44 45, 46, 47, 49 48, 50 51 52 24PT1 SAR Drawing NUH-05-4010 Material SA-240 Type 304 SA-240 Type 304, (Or SA182 Type F305 for Top lid)

A240 Type 304 Stainless Steel A240 Type 304 A240 Type 304, A479 Type 304 24PT1 Safety Classification ITS ITS ITS ITS ITS EnclosureX to E-XXXX Table RAI 15.13-3 24PT1 DSC (5 pages)

Coe 1004 DSC Coe 1004 Coe 1004

& AMR Results Material Safety Table Classification 24Pl2S and 24Pl2L A-240 Type 304 ITS Table 1C-12 24PlH Table 1J-13 24PlH Table 1J-13 NIA ITS A240 Type 304 ITS Page 71 of 119 None Required None Required None Required Inert Gas NIA NIA Inert Gas None Identified None Required N/A NIA NIA Sheltered Loss of Material, NUHOMS" AMP Cracking Sheltered Loss of Material, NUHOMS" AMP Cracking Applicability of CoC 1004 AMR and AMP to 24PT1 components are made of the same material d see the same type of emnronment. Therefore. the results of the Coe 1004 AMR are applicable to the 24PT1 and no AMA is required.

These components are made of the same material (SA182 type F305 is also stainless steel) and see the same type of environment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

These components are made of the same material and see the same type of environment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

The 24PT1 failed fuel can spacer bar is made of the same material as the failed fuel can washer plate (Item #42) and sees the same type of environment.

Since no AMA was required for the washer plate, no AMA is required for the spacer bar.

CoC 1029 SAR describes the use of stainless steel fuel spacers to center the short 14x14 Westinghouse fuel. While these subcomponents were not explicitly e1.0luated in the renewal of CoC 1004, these are stainless steel components in an inert gas environment. Therefore, no AMA is required.

NIA While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of environment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of environment, the CoC 1004 AMR results and AMP are applicable to the 24PT1.

RAIS and Responses Subcomponent Parts Altematiw Outer Bottom Cowr Plate Altematiw Inner Bottom Cowr Plate Shim Plate Screw Socket HD Cap Alternate Bottom Shield Plug 24PT1 SAR Drawing NUH.05-4010 Item No.

53 54 55 56 57 24PT1 SAR Drawing NUH.05-4010 Material A240 Type 316, Or A182 Type F316 SA-182 Type F316 SA-240 Type 304 A193 GR 87 A240 Type 316, Or A182 Type F316 24PT1 Safety Classification ITS ITS ITS ITS ITS (1) Failure of this NITS item would prewnt fulfillment of an im Coe 1004 DSC

& AMR Results Table 32PT Table 1E-10 32PT Table 1E-10 Enclosure X to E-XXXX coc 1004 Material Table RAI 15.13-3 24PT1 DSC (5 pages)

Coe 1004 Safety Classification A240 Type 304 Page 72 of 119 Sheltered Loss of Material, Cracking NUHOMS"' AMP None Required None Required NUHOMS"' AMP Applicability of CoC 1004 AMR and AMP to 24PT1 the 24PT1 material is Type 316 (or A182 Type

16) and the 32PT material is Type 304, they are both stainless steel. Since they are both stainless steel and see the same type of emironment. the CoC 1004 AMR results and AMP are applicable to the 24PT1.

While the 24PT1 material is Type 316 and the 32PT material is Type 304, they are both stainless steel.

Since they are both stainless steel and see the same type of emironment, the Coe 1004 AMR results and AMP are applicable to the 24PT1.

These components are made of the same material and see the same type of emironment. Therefore, the results of the CoC 1004 AMR are applicable to the 24PT1 and no AMA is required.

The failed fuel can Socket Cap screw is in an inert Gas emlironment and therefore, no AMA is required.

While a portion of the 24PT1 alternate bottom shield plug is in an encased emnronment (and thus no AMA is required,) a portion is exposed to the sheltered en\\ironment. The portion exposed to a sheltered en\\ironment is susceptible to the same aging effects as Item #53. Since the CoC 1004 AMR results and AMP were determined to be applicable to item #53, they are also applicable to item #57.

RAls and Responses Subcomponent Parts HSM Base Walls and Roof HSM End and Rear Shield Walls Shielded Door Door Plate Door Deformed Bar Anchors Support Rail Beam & Cross Beam Support Rail Plate Support Structure Steel (Rail Extension Plate/

Baseplate, DSC Stop Plate &

Extension Plate, Stiffener Plates, Gussets, Base Plates)

AHSM SAR Drawing NUH.03-4011 Item Nos.

N/A<2l N/A(2l N/A(2l 2

3, 14 6, 7 4, 5, 8, 9, 10, 11, 12, 13, 47 AHSM SAR Drawing NUH.03-4011 Material Reinforced Concrete Reinforced Concrete Reinforced Concrete A36 A496 A240 Type 304 Or A479Type 304 AHSM Safety Classification ITS ITS ITS ITS ITS Coe 1004 HSM&AMR Results Table Model 152 Table 1F-15 Model 152 Table 1F-15 Model 152 Table 1F-15 Enclosure X to E-XXXX Coe 1004 Material Reinforced Concrete Table RAJ 15.13-4 AHSM (5 pages) coc 1004 Safety Classification NITS<1>

A 240 lYPE 304 ITS Page 73 of 119 Embedded/

Encased Sheltered Sheltered Sheltered NUHOMS AMP NUHOMS AMP Loss of Material NUHOMS AMP None Identified None Required Loss of Material NUHOMS AMP Loss of Material NUHOMS AMP Loss of Material NUHOMS AMP Applicability of CoC 1004 AMR and AMP to AHSM e components are made of the same material and see the same type of em,;ronment. Therefore, the CoC 1004 AMR results and AMP are applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the Coe 1004 AMR results and AMP are applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the results of the Coe 1004 AMR are applicable to the AHSM and no AMA is required.

These components are made of the same material and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the Coe 1004 AMR results and AMP are applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the CoC 1004 AMR results and AMP are applicable to the AHSM. Note that Coe 1004 Table 1 F-15 erroneously failed to list the NUHOMS"' AMP as a required AMA, e1oen though it listed loss of material as aging effects that require management.

RAls and Responses AHSM SAR AHSM SAR Subcomponent Drawing Drawing Paris NUH-03-4011 NUH-03-4011 Item Nos.

Material A193 GR 87. Or Rear Shield Wall A325, Or A490, Attachment Or A453 GR 660, Hardware (Stud, 15, 16, 17 OrA193CL2, Nut, Coupling GR 88M2 Or Nut)

CL1C GR 88R Or 88RA A193 GR7, Or A325, Or A490, Or A453 GR 660, Vent Cowr Or A193 CL2.

Attachment GR B8M2 Or Embedments 18, 19, 20, 26 CL1C GR 88R (Stud /Nut Or B8RA, A194

/Washer /Washer Gr 2H, GR BM, Plate)

OrA563 GrA, Carbon or Stainless/Steel, A36 Threaded Insert Dayton Superior 22, 27, 28 Carbon Or (for Heat Shields Stainless Steel

& Outlet Vent)

Not Used 23, 50, 51, 52, 73 N/A Flexible Material 24 Richmond Dowel 25, 72, 72A Bar Splicer Door Attachment-Emb edment (Stud, 29, 30, 31 Nut and Coupling Nut)

AHSM Safety Classification ITS ITS ITS Coe 1004 HSM&AMR Results Table Model 152 Table 1F-15 Model 152 Table 1F-15 Enclosure X to E-XXXX Table RAI 15.134 AHSM Coe 1004 Material A193 Gr 87.

A325 or A490 /

A194 Gr2H or A563 Gr A (5 pages)

Coe 1004 Safety Classification ITS NITSl1>

ITS Page 74 of 119 Embedded/

Encased NIA NIA Embedded/

Encased Embedded I Encased NUHOMS AMP NUHOMS AMP Loss of Material NUHOMS AMP NIA NIA NIA NIA None Identified None Required Loss of Material NUHOMS AMP Applicability of CoC 1004 AMR and AMP to AHSM ile the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in an external em.ironment. Therefore, the Coe 1004 AMP is applicable to the AHSM.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in an embedded/encased emnronment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

NIA NIA Toe AHSM Material A706 Gr60 and Carbon Steel is equiv.alent to A615 GR 60 for aging management re\\!ew, i.e., they are all carbon steel. Therefore the Coe 1004 AMR is applicable to the AHSM and no AMA is required.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in an embedded/encased en\\!ronment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

RAls and Responses Subcomponent Parts Cask Alignment Target (Plate, Slud)

Tube Steel and Plate (Embedded)

Expanded Coil Insert Dayton Superior Door Attachment Hardware (Stud /

Nut /Washer I Washer Plate)

Top Block Attachment Bolt Top Block Attachment Hardware (Nut, Washer, Washer Plate)

AHSM SAR Drawing NUH-03-4011 Item Nos.

32, 33 34, 35, 36 37 38, 39, 40, 41 42, 43 44, 45, 46 AHSM SAR Drawing NUH-03-4011 Material A36 Or Stainless Steel A36, Or Stainless Steel, Or A500 GR B Carbon Or stainless Steel A193 GR 87, Or A453 Gr 660, Or A193 CL2, GR 88M2 Or CL 1 C, GR B8ROr B8RA, Or A194 GR 2H, Or 8M, Carbon or Stainless Steel, OrA36 A193 GR 87, Or A325, Or A490, Or A453 GR660, Or A193 CL2, GR 88M2 CL1C, G Or A19 A4 A193 B8M2 GR 88 B8RA, Or Car Or Stainless Steel, Or A36 AHSM Safety Classification NITS NITS ITS ITS coc 1004 HSM &AMR Results Table Model 152 Table 1F-15 Model 152 Table 1F-15 Model 152 Table 1F-15 EnclosureX to E-XXXX Table RAI 15.13-4 AHSM coc 1004 Material A36/ Carbon Steel A194 Gr 2H or A563 Gr A/

Carbon Steel /

A36 (5 pages)

Coe 1004 Safety Classification NITS<1>

N1TS<1>

Page 75 of 119 External I Embedded External External/

Embedded Loss of Material Loss of Material Loss of Material Applicability ofCoC 1004 AMR and AMP to AHSM

~ n-important to safety item that is not in-scope.

erefore, no AMA required. Note that Coe 1004 NIA Table 1F-15 erroneously listed the NUHOMS AMP as a required AMA, e1oen though it listed no aging effects that require management.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 NUHOMS AMP HSM AMP manages the aging effect of stainless steel in an embedded/encased em,ronment. Therefore, the Coe 1004 AMP is applicable to the AHSM.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 NUHOMS AMP HSM AMP manages the aging effect of stainless steel in an embedded/encased emironment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

While the AHSM allows the use of stainless steel NUHOMS AMP material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in an external/embedded emironment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 NUHOMS AMP HSM AMP manages the aging effect of stainless steel in an external emironment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

While the AHSM allows the use of stainless steel NUHOMS AMP material in addition to carbon steel, the Coe 1004 HSM AMP manages the aging effect of stainless steel in an external/embedded en\\ironment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

RAls and Responses Subcomponent Parts DSC Axial Retainer Support Attachment Hardware (Bolt, Stud, Nut, Jam Nut, Washer Plate)

Inner & Outer Heat Shield Support Structure Heat Shield Zee Bracket Heat Shield Attachment Hardware (Stud, Hex Flange Nut)

AHSM SAR Drawing NUH-03-4011 Item Nos.

48 53, 54, 55, 56, 57 58, 59 60 61 49, 62, 63, 64 AHSM SAR Drawing NUH-03-4011 Material A500 GR B, A618, A847, A453, A588 A193 GR B7,

CL2 GRM2,0r A325,0r A490,0r A453 GR 660, Or Stainless Steel, Or A194 GR 2H, OrA563 GRA, OrA36 304 Or316 Stainless Steel 304 Or316 Stainless Steel 304 Or316 Stainless Steel A194 GR 2H, Or A563 GRA, Or Stainless Steel, A193 GR CL2, GR

BBMN, Or AHSM Safety Classification ITS ITS ITS ITS ITS Coe 1004 HSM&AMR Results Table Model 152 Table 1F-15 Model 152 Table 1F-15 Enclosure X to E-XXXX Coe 1004 Material Table RAI 15.13-4 Al-ISM (5 pages)

Coe 1004 Safety Classification Carbon Steel ITS Page 76 of 119 NUHOMS AMP NUHOMS AMP Sheltered Loss of Material NUHOMS AMP Sheltered Loss of Material NUHOMS AMP Sheltered Loss of Material NUHOMS AMP Applicability of CoC 1004 AMR and AMP to AHSM he allowed AHS M material is carbon steel.

erefore, these components are of the same material, i.e., carbon steel, and see the same type of en\\ironmenl. Therefore, the CoC 1004 AMR results and AMP are applicable to the AHSM.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in a sheltered en\\ironment. Therefore, the Coe 1004 AMP is applicable to the AHSM.

These components are made of the same material and see the same type of en\\ironment. Therefore, the Coe 1004 AMR results and AMP are applicable to the AHSM.

While the AHSM allows the use of stainless steel material in addition to carbon steel, the CoC 1004 HSM AMP manages the aging effect of stainless steel in a sheltered en\\ironment. Therefore, the CoC 1004 AMP is applicable to the AHSM.

RAls and Responses AHSM SAR Subcomponent Drawing Parts NUH.03-4011 Item Nos.

Wall Attachment Hardware (Stud, 65, 66, 67, 68, Washer Plate, 69, 70, 71 Nut, Washer)

Birdscreen Strip, 74, 75 Wire Cloth Concrete Anchor 76 Rain Protection 77 AHSM SAR Drawing NUH.03-4011 Material A193 GR 87, Or A453 GR 660, Or A193 CL2 GR BBM2 OrCL1C, GR B8ROr BBRA, Or A36, Or Stainless Steel, A194 GR 2H,Or8M,Or Carbon Steel Stainless Steel Stainless Steel Stainless Steel AHSM Safety Classification ITS NITS NITS NITS Coe 1004 HSM&AMR Results Table Model 152 Table 1F-15 Model 152 Table 1F-15 Model 152 Table 1F-15 (1) Failure of this NITS item would prewn! fulfillment of an important to safely functio *

(2) Drawing NUH-03-4011 does not assign a part number to these subcomponent 1/o EnclosureX to E-XXXX Table RAI 15.13-4 AHSM Coe 1004 Material A193 Gr 87, A325 or A490 /

A36/A194 Gr 2H or A563 Gr A/

Carbon Steel (5 pages)

Coe 1004 Safety Classification ITS NUHOMS AMP NIA NIA NIA Applicability ofCoC 1004 AMR and AMP to AHSM While the AHSM allows the use of stainless steel material in addition to carbon steel, the Coe 1004 HSM AMP manages the aging effect of stainless steel in an external/embedded emAronment. Therefore, !he CoC 1004 AMP is applicable to !he AHSM.

A non-important to safety item that is not in-scope.

Therefore, no AMA required.

A non-important to safety item that is not in-scope.

Therefore, no AMA required.

A non-important to safely item Iha! is no! in-scope.

Therefore, no AMA required.

d specifies the design and construction standards (i.e., Nole 1 on Drawing NUH-03-4011).

Page 77 of 119

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim APPENDIX A.13 AGING MANAGEMENT PROGRAMS Table of Contents A.13. AGING MANAGEMENT PROGRAMS...............................................,.......... A.13-1 Page A.13-i This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim A.13. AGING MANAGEMENT PROGRAMS The aging management programs (AMPs) described in Appendix C, Section C.13 are applicable to the SSCs of the MP187 Cask system.

Page A.13-1 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim APPENDIX B.13 AGING MANAGEMENT PROGRAMS Table of Contents B.13.AGING MANAGEMENT PROGRAMS.................................................

Page B.13-i This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim B.13. AGING MANAGEMENT PROGRAMS The aging management programs (AMPs) described in Appendix C, Section C.13 are applicable to the SSCs of the Standardized Advanced NUHOMS syste Page B.13-1 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim APPENDIX D.13 AGING MANAGEMENT PROGRAMS Table of Contents D.13.AGING MANAGEMENT PROGRAMS.................................................

PageD.13-i This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim D.13. AGING MANAGEMENT PROGRAMS The aging management programs (AMPs) described in Appendix C, Section C.13 are applicable to the SSCs of the 618TH system.

PageD.13-1 This section is newly added.

ML19095B552

Text

References:

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