ML19095B553

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Enclosure 5: Non-Proprietary Draft Safety Analysis Report (SAR) Section C.13, Revision 3
ML19095B553
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Site: Consolidated Interim Storage Facility
Issue date: 04/03/2019
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Consolidated Interim Storage Facility
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Office of Nuclear Material Safety and Safeguards
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Enclosure 5 Non-Proprietary Draft SAR Section C.13

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

C.13.1 Purpose.......................................................................... _............

C.13.2 Methodology.......................................................................

C.13.3 DSC External Surfaces Aging Management Progra C.13.3.1 Scope of Program.......... :.........................

C.13.3.2 Preventive Actions............................

C.13.3.3 Parameters Monitored or Inspect C.13.3.4 Detection of Aging Effects.......

........................... C.13-6 C.13.3.5 Monitoring and Trending....................,....,..................................... C.13-8 C.13.3.6 Acceptance Criteria........................................................................ C.13-8 C.13.3.7 Corrective Actio,

........................... C.13-10 C.13.3.10 s, or in the Path of Effluent

...................................................... C.13-14

......................................................... C.13-14

............................................................... C.13-16 d Trending.................................................................. C.13-20 Criteria........................................................................... C.13-20 onfirmation Process........................................................................ C.13-23

..

  • Administrative Controls.................................................................... C.13-23 Operating Experience............................................................... C.13-23 SM Aging Management Program for External and Internal Surfaces........................................................................................-.................. C.13-26 C.13.5.1 Scope of Program.............................................................................. C.13-26 Page C.13-i This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.5.2 Preventive Actions............................................... :............................ C.13-27 C.13.5.6 Acceptance Criteria......................................................................... C.13-29 C.13.5.7 Corrective Actions....................................................,................. C.13-32 C.13.5.8 Confirmation Process................................................................ C.13-32 C.13.5.9 Administrative Controls..........................,..................................

C.13.5.10 Operating Experience...............

Page C.13-ii This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim List of Tables Table C.13-1 DSC AMP for the Effects of CISCC Tollgates............................................ C.13-40 Page C.13-iii This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13. AGING MANAGEMENT PROGRAMS C.13.1 Purpose This chapter describes the aging management programs (AMPs) ere,* di or managing each of the identified aging effects for the in-scope structures, sy em and components (SSCs) of the NUHOMS related dry storage sys lJro

~l~~t~~~:~~i~:~~:~~in~0:i~~~;:;!;~~~i~~~~~~'~eiJ, ss~rf r11~

, 11ciioh

~tfue:!SSG~. The AMPs are based on the results of th g management r ~..

(AMR) for the dry shielded canisters (DSCs), hori storage modules (HS concrete basemat presented in [C.13-29].

The AMPs developed to manage aging effi -;

DSC External Surfaces Aging Managem DSC Aging Management Program for the E Corrosion Cracking ( appli le to DSC)

Horizontal Storage Mod I Surfaces (applicable to H 1.

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

r External and Internal

.

  • c sense, and are intended e NUHOMS related dry

WCS Consolidated Interi.m Storage Facility Safety Analysis Report Revision 3 Interim C.13.2 Methodology The AMPs are based on the AMPs approved for the renewal of CoC 1004 [C.13-29 and C.13-30]. The structure of the AMPs is consistent with the 10 progra, elements described in NUREG-1927 [C.13-1], as follows:

1.

Scope of the program: The scope of the program includes th subcomponents subject to the AMP and the intended safe maintained. In addition, the element states the specific and aging mechanisms and effects to be managed.

2.

Preventive actions:

of aging for SSCs.

3.
4.

ion and monitoring ric, surface

  • ,, ** g of inspections to in ormation in this a "ho ' (l),;

e AMP (i.e., the specific part of the inspection or monitoring as" are defined as surfaces of in-scope SSCs and subcomponents s

lly inspected by direct or remote means.

~=~=d=in=: This element describes how the data collected will be This includes an evaluation of the results against the acceptance a, d an evaluation regarding the rate of degradation to ensure that the

, the next scheduled inspection will occur before there is a loss of cl safety function.

e tance criteria: Acceptance criteria, against which the need for corrective action will be evaluated, ensures that the SSC intended safety functions and the approved design bases are maintained during the period of extended operations.

Page C.13-2 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim

7.

Corrective actions: Corrective actions are the measures taken when the acceptance criteria are not met. Timely corrective actions, including root cause determination and prevention of recurrence for significant conditions adverse to quality, are critical for maintaining the intended safety functions oft SCs during the period of extended operations.

8.

Confirmation process: This element verifies that preventive and that effective appropriate corrective actions have bee confirmation process is commensurate with TN Ameri Subpart G Program. The QA Program ensures that includes provisions to preclude repetition of si quality.

9.

Administrative controls:

approval process in accordance with

10. Operating experience: The operating expe a determination that the effects of aging will SSC intended safety funcf swill be maintaine operations. Operating e each AMP program elem t of the program supports tely managed so that the the period of extended the effectiveness of extended operation" is as first placed in service, torage Installation (ISFSI), or nuclear the HSM and basemat).

Page C.13-3 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report C.13.3 DSC External Surfaces Aging Management Program C.13.3.1 Scope of Program This AMP applies to all DSCs except those where the AMP in Section management for the effects of chloride-induced stress corrosion era applies.

This program visually inspects and monitors the external su be subject to loss of material and cracking. The program s surfaces of the DSC shell assembly. The areas ofDS Fabrication welds of the confinement bound zone (RAZ), i.e., longitudinal and (if any) cylindrical shell, Crevice locations, e.g., where the shell The upper surface of the cylindrical shell,

settle, The top and bottom end Revision 3 Interim ment boundary, but their condition must rt. As vertical surfaces out of the main path the effect of atmospheric deposits.

y be limited during storage, but prior to r is pulled into a transport cask.

effects requiring management for the external 11 assembly (to maintain confinement, shielding structural, heat bility intended safety functions) are as follows:

ponents subject to AMR are constructed of the following Steel - shell assembly shell assembly components subject to AMR are exposed to the following e

ironments:

Sheltered Page C.13-4 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.3.2 C.13.3.3 Aging Effects Requiring Management The following aging effects associated with the DSC shell assembly components require management:

Loss of material due to crevice and pitting corrosion for stainless components Loss of material due to galvanic corrosion for the DSC s lubricant a~ the sliding rail surface Loss of material due to radiation-induced crevice stress corrosion cracking (SCC) for stainless st Cracking due to SCC for stainless steel co and aggressive chemicals in the environ

- ds and HAZs, and crevice locations near the DSC support rails idi ontinuities and imperfections.

ef rs Monitored or Inspected for Identified Aging Effects Aging Mechanism Parameter(s) Monitored Crevice Corrosion Surface Condition Pitting Corrosion Surface Condition Galvanic Corrosion Surface Condition Stress Corrosion Cracking Surface Condition, Cracks Page C.13-5 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.3.4 Detection of Aging Effects A minimum of one DSC from each originating ISFSI, is selected for inspection. The DSC(s) selected for inspection is based on the following considerations/c *1; ria which provide the basis for selection of a bounding DSC(s):

1.

Time in service: Storage duration (time in service at origina *,.

CISF) is related to surface temperature and deposition of DSC(s) selected for inspectfon is from the pool of DSC service.

2.

Initial heat load: The DSC selected for inspec *,

3.
4.

low initial heat loading that result in low D increasing relative humidity inside the H contaminants.

ion can e conducted remotely by inserting high-resolution remote pan-

) cameras or fiber optics through the HSM vents or through the annular gap betwe., i e DSC and HSM front door opening. Visual examinations follow e nsistent with the ASME Code,Section XI, IWA-2200 [C.13-3].

e HSM cavity, certain surface areas of the DSC may be inaccessible for ne, @

camera. This program addresses detection of aging affects for inaccessible s by the inspection findings in accessible areas.

As much of the DSC surface as can be accessed is examined by VT-3 to ascertain its general condition, including evidence of water stains, discoloration, and surface deposits.I Page C.13-6 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Areas subject to VT-I I examination are:

the confinement boundary weld seams and their HAZ, the confinement boundary adjacent to the sliding rail surface that it r the confinement boundary surfaces with water staining or with indicative of corrosion products observed by the VT-3 inspec

  • the outer top cover plate, welds, and HAZ, if accessible, completely withdrawn into the transfer cask.

Less than 100% coverage is acceptable if ISP can de,

for inspection bound or are representative of the b rate that the area of the subject area.

and stains ( cause pearance and

, orded.

._=mination system shall be, as a minimum, capable of detecting flaws wable flaws in ASME B&PV Code Section XI IWB-3514.3 orming visual examinations shall be qualified and certified in th ASME XI, IWA-2300, including the requirements of ASME XI, 1 According to ASME Section XI IW A-2211, the VT-1 visual examination is conducted to detect discontinuities and imperfections on the surface of components, including such conditions as cracks, wear, or corrosion. The VT-1 examination procedure is capable of resolving demonstration characters height of 1.1 mm in accordance with ASME Section XI Table IWA-2211-1 "Visual Examinations." Remote inspection camera resolution capability shall meet VT-1 illumination, distance, and character height requirements for examination effectiveness.

Page C.13-7 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Qualification of other NDE personnel shall be in accordance with ASME XI, IWA-2300. Personnel performing ultrasonic examinations shall also meet the additional certification requirements of ASME XI Appendix VII. In addition, they shall have a current certification for ASME XI, Appendix VIII, Supplem, 2, for detection, depth sizing, and length sizing of intergranular stress corros *,

~ acking (IGSCC) in austenitic materials.

C.13.3.5 Monitoring and Trending A baseline inspection is performed as part of the monitorin that the inspection results can be used for subsequent., ing. Deficiencie documented using approved processes and proced ch that results can be

~,,

and corrected. This monitoring is conducted in e@

TN Americas 10 CFR Part 72, Subpart G Pro, a,.

C.13.3.6 Acceptance Criteria remote digital camera is bas (ASME Section XI Table IW -

degradation detected are evalu action program.

erica's corrective xamination are no indications of pitting, rface degradation.

a as evidenced by red-orange corrosion ating from crevice locations (support rail plate-to-DSC shell

,, rosion products near crevices tions of corrosion products on or adjacent to confinement boundary If, base ©, he results of the inspection, the DSC is determined to be free of any

==*- of corrosion or other degradation that could lead to the loss of intended

  • , no further actions are necessary until the next inspection.

Page C.13-8 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C

If the DSC is determined to contain confirmed or suspected indications of corrosion or degradation, additional engineering evaluations are performed to demonstrate that the DSC will remain able to perform its design bases functions until the next inspection.

ASME Code Section XI provides specific rules for evaluating flaw indica

  • ns that may be detected during the inspections. If flaw indications are found,, e geometry is determined from the inspection results in accordance w. *,,. ction XI, IWA-3300 [C.13-3]. The flaw dimensions are assessed and corn ith the allowable flaw dimensions in Section XI, IWB-3514 [C.13-3 the flaw size is less than the allowable flaw size in the I standards, the flaw is acceptable with no need for furthe exceeds the allowable flaw size in the IWB-3514.1 a must be evaluated using the acceptance criteria in ASME Section XI Appendix C [C.13-3] may b il!ISe When visual examination detects evidence will be further examined to determine the ex additional information would be that required to nature of the defects observed:

Surface-connected crac examination, for evaluat1 IWB-3514.3.

Surface-connected crack len both, for evaluation in accor Page C.13-9 This section is newly added.

y eddy current, UT, or rIWB-3640.

  • wcs Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.3. 7 Corrective Actions Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented according to the requirements of Americas 10 CFR Part 72, Subpart G Program. 1N America's correcti. a program ensures that conditions adverse to quality are promptly ide,

corrected, including root cause determinations and prevention of Deficiencies are either corrected, or are evaluated as acceptab.

through engineering analysis, which provides reasonable a, ra ce th

,Ji.

  • function is maintained consistent with current licensing as onditions.

performed to assess conditions associated with aging

' ; to follow the sa methodology used in the licensing and design basi ~al lations. Extent of con investigation may trigger additional inspections aifferent method, increase inspection frequency or expanded inspection e size, as d.. ribed next.

Identification oflocalized corrosion or stres

, ion c e,i g requires an expansion of the sample size to determine the extent of co, iit,',

confirmed localized corrosion or stress corrosion Confirmation of localized corrosi additional can*

for additio, *

  • thermal

., s rate with in-service inspection results:

rust deposits that are determined to be a result of iron

-~~*.::t do not have evidence of localized corrosion or stress corrosion Canis e that show evidence oflocalized corrosion or stress corrosion cracking that d. s ot exceed the acceptance standards in IWB-3514.1 are permitted to rem *,, service and will be evaluated at 5-year intervals. Sample size should be ea d to assess candidate canisters with similar susceptibility assessments as mined from the selection criteria in Section C.13.3.4.

Page C.13-10 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Canisters that show evidence of localized corrosion or stress corrosion cracking that exceeds the acceptance standards in IWB-3514.1 but meet the acceptance criteria identified in IWB-3640 including the required evaluation per IWB-3641(a) using the prescribed evaluation procedures, are permitted to re ain in service and should be evaluated at 3-year intervals. Sample size s

  • Ill increased to assess candidate canisters with similar susceptibil
  • determined from the selection criteria in Section C.13.3.4.

C.13.3.8 Confirmation Process Confirmatory actions, as needed, are impleme action program. See also Section C.13.3.7.

C.13.3.9 Administrative Controls Page C.13-11 This section is newly added.

America's corrective

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim In 2012, Calvert Cliffs performed an inspection of the interior of two NUHOMS HSMs, and the exterior of the DSCs as part of their license renewal application. The first module examined was HSM-15, which was loaded in November 1996 and contained the "lead canister" to meet NUREG-1927 [C.13-28] Appendix. uidance.

The second module inspected was HSM-1, which was loaded in Nave 993 (the first loading) and represents one of the lowest heat load canisters ev.

cled (estimated at 4.2 kW (as of the time of inspection)). The latter s le ental canister was added as part of the Electric Power Research Institute (E efforts on evaluating stress corrosion cracking of stainless steel canis The EPRI research effort included salt concentration me su ents on tH of the DSC, collection of samples of the deposits on, e N* er shell of the offsite analysis, and surface temperature measurem6.'nt:ruJ.,

benchmarking best-estimate thermal models.

The visual inspection was conducted by re, 0te controlled high definition PTZ camera syste by lowering the camera through the rear outlet. Fl,

majority portion of the DSC. The direct inspection a partially open door by mounti

, e camera on a pole.

ood general con?ition. The center s were examined and no rust spots or signs plug circumferential weld could not be s, el sleeve of the HSM doorway opening. A n

e DSC shell base metal. Calvert Cliffs st on the shell were the result of n during fabrication or handling prior to being ree iron contamination can occur when carbon or low-alloy steel tact with the surface or particles that are transferred to the stainless ding, welding, or cutting of carbon or low-alloy steel. Rusting filie iron

, e expected to have occurred fairly quickly once the outside.

,}

DSC w xposed to water, which happens during the normal course of loading em the TC annulus is filled with demineralized water. The resulting light coating of ace rust wo*uld be cosmetic in nature, and would not result in degradati, t the stainless steel shell of the DSC in the sheltered environment of the HSM,,

, therefore, not believed to be a current challenge to the confinement DSC-6. Calvert'Cliffs has initiated a condition report to evaluate these s in further detail to determine if additional and/or more frequent monitoring is

., 1.red to conclusively ascertain their nature, and then take appropriate corrective

. action if their presence is determined to represent a potential challenge to the confinement function of the DSC.

Page C.13-12 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The shell ofDSC-11 (the lower heat load canister) was observed to be in good condition, and no signs of the rust were noted on the base metal or welds. A linear wear mark was noted running the length of the lower shell ofDSC-11 near the inner side of the west rail. This mark is believed to be from the demonstration ependent Spent Fuel Storage Installation loading campaign that was conducted te o the start of formal loading operations in 1993. During that demonstration, D. -

was loaded with dummy fuel assemblies (FAs) and inserted into an RSM, a

,,e withdrawn.

Verbal discussions with individuals who worked on the first 1 ign indicated that when the DSC-11 was used for an actual Joa..,

  • twas from the position used for the demonstration not to slide it along l,

twice. No signs of corrosion were noted on this wear from sliding on the Nitronic 60 stainless steel surf:,.

the rail, the lack of co, s:01 on this wear mark compared with that of the sc *,, n DSC-6, lends additional credence to the idea that the rust on the latte, 0s ed throug, ntact with carbon o low-alloy steel. The bottom end of both D ared po *

., free of corrosion and in very good condition. Both grapple rings w appeared to be in good condition.

Learning AMP The "DSC External Surfaces

" earning" AMP. This ncorpo

  • e new information on inspection findings, cific and industry OE is nd industry OE will continue through the this AMP continues to be effective in i

s of OE in the future may identify areas ated, or if a new program should be effectiveness of this AMP under its QA program used to meet the 72, Subpart G [C.13-5 and C.13-26].

Page C.13-13 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.4 DSC Aging Management Program for the Effects of CISCC (Coastal Locations, Near Salted Roads, or in the Path of Effluent Downwind from the Cooling Tower(s))

C.13.4.1 Scope of Program This AMP is applicable to DSCs from ISFSis that may have sufficie, chlorides to initiate CISCC.

This AMP is applicable to DSCs from ISFSis chlorides to initiate CISCC within the period of e n,, e, operation. ISP may demonstrate that this AMP is n t applicable by one g can b complished by using airborne particulate monitors or other monitorirr, tions specific to airborne chloride measurement. The airborne chloride concentrat©, data should follow Environmental Protection Agency Clean Air Status and Tren

  • twork (CASTNET) protocol. CASTNET measures weekly

, s of chloride using a three-stage filter pack with a controlled flow rate, e results are presented in ~Lg/m3*

SC AMP for the Effects of CISCC comprises three distinct processes:

ISFSI specific applicability evaluation to determine if this AMP is applicable to the DSC DSC surface monitoring for chlorides, and Page C.13-14 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Remote visual inspection for aging effects This program visually inspects and monitors the external surfaces of the DSC shell assemblies that may be subject to loss of material or CISCC. The progra includes the external surfaces of the DSC. The areas of DSC inspectio Fabrication welds of the confinement boundary and the assoc*,.,

zone (HAZ), i.e., longitudinal and (if any) circumferential e,

cylindrical shell, Crevice locations, ~-, where the shell sits on the s The upper surface of the cylindrical shell, wher

settle, The top and bottom ends of the cylinder Outer bottom cover plate, grapple asse,

Outer top cover plate, welds and HAZs.

The last two areas are not part be ascertained prior to retrie of air flow, they are the least s Accessibility to the outer top c e

transport, it can be inspected aft The materials shell stainl of efflu cts requiring management for the DSC tal location, near salted roads, or in the path er(s) (to maintain confinement, shielding,

, tended safety functions) are as follows:

mbly components subject to AMR are exposed to the following Page C.13-15 This section is newly added.

I.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.4.2 C.13.4.3 Aging Effects Requiring Management The following aging effects associated with the DSC shell assembly components require management:

Loss of material due to crevice and pitting corrosion for stainles components, Loss of material due to galvanic corrosion for the DSC s lubricant at the sliding rail surface, Cracking due to CISCC for stainless steel compon,

and aggressive chemicals in a coastal location, effluent downwind from the cooling tower(s,

Loss of material due to radiation-induce SCC for stainless steel DSC shell.

, pection portion of the AMP consists of visual inspections to monitor for radation of the DSC shell assembly.

C surfaces, welds and HAZs, and crevice locations near the DSC support rails*

are visually inspected for discontinuities and imperfections.

Page C.13-16 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Parameters Monitored or Inspected for Identified Aging Effects Aging Effect Aging Mechanism Pararneter(s) Monitored Loss of Material Crevice Corrosion Surface Condition Loss of Material Pitting Corrosion Loss of Material Galvanic Corrosion

  • cracking Stress Corrosion Cracking C.13.4.4 Detection of Aging Effects A minimum of one DSC from each originating DSC(s) selected for inspection is based on t provide the basis for the selection of a bou
1.
2.
3.

pool ofDSCs with ce temperatures, thus oting incubation of ambient ations: A review of the design drawings ed to further screen-in the DSC(s) from (1) and (2). Fabrication weld maps, if ity locations of the circumferential and as, and exte nfigurations of the inner bottom cover-to-shell ME Figure NB-.4243-1 ( c )). These features are verified against the ings for the specific DSC(s) under consideration for inspection.

tion relative to climatolo ical and eo ra hical features:

oriented such that the inlet vent openings face the prevalent wind, 'ii! ction are to be considered for inspection, particularly if the wind direct @

  • s in the path of potential sources of chloride aerosol contaminants ( e.g.,

off-s ID

, salted roads, cooling towers, if present).

ections and surface sampling for chlorides are performed at intervals of 5 year. The+/- 1 year is provided for inspection planning and potential limited

, ability of vendor remote non-destructive examination (NDE) equipment. The first examination will be performed on the selected DSC(s) prior to entering their period of*

extended operation. The same DSC(s) are used for each subsequent examination for trending.

Page C.13-17 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Visual inspection, surface deposit sampling, and other NDE can be conducted remotely by inserting the inspection and/or sampling devices through the HSM vents or through the annular gap between the DSC and HSM front door opening. Visual examinations follow procedures consistent with the ASME Code, Sectio

, IWA-2200 [C.13-3].

Within the HSM cavity, certain surface areas of the DSC may be* 1 inspection. This program addresses detection of aging affects the inspection findings in accessible areas.

As much of the DSC surface as can be accessed is ex general condition, including evidence of water stai deposits.

Areas subject to VT-12 examination are the confinement boundary weld seams arr the confinement boundary adjacent to the sli the confinement bounda indicative of corrosion p,

2 According to ASJ.v.lE Section XI IW A-2211, the VT-1 visual examination is conducted to detect discontinuities and imperfections on the surface of components, including such conditions as cracks, wear, or corrosion. The VT-1 examination procedure is capable of resolving demonstration characters height of 1.1 mm in accordance with ASJ.v.lE Section XI Table IWA-2211-1 "Visual Examinations." Remote inspection camera resolution capability shall meet VT-1 illumination, distance, and character height requirements for examination effectiveness.

Page C.13-18 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim stem shall be, as a minimum, capable of detecting flaws sizes flaws in ASME B&PV Code Section XI IWB-3514.3 [C.13-3].

formin

  • ual examinations shall be qualified and certified in "th ASME XI, IWA-2300, including the requirements of ASME XI, Qualific,, of other NDE personnel shall be in accordance with ASME XI, m*. Personnel performing ultrasonic examinations shall also meet the al certification requirements of ASME XI Appendix VII. In addition, they ave a current certification for ASME XI, Appendix VIII, Supplement 2, for de ection, depth sizing, and length sizing ofIGSCC in austenitic materials. Inspection procedures and personnel for surface sampling are qualified in accordance with site-controlled procedures and processes, as prescribed in the TN Americas 10 CFR Part 72, Subpart G Program.

Page C.13-19 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.4.5 Monitoring and Trending A baseline inspection is performed as part of the monitoring and trending activities so that the inspection results can be used for subsequent trending. Deficienc

  • documented using approved site processes and procedures, so that res trended and corrected. This monitoring should be conducted i~ acco TN Americas 10 CFR Part 72, Subpart G Program.

C.13.4.6 Acceptance Criteria The acceptance criteria are defined to ensure that the be identified before loss of intended functions. Vis remote digital camera is based on ASME VT-3 (ASME Section XI Table IWA-2211-1) [C.1 degradation detected are evaluated for con

  • action program.

evidenced by red-orange corrosion ations (support rail plate-to-DSC shell Its of the inspection, the DSC is determined to be free of any or other degradation that could lead to the loss of intended

. s are necessary until the next inspection.

Page C.13-20 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim If the DSC is determined to contain confirmed or suspected indications of corrosion or degradation, additional engineering evaluations are performed to demonstrate that the DSC will remain able to perform its design bases functions until the next inspection.

ASME Code Section XI provides specific rules for evaluating flaw indic ns that may be detected during the inspections. If flaw indications are found, geometry is determined from the inspection results in accordance w:,

IWA-3300 [C.13-3]. The flaw dimensions are assessed and com allowable flaw dimensions in Section XI, IWB-3514 [C.13-3 the flaw size is less than the allowable flaw size in the I standards, the flaw is acceptable with no need for furthe e exceeds the allowable flaw size in the IWB-3514.1 aC'~~lffllln must be evaluated using the acceptance criteria in ASME Section XJ Appendix C [C.13-3] may b

  • when visual examination detects evidence,

will be further examined to determine the ex additional information would be that required t nature of the defects observed:

examinati9n, for evaluat1 IWB-3514.3.

y eddy current, UT, or rIWB-3640.

such as crevice corrosion or concentrated rosion would be determined by visual shell thickness in accordance with ASME 1 1 e locations, further evaluation of the aging

  • le locations is conducted via 1N America's corrective action the aging effect is adequately managed and that the component's aintained during the period of extended operation.

Page C.13-21 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.4. 7 Corrective Actions Site QA procedures, review and approval processes, and administrative controls are implemented according to the requirements of the TN Americas 10 CFR 72, Subpart G Program. TN America's corrective action program ensures,

adverse to quality are promptly identified and corrected, including r © use determinations and prevention of recurrence. Deficiencies are eit rrected or are evaluated to be acceptable for continued service through engi.

provides reasonable assurance that the intended function is, 0i

  • ine current licensing basis conditions. Evaluations performe t sess cond1.~~...

associated with aging need to follow the same metho

, * :Y used in the lice

.ngi design basis calculations. Extent of condition inve !l *

  • n may trigger additio inspections via a different method, increased in n frequency and/or expand,

inspection sample size, as described next.

Identification of localized corrosion or stres of the sample size to determine the extent of co confirmed localized corrosion or stress corrosion continued service. Canisters w

  • do not meet the prescribed e 1,

.,,,s rate with in-service inspection results:

10n are permitted to remain in service and year intervals with no expansion of sampling.

rust deposits that are determined to be a result of iron t do not have evidence of localized corrosion or stress corrosion Canis e that show evidence of localized corrosion or stress corrosion cracking that d ~s ot exceed the acceptance standards in IWB-3514.1 are permitted to service and will be evaluated at 5-year intervals. Sample size should be d to assess candidate canisters with similar susceptibility assessments as mined from the selection criteria in Section C.13.4.4.

Page C.13-22 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Canisters that show evidence of localized corrosion or stress corrosion cracking that exceeds the acceptance standards in IWB-3514.1 but meet the acceptance criteria identified in IWB-3640, including the required evaluation per IWB-3641(a), using the prescribed evaluation procedures, are permi. to remain in service and should be evaluated at 3-year intervals. Sample siz s, k1 d be increased to assess candidate canisters with similar susceptibil

  • a essments as determined from the selection criteria in Section C.13.4.4.

Canisters that show evidence of localized corrosion or s es o

  • {;), cracking that exceeds acceptance criteria identified in IWB-3641 not per,,,fe, to
  • remain in service. Sample size should be increase,, assess candidate *'a,
  • ers with similar susceptibility assessments as deter ri,. from the selection Section C.13.4.4.

C.13.4.8 Confirmation Process Confirmatory actions, as needed, are impleme action program. See also Section C.13.4.7.

C.13.4.9 Administrative Controls Administrative controls under America's corrective ustenitic Stainless Steel and Maintenance of Dry Cask Storage System Canisters", cribes the potential for CISCC of austenitic stainless steel DCS canisters.,ii : CC could affect the ability of the spent fuel storage canisters to perform their c

, ment function during the period of extended operation. Several instances f C.

ave occurred in austenitic stainless steel components that were exposed to eric conditions near saltwater bodies.

Page C.13-23 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim In the fall of 2009, three examples of CISCC, which extended through-wall, were*

discovered at a nuclear station in the weld HAZ of Type 304 stainless steel piping.

The piping included 24-inch, Schedule 10 emergency core cooling system (ECCS) suction piping; 6-inch, schedule 10 alternate boration gravity feed to cha i" line piping; and an ECCS mini flow return to refueling water storage tank.

,

  • the through-wall failures were attributed to CISCC, surface pitting was
  • the surface *of the pipes, with a greater concentration in the weld were exposed to the outside ambient coastal atmosphere. Thr developed after an estimated 25 years of service.

ed from the DSC surface has been

,e e salt deposits collected on the actual canister

. e also contain other inorganic multiple species together with chloride

-7, C.

-8 13-9]. The visual inspection on the DSC surfaces showed that the

, en, izonta: m, ce of the DSC canister was covered with dust layers of soil/clay and c,, G - e cons *, e, while the canister side and lower parts were visually metallic.

analys1 ID the deposits collected from the upper horizontal surface taken from the clock position showed a relatively high concentration of sulfate, phosphat nitrate with little amount of chloride content (highest measured concentra was 5.2 mg/m2). The major cations in the deposits were silicon, iron, and cal *,,, along with lower levels of magnesium, aluminum, potassium, titanium, nd

  • G.

-ray diffraction analysis revealed multiple crystal phases of the deposits g calcium carbonate, aluminum hydroxide, and silicon containing oxide or tes complex. No visual indications of cracking were noted from the inspection.

Page C.13-24 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim As demonstrated from the inspection results at the Calvert Cliffs ISFSI, the deposits accumulated on the canister surfaces in particular for the upper horizontal surface area contained multiple other soluble and non-soluble species together with chloride content. These other types of anions and cations can affect chemistry oft deliquesced chloride salt solution. For example, the alkaline nature of,

ncrete constituents such as calcium carbonates and aluminum hydroxide c,, a, to buffer the acidic deliquesced salt brine to be more benign. This is consiste i :}, the buffering effect of carbonate and alumino-silicate that reduced the loca *

, @

  • n of Alloy 22 in brine in geologic depository studies. To some as nitrate and sulfate, and metal cations are also known corrosion of stainless steel and aluminum. At this ti.,, ever, it is unkno,

the presence of the other species would affect the e.. tibility of the stainless canister to CISCC.

LeamingAMP MP under its QA program used to meet

.13-5 and C.13-26].

omg is AMP requires periodic written evaluations as descri

, ~,

le C.13-1, of the aggregate impact of aging-related DSCs OE, rch, m :t0

  • g, and inspections on the intended safety functions of the in-scope

@'s bcom m 1 ~ s (i.e., tollgates). While new information relevant to aging

-z:,;.:=:.i.*t is as se as it becomes available, in accordance with normal corrective progr ~; tollgates are an opportunity to seek other information that

  • ble and to perform an aggregate assessment. Tollgate assessments are oints. No action, other than performing an assessment and addressing

. gs in TN America's corrective action program, is required to continue operatia,.

llgate assessment reports are not required to be submitted to the NRC, 1lable for inspection. Appendix A ofNEI 14-03 [C.13-2], provides g *, a, e on the performance criteria for the tollgate assessments.

T e tollgate schedule may be accelerated (i.e., the next tollgate is performed earlier) whenever sufficient new information has accumulated that could warrant a change in the AMP.

Page C.13-25 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.5 HSM Aging Management Program for External and Internal Surfaces C.13.5.1 Scope of Program The scope of the HSM AMP for external and internal surfaces progra inspection of accessible concrete and steel components including H and floor slab (if applicable), HSM access door, DSC support str assembly, heat shields, air inlet and outlet vents, embedments structural connections including anchor bolts, cast-in-place *,,

o mounting hardware). This AMP also examines the ISFSI s ~ge pad for.

concrete degradation.

The materials, environments;and aging effects r interior and exterior surfaces and structural c""2;H~,u structural, heat transfer, and retrievablity i e Materials Reinforced concrete Carbon steel Stainless steel are exposed to the following aging effects associated with the HSM structural components require

  • material (spalling, scaling) and cracking due to freeze-thaw actions for

, reed concrete, racking; loss of bond; and loss of material (spalling, scaling) due to corrosion of embedded steel for reinforced concrete; Cracking due to expansion from reaction with aggregates (alkali-silica reaction (ASR)) for reinforced concrete, Page C.13-26 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Increase in porosity and permeability; cracking; loss of material (spalling, scaling) due to aggressive chemical attack for reinforced concrete, Cracking due to increased stress levels from settlement for reinforced Loss of material due to general, pitting, and crevice corrosion for components, Loss of material due to pitting and crevice corrosion for al steel components, and Loss of material due to galvanic corrosion of Nitro C.13.5.2 Preventive Actions C.13.5.3 The program is a condition monitoring program t actions.

pon,

ameters monitored or des, standards, and guidelines and I 349.3R [C.13-11] and ANSI/ASCE 11 selection of parameters to be monitored or lements.

red include: (1) cracking, loss of bond, and e to corrosion of embedded steel, freeze-thaw, ical attack; (2) cracking due to expansion from reaction with

) increase in porosity and permeability due to leaching of calcium

, ation or aggressive chemical attack; ( 4) reduction of concrete

  • N. o local concrete degradation; ( 5) cracking and distortion due

@n: of below-grade concrete is monitored by groundwater chemistry

, e following parameters:

Page C.13-27 This section is newly added,

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Carbon steel, stainless steel, and aluminum components are monitored for loss of material due to general, pitting, galvanic corrosion, and crevice corrosion. Other conditions such as loose or missing anchors, and missing or degraded grout are also part of the inspection.

For coated HSM carbon steel subcomponents, this AMP manages 1 integrity due to blistering, cracking, flaking, peeling, or physical C.13.5.4 Detection of Aging Effects Visual inspections of the exterior and interior surfaces structural components and the accessible portions prior to entering the period of extended operatio year thereafter, consistent with industry stand,

groundwater chemistry sampling is perfor operation and every 5 years +/- 1 year therea.

corrosive environment existing in the area oft inspection planning and potential limited availab1 equipment. The same HSM(s) 11 be used for each purpose of trending.

ctions by personnel qualified to monitor ging effects, such as those described in the 3-13], and ANSI/ASCE 11 [C.13-14].

istry sampling is used to monitor the condition of the below-grade s of the storage pad.

hould be consistent with industry guidelines and standards.

s of ins

M cavity, certain surface areas are inaccessible for remote camera

.. g., concrete surfaces behind heat shields, portion of the interior rear

. This program addresses detection of aging affects for inaccessible areas I

  • spection findings in accessible areas.

ential degradation of the below-grade portion of the concrete pad is assessed by results of groundwater sampling at a minimum of three locations in the area of the ISFSI at a frequency of five years.

Page C.13-28 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.5.5 Monitoring and Trending The first (baseline) inspection ascertains the condition of the HS Ms at the beginning of the period of extended operation. The conditions of the HS Ms observed i ubsequent inspections are compared with the baseline conditions of the HSMs fo purposes.

ACI 349.3R [C.13-11] prescribes that crack maps should bed and trended as a means of identifying progressive growth o degradation due to specific aging effects such as ASR-indu expansio

,i;.e thaw, or corrosion ofrebar. Crack maps should be co

, a" d with those fro inspections to identify accelerated degradation oft i

extended operation.

Deficiencies are documented using approv.

can be trended and corrected. This monitori provisions of TN Americas 10 CFR Part 72, S C.13.5.6 Acceptance Criteria The HSM AMP for external evaluated by qualified enginee

, of the following indications of relevant degradation detected ee pitting, and galvanic corrosion (loss of material),

©

, flaking, or oxide-coated surfaces (loss of material),

orrosion stains on adjacent components and structures (loss of material),

Surface cracks ( cracking), or Stains caused by leaking rainwater Page CJ3-29 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim For carbon steel surfaces, one acceptable method for characterizing and quantifying the amount of corrosion (rust) present on a painted steel surface is ASTM D610-08

[C.13-16]. This test method covers the evaluation of the degree of rusting (spot rusting, general rusting, pinpoint rusting, and hybrid rusting) using visua ndards and descriptions of 11 rust grades. In.this method, Rust Grade 10 corr tl ~, s to no rust or less than 0.01 % of surface rusted, Rust Grade 4 corresponds *©:

ting greater than 3% to the extent of 10% of surface rusted, and Rust Grade ponds to approximately 100% of surface rusted. In addition to determi *!lir s *, ce of the corrosion, noted degradation shall be trended and evaluate Ill, r TN corrective action program.

For stainless steel and aluminum HSM subcompo support structure (HSM Model 152 only) heats characterization method similar to ASTM D and trend crevice and pitting corrosion, if Concrete Components Inspection parameters for cone nt acceptable e inactive. These ction are considered acceptable without Absence of corrosion staining of undefined source on concrete surfaces, Page C.13-30 This section is newly added.

  • 1 WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Passive settlements or deflections within the original design limits.

The acceptance criteria for the groundwater chemistry sampling program are:

pH~ 5.5 Chlorides :S 500 ppm Sulfates :S 1500 ppm These criteria are consistent with guidance provided in N__,_~

would demonstrate that the ISFSI concrete pad is not e and groundwater environment. For sites that exceed,.

with an aggressive soil and groundwater environ pad AMP is to be implemented as part of corr f If aging effects are identified in accessible, ea,*

effects in inaccessible locations is conducted

  • program to ensure the aging effect is adequately intended function is* maintained during the period o Coatings sms, in accordance with ASTM D4538-05 re as follows:

eparation of one or more coats or layers of a coating from the substrate tion - separation of one coat or layer from another coat or layer or from

., strate

  • sting - corrosion that occurs when the applied coating thickness is insufficient o completely or adequately cover steel surfaces Physical Damage - removal or reduction of thickness of coating by mechanical damage Page C.13-31 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Repair, rehabilitation, or corrective action of an unacceptable condition should be performed in accordance with an applicable rehabilitation standard such as ACI 224.lR [C.13-20], ACI 364.lR [C.13-21] or ACI 562-13 [C.13-22].

C.13.5. 7 Corrective Actions Site QA procedures, review and approval processes, and adminis implemented according to the requirements of TN Americas 1 G Program. TN America's corrective action program ensur

,l,i con "itli,

to quality are promptly identified and corrected, including,

  • cause de and prevention of recurrence. Deficiencies are either ted or are evalu acceptable for continued service through engineeri a,
  • ysis, which provides reasonable assurance that the intended function *,,
  • tained consistent with cu nd design basis s corrective action ethod, increased C.13.5.8 Confirmation Process Confirmatory actions, as neede
  • action program. See also Sectio merica' s corrective C.13.5.9 Page C.13-32 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13.5.10 Operating Experience The HSM AMP for external and internal surfaces is modeled after the regulatory philosophy of 10 CFR 50.65 [C.13-10] structures monitoring program. St ctures monitoring programs have been implemented for managing aging effe,s,, rmg the extended period of license renewal of the operating reactor plants.

  • G-1522

[C.13-23] documents the results of a survey in 1992 to obtain in£,, a on on the types of distress in the concrete and steel structures and components,

performed, and the durability of the repairs. Licensees who. s,

  • nde
  • ~

reported cracking, scaling, and leaching of concrete stru tu -. The degr attributed to drying shrinkage, freeze-thaw, and abras*.,. he degradation a,

includes corrosion of component support members

, nchor bolts, cracks an ID deterioration of masonry walls, and groundwate

-a age and seepage into underground structures. The degradations at, as, sites were, 1 ore severe than tho observed at inland sites because of exposu t"© rackish wa 2, Calvert Cliffs performed an inspection of the interior of two NUHOMS s, and the exterior of the DSCs as part of their license renewal application

[C.13-4]. The visual inspection was conducted by remote and direct means with a remote controlled high definition PTZ camera system.

Page C.13-33 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The accessible surfaces of the HSM concrete walls, roof, and floor all appeared to be in good condition with little to no signs of spalling or cracking. There was additional evidence of localized water intrusion to the interior of the module in the form of a few concrete stalactites. These stalactites were seen only near the rear outlet v.., which suggests that the source of the water intrusion is the outlet vent stack. B ©.,

stalactite debris was observed on the surface of the heat shields beneath the c

. Stalactites are formed when water leaches calcium hydroxide out of the co precipitates as calcium carbonate on contact with carbon dio *

  • e,

observed to flow inward along concrete surface cracks, tho J~

  • ater penetrated to the rebar, and the pure white color of the s la 'tes was pre concrete surface. Therefore, concrete leaching could. *.
  • ccur in these sur cracks.

osion of the carbon all ar s of general surface

=~1".u""~*~ function of the DSC Page C.13-34 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim TMI-2 at Idaho National Laboratory Experience The Three Mile Island Nuclear Generating Station, Unit 2 ISFSI uses NUHOMS-12T HSMs. In 2000, the licensee Department of Energy Idaho National Labor '. ry (INL),

noted cracks in the HSMs and concluded they were cosmetic and insi,, rru~

t.

However, in 2007, the licensee observed continued cracking, crazin a,, spalling, as well as increased efflorescence on the HSM surfaces. The efflor was a solid, whitish crystalline material that was determined through sam

, lysis to be calcium carbonate. The licensee performed an evaluation i. '

dur*

ich it determined that the HSMs were capable of performing t ei *, sign basis 2008, the licensee noted that 28 of the 30 HSMs had.a;e, mostly emanat the anchor bolt blockout holes with widths up to O e

(0.38 in.). At that tim licensee determined that the HSMs appeared to maturely deteriorating and continued crack growth could affect the abil

  • e HSMs to Ifill their original!

planned 50-year design service life. Subse evaluation *~, e licensee initiated the development of an annual inspection pla

  • 19

, e HS,,,a cl base mat, as well as an examination of the inside of the HSMs. The alm

  • 01,
  • eluded a field investigation and laboratory analysis to evaluate tB e@, rete material quality, strength, and long-term durabi
  • otential. The cone reached was that water had entered the anchor bolt b Ms. Subsequent freeze-thaw cycles initiated th process resulted in both continued crack growth an,

fied in 2007

[C.13-24].

~n to correct the degrading concrete of their acking, the HSMs continued to fulfill fully

  • tted to perform follow-up concrete ual inspection of the repaired areas for any action; (2) that the personnel performing

, 0 Im. the requirements of American Concrete

~

  • R-02, Chap e

, "Qualifications of Evaluation Team;" (3) that f accessible HSM concrete surfaces for aging effects would be ctions contained in ACI 349.3R-02, Section 3.5.1, Visual 1.IR-08, "Guide for Conducting a Visual Inspection of

  • , Servic ** : ed on completion of the HSM concrete repairs, combined

,. plans to implement a baseline inspection and an aging monitoring I, e HSM's, the NRC inspector follow-up item (IFI) has been closed M Aging Management Program for External and Internal Surfaces" is a ning" AMP. This means that this AMP will be updated, as necessary, to incorporate new information on degradation due to aging effects identified from site-specific inspection findings, related industry OE, and related industry research.

Site-specific and industry OE is captured through ISP's OE review process.

Page C.13-35 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The ongoing review of both site-specific and industry OE will continue through the period of extended operation to ensure that the program continues to be effective in managing the identified aging effects. Reviews of OE by the licensee in the future may identify areas where AMPs should be enhanced or new programs develo ISP is to maintain the effectiveness of this AMP under its QA pro gr the criteria of 10 CFR Part 72, Subpart G [C.13-5 and C.13-26].

Page C.13-36 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13-1 C.13-2 C.13-3

  • C.13-4 C.13-5 C.13-6 C.13-7 C.13-8 C.13.6 References NUREG-1927, "Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance," U.S. Nuclear Regulato Commission, Revision 1, June 2016.

NEI 14-03, "Format, Content, and Implementation Guidance for C Operations-Based Aging Management," Revision 1, September,

ASME B&PV Code,Section XI, "Rules for Inservice Insp~ of e

Power Plant Components." The ASME Boiler and Pressure Vess~5'de, 2010, American Society of Mechanical Engineers.

Calvert Cliffs Nuclear Power Plant, Independent Material License No. SNM-2505, Docket No.

Supplemental Information, RE: Calvert Clif Installation License Renewal Application,'

[ML12212A216].

Cracking of Austenitic Stainle

' ee Canister," U.S. Nuclear Regula,

and Safeguards.

Stress Corrosion -

sk Storage System ear Material Safety newal and Expansion," Presentation at the e

St. Petersburg, FL, May 7-9, 2013.

Evaluation of Existing Nuclear Safety-Related Concrete Structures, American ID crete Institute," 2002.

1, Revision 2, "Generic Aging Lessons Learned (GALL) Report-Final ecember 2010.

1. lR, "Guide for Making a Condition Survey of Concrete in Service,"

erican Concrete Institute, 2008.

C.13-14 ANSI/ASCE 11-90, 99, "Guideline for Structural Condition Assessment of Existing Buildings, American Society of Civil Engineers.

Page C.13-37 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13-15 American Concrete Institute, "Building Code Requirements for Reinforced Concrete,"

(ACI 318-83, 95) ACI, Detroit, MI (1983, 1995).

C.13-16 C.13-17 C.13-18 C.13-19 ASTM D610-08, "Standard Practice for Evaluating Degree of Rusting on Painted Steel Surfaces," American Society for Testing and Materials, Novembe *.

ASTM D7167-12, "Standard Guide for Establishing Procedures to,.the Performance of Safety-Related Coating Service Level III Lining Operating Nuclear Power Plant, ASTM International," West 2012.

C.13-20 ACI 224.IR-07, "Cause, Evaluation, and Repair American Concrete Institute, 2007.

C.13-21 ACI 364.lR-07, "Guide for ai a'tlt*.

American Concrete Institute, *0 1 C.13-22 ACI 562-13, "Evaluation, Repa C.13-23 C.13-24 C.13-25 Concrete Institute, 2013.

nditions of Safety-Related Nuclear Plant ture Degradation of Spent Fuel Storage

  • onmental Moisture," U.S. Nuclear aterial Safety and Safeguards.

to er DOE, "Three Mile Island, Unit 2 ISFSI -

the Independent Spent Fuel Storage Installation - Inspection 012-001" August 14, 2012 [ML12228A457].

rt G, Quality Assurance Criteria for the Independent Storage of

-Level Radioactive Waste, and Reactor Related Greater Than the Federal Register.

Code,Section V, "Nondestructive Examination," The ASME Boiler essel Code, 2010 edition.

  • 7, "Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage censes and Certificates of Compliance," U.S. Nuclear Regulatory

'ssion, Revision 0, March 2011.

Page C.13-38 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim C.13-29 Letter E-46190 from Jayant Bondre (AREVA Inc.) to Document Control Desk (NRC),

"Response to Re-Issue of Second Request for Additional Information - AREVA Inc.

Renewal application for Standardized NUHOMS System - CoC 1004 (Docket No.

72-1004, CAC No. L24964)," September 29, 2016, (ADAMS Accession mber MLl 6279A367).

C.13-30 Letter from Meraj Rahimi (NRC) to Jayant Bondre (1N Americas Initial Certificate and Amendments Nos. 1 through lland 13 Amendment No. 14 of Certificate of Compliance No. 1004 NUHOMS Horizontal Modular Storage System," Dece Accession Number MLl 7338A092).

Page C.13-39 This section is newly added.

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table C.13-1 DSC AMP for the Effects of CISCC Tollgates Tollgate Year Assessment

  • 1 prior to T0 Perform initial inspection of selected DSCs as specified in and as updated at the time.that planning for the inspectio 2

3 To+S (note 1)

, and international inspections of welded hnologies to inspect DSCs for stress emistry of surface deposits.

gained from the sources listed in tollgate 2 gate 2 as informed by the results of tollgates 2 and 3 ame as tollgate 3 as informed by the results of tollgates 2, 3, and 4 e first DSC at the ISFSI was loaded.

Page C.13-40 This section is newly added.

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