ML20275A280
| ML20275A280 | |
| Person / Time | |
|---|---|
| Site: | 07200001 |
| Issue date: | 10/15/2020 |
| From: | Kristina Banovac Storage and Transportation Licensing Branch |
| To: | Murray S GE Hitachi Nuclear Energy |
| KLBanovac NMSS/DFM/STL 301.415.7116 | |
| References | |
| 000993/L-2020-LNE-0004, 001028/L-2020-RNW-0024 | |
| Download: ML20275A280 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 15, 2020 Mr. Scott P. Murray Manager, Facility Licensing GE Hitachi Nuclear Energy 3901 Castle Hayne Road P.O. Box 780, M/C K-84 Wilmington, NC 28402
SUBJECT:
REQUEST FOR SUPPLEMENTAL INFORMATION FOR ACCEPTANCE REVIEW OF THE APPLICATION FOR RENEWAL OF THE MORRIS OPERATION LICENSE NO. SNM-2500 (CAC/EPID NOS. 001028/L-2020-RNW-0024 AND 000993/L-2020-LNE-0004)
Dear Mr. Murray:
By letter dated June 30, 2020, GE Hitachi Nuclear Energy Americas LLC (GEH) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for renewal of the Morris Operation License No. SNM-2500 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20182A699). The submittal of the license renewal application was timely per the requirement of Title 10 of the Code of Federal Regulations (10 CFR) 72.42(c) and the exemption dated May 13, 2020 (ADAMS Accession No. ML20134H885). In an email dated July 31, 2020, I informed you of the start of the NRC staffs acceptance review of the application (ADAMS Accession No. ML20213C325).
The purpose of this letter is to provide the results of the NRC staff's acceptance review. The NRC staff has reviewed the application and concluded that it did not provide technical information in sufficient detail to enable the NRC staff to begin a detailed technical review. The NRC staff has determined that we need the information identified in the enclosed request for supplemental information (RSI). The enclosure also includes observations. Observations are questions identified by the NRC staff during the acceptance review, which do not rise to the level of a RSI that needs to be resolved before the renewal application could be accepted for review, but may require the NRC staff to issue a request for additional information (RAI) during the detailed technical review. GEH may respond to the observations in its response to the RSIs to avoid the need for a RAI during the NRC staffs detailed technical review.
Discussion of the RSI and RSI response date occurred on October 8 and October 14, 2020. In order to schedule our technical review, responses to the enclosed RSIs should be provided by February 26, 2021. Inform us at your earliest convenience, but no later than February 12, 2021, if you are not able to provide the information by that date. To assist us in rescheduling your review, you should include a new proposed submittal date and the reasons for the delay.
S. Murray 2
Please reference Docket No. 72-01 and CAC/EPID Nos. 001028/L-2020-RNW-0024 and 000993/L-2020-LNE-0004 in future correspondence related to this request. If you have any questions regarding this matter, please contact me at (301) 415-7116 or Kristina.Banovac@nrc.gov.
Sincerely, Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 72-01 License No. SNM-2500 CAC/EPID Nos. 001028/L-2020-RNW-0024 000993/L-2020-LNE-0004
Enclosure:
RSI and Observations cc:
Morris Operation Service List Kristina L.
Banovac Digitally signed by Kristina L. Banovac Date: 2020.10.15 14:29:43 -04'00'
Morris Operation Service List cc:
Scott P. Murray Manager, Facility Licensing GE Hitachi Nuclear Energy 3901 Castle Hayne Road P.O. Box 780, M/C K-84 Wilmington, NC 28402 Bobbie Lockwood General Manager, Services Operations GE Hitachi Nuclear Energy 3901 Castle Hayne Rd Wilmington, NC 28402 Tony McFadden Site Manager, Morris Operation GE Hitachi Nuclear Energy 7555 East Collins Road Morris, IL 60450 Grundy County Clerk 111 East Washington Street P. O. Box 675 Morris, IL 60450-0675 Adnan Khayyat Division Chief, Division of Nuclear Safety Illinois Emergency Management Agency 1035 Outer Park Dr Springfield, IL 62704 Steven Reynolds Manager, Nuclear Facilities Inspection Illinois Emergency Management Agency 245 W. Roosevelt Rd Bldg. 8, Suite 55 West Chicago, IL 60185 Region III Administrator U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352
ML20275A280 OFFICE NMSS/DFM/STL NMSS/DFM/MSB NMSS/DFM/MSB NMSS/REFS/FAB NAME KBanovac DTarantino RTorres MHenderson DATE 9/3/2020 9/18/2020 9/18/2020 9/15/2020 OFFICE NMSS/DFM/STL NMSS/DFM/MSB NMSS/REFS/FAB NMSS/DFM/STL NAME WWheatley TBoyce FMiller JMcKirgan DATE 9/23/2020 9/25/2020 9/25/2020 10/14/2020
Enclosure Request for Supplemental Information and Observations GEH Morris Operation Docket No. 72-01 License Renewal By letter dated June 30, 2020, GE Hitachi Nuclear Energy Americas LLC (GEH) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for renewal of the Morris Operation License No. SNM-2500 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20182A699). This request for supplemental information (RSI) identifies information needed by the NRC staff to complete its acceptance review of the license renewal application. NUREG-1927, Revision 1, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel (ADAMS Accession No. ML16179A148) and Spent Fuel Storage and Transportation Office Instruction -
14 (SFST - 14), Acceptance Review Process (ADAMS Accession No. ML101130519) were used by the staff in its review of the application.
Each individual RSI describes information needed by the NRC staff to begin a detailed review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements. Observations are also provided. The observations are questions identified by the NRC staff during the acceptance review, which do not rise to the level of an RSI that needs to be resolved before the license renewal application could be accepted for review, but may require the NRC staff to issue a request for additional information (RAI) during the detailed technical review. GEH may respond to the observations in its response to the RSIs to avoid the need for a RAI during the NRC staffs detailed technical review.
RSI-1. Provide supplemental information that describes the current licensing basis for the Morris Operation Independent Spent Fuel Storage Installation (ISFSI) and identifies the changes proposed for license renewal.
The license renewal application (LRA) consists of a cover letter, submittal of a revised consolidated safety analysis report (CSAR) (designated as Revision 15 and dated June 2020),
and a supplement to the environmental report. It is not clear from the information provided in the LRA which documents compose the current licensing basis for the Morris Operation ISFSI.
The cover letter states:
The GEH MO CSAR contains a detailed description of the facility, site characteristics and includes technical information and safety assessments of the principle structures, systems and components of the installation. The CSAR also contains a summary description of the programs and activities relied upon to manage the effects of aging and an evaluation of the time limited aging analysis for the renewal period (CSAR Appendix A.8). The CSAR provides reasonable assurance of protection of the health and safety of the public and operating personnel. A revised CSAR is provided as Attachment 1 to this letter and revised CSAR "A" appendices are provided as Attachment 2 to this letter.
The CSAR, Revision 15 contains change bars throughout. It is not clear if CSAR, Revision 15 is the current operating final safety analysis report (FSAR) for the site, where any changes denoted with change bars have already been made by the licensee under 10 CFR 72.48, or if it is GEHs proposed changes to the FSAR (e.g., updates to aging management information) to support the current LRA. Clarify if the CSAR, Revision 15 is the current operating FSAR for the site and identify those changes that are proposed by GEH to support the LRA.
2 In addition, the cover letter notes, The CSAR "B" Appendices that were submitted during the last license renewal in May 2000 (ML080170476) remain unchanged and are incorporated by reference. However, it appears that Appendix B changed in the January 26, 2011, submittal of the CSAR (ADAMS Accession No. ML110330234). Confirm whether the January 26, 2011, submittal is the latest version of Appendix B of the CSAR.
The staff needs this information to proceed with its review to determine if the Morris Operation ISFSI license renewal application meets the regulatory requirements of 10 CFR 72.42(a) and (b).
RSI-2. Provide the age of the structures, systems, and components (SSCs) within the scope of renewal listed in Appendix A.8, pages 1-2 and Table 1.
Since some in-scope SSCs have been in service since 1972, the staff needs to understand the age of the in-scope SSCs to begin its review of the applicants aging management review.
The staff needs this information to proceed with its review to determine if the Morris Operation ISFSI license renewal application meets the regulatory requirements of 10 CFR 72.42(a) and (b).
RSI-3. Update the aging management programs (AMPs) to include specific activities that are credited for managing aging mechanisms and effects of the SSCs and a summary of operating experience.
The staffs guidance for the 10 program elements of an AMP may be found in NUREG-1927. In particular, NUREG-1927, Section 3.6.1, discusses that the detection of aging effects element should provide specific inspection and monitoring details, including method or technique, frequency, sample size, data collection, and timing of inspections to ensure timely detection of aging effects. The staff notes that the applicant referenced several site-specific Standard Operation Procedures (SOPs) in the AMPs, but the details of the aging management activities and relevance of these SOPs are not provided. Alternatively, provide a copy of the SOPs that are referenced in CSAR Appendix A.8.
In addition, as part of Element 10, Operating Experience, of the AMP, provide a summary of operating experience (e.g., any occurrence of degradation or conditions that are adverse to the safety function of the basin structure and fuel storage components at the ISFSI) involving previously-identified aging effects. The summary should include conditions that were entered in the corrective action program even if they are not discussed in the CSAR. Also, provide any reports or summaries of results from prior implementation of the SOPs to support their referencing in the AMPs.
The staff needs this information to proceed with its review to determine if the Morris Operation ISFSI license renewal application meets the regulatory requirements of 10 CFR 72.42(a) and (b).
RSI-4. Provide the following inspection and evaluation reports referenced in the CSAR:
- 1. GENE 689-013-0893, Morris Fuel Recovery Center Fuel Storage Basin Liner Visual Examination Summary Report, referenced in CSAR Appendix A.8, Fuel Basin Liner Time
3 Limited Aging Analyses (TLAAs). The staff notes that based on the inspection results, the applicant concluded that:
The results of this inspection showed, that based on high-resolution visual inspection and surface examination, the basin liner is judged to have continued integrity, with no environmental degradation associated with 20+ years of fuel storage. Also, considering the continuous maintenance of high purity water flow in the fuel storage basins continued long-term service is indicated.
- 2. GENE 689-003-0494, Morris Fuel Recovery Center Fuel Storage Basin Liner Metallurgical Evaluation, referenced in CSAR Appendix A.8, Fuel Basin Liner TLAAs.
The staff notes that based on the evaluation results, the applicant concluded that:
The nominal liner wall thickness in the unloading pit is 0.125 inches. Assuming the degradation occurred over 20 years and the corrosion rate remained constant, the liner would not be penetrated for the foreseeable future.
- 3. NEDO-20969B, Operating Experience - Irradiated Fuel Storage - Morris Operation, Morris, Illinois, General Electric Company, K. J. Eger, referenced in CSAR Section 5.3.2.2. In reference to this report, the CSAR states:
Irradiated fuel from light water reactors has been received and stored at GEH-MO since 1972. These activities have reaffirmed irradiated fuel can be handled and stored safely with no impact on the environment. There has been no detectable deterioration of fuel in storage (as determined by measurement of basin water activity) indicating the fuel is stable while in the storage basin environment.
These referenced reports may provide relevant operating experience or additional assessment to support conclusions made in the CSAR regarding degradation of fuel, cladding, the basin, and other SSCs within the scope of renewal. In addition, please submit any other relevant operating experience (e.g., results of AMP inspections or monitoring since the previous renewal) or additional assessment or evaluation via the corrective action program, to support the conclusions made in the LRA.
The staff needs this information to proceed with its review to determine if the Morris Operation ISFSI license renewal application meets the regulatory requirements of 10 CFR 72.42(a) and (b).
RSI-5. Provide information on financial data, per 10 CFR 72.22(e), which shows that GEH can carry out the proposed activities for the requested period of extended operation. Also, clarify if the March 6, 2020, decommissioning funding plan (DFP) (ADAMS Accession No. ML20066K265) serves as the submittal of the DFP associated with the license renewal, as required in 10 CFR 72.30(c).
The NRC staff will review the financial qualifications of GEH to carry out the proposed activities for the requested period of extended operation, including the operating cost estimate and operating funds availability, consistent with the guidance in NUREG-1927, Revision 1, Section 1.4.2. Therefore, identify costs related to any proposed aging management activities and ISFSI operating and decommissioning costs that have been revised from those specified in the original specific-license application for construction, operation, and decommissioning.
4 The LRA references the DFP that was submitted on March 6, 2020. Clarify if the March 6, 2020, DFP also serves as the DFP for the license renewal submittal per 10 CFR 72.30(c) or if there have been any changes to the March 6, 2020, DFP to be considered in the review of the LRA.
The staff needs this information to proceed with its review to determine if the Morris Operation ISFSI license renewal application meets the regulatory requirements of 10 CFR 72.22(e) and 72.30(c).
Observations Observation 1. Clarify whether continuous radionuclide release from fuel has changed the properties or condition of the spent fuel or cladding and demonstrate that the analyzed configuration of the spent fuel is maintained in the requested period of extended operation.
CSAR Section 5.3.2.2 and Section 5.4.4.1 state the following:
There has been no detectable deterioration of fuel in storage (as determined by measurement of basin water activity) indicating the fuel is stable while in the storage basin environment.
There are no indications of clad deterioration from the basin environment.... Questions have been raised regarding long-term storage (20 to 100 years) because of possibilities of corrosive effects from inside the cladding and from effects at the external crud-cladding junction. However, tests at Windscale on 9-year storage fuel do not show such attacks.
The staff notes that these are the same statements as the CSAR issued in 2004 at the time of first renewal, and the fuel has been in storage much longer than 9 years. The staff further notes that basin water activity described in CSAR Section 5.5.2.2 indicates release of some radionuclides from fuel and the release has been continuous from the beginning of fuel storage.
The current status of the fuel and cladding does not appear to be characterized by any testing or inspection, and the implications of continuous radionuclide release on spent fuel properties and cladding performance do not appear to be addressed.
This information is needed to evaluate compliance with 10 CFR 72.42(a) and (b).
Observation 2. Justify that the inaccessible areas and welds of the stainless steel liner and other steel components exposed to the basin water environment are not subject to crevice corrosion, galvanic corrosion, microbiologically influenced corrosion, and stress corrosion cracking. Ensure aging management activities related to inaccessible areas and welds of these subcomponents are reflected in the AMP, or these aging mechanisms are dispositioned via TLAAs or supplemental safety analyses.
CSAR Section 5.5.1.3 and CSAR Appendix A.8, Structures Monitoring AMP state the following:
Basin liner corrosion, to the extent that it occurs, is expected to be a general attack with essentially no effects from galvanic corrosion. System pH is controlled, and metal ions present in the system are minimized by use of demineralized water. Water purity is
5 maintained by circulating basin water through a filtration and ion-exchange cleanup system.
there is no visible evidence that the concrete or stainless steel structures that are accessible for inspection are degrading/degraded to any extent that would indicate their functionality has in any way changed over the review period.
The staff notes that the statement on basin liner corrosion is the same as the CSAR issued in 2004 at the time of first renewal. Galvanic corrosion and crevice corrosion can occur in inaccessible contact areas. Cracks from stress corrosion cracking of welds may not be detected by inspection for general attack. Visible evidence may not indicate the occurrence of some degradation mechanisms such as stress corrosion cracking and degradation at inaccessible areas such as crevice corrosion. The current status of the inaccessible areas and welds of the stainless steel liner of the fuel storage basin, stainless steel baskets and supporting grids, and other steel SSCs within the scope of renewal are not described and the implications for aging management are not addressed.
This information is needed to evaluate compliance with 10 CFR 72.42(a) and (b).