ML22132A072
| ML22132A072 | |
| Person / Time | |
|---|---|
| Site: | 07200001 |
| Issue date: | 05/12/2022 |
| From: | Murray S GE Hitachi Nuclear Energy |
| To: | Kristina Banovac Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22132A071 | List: |
| References | |
| M220074 | |
| Download: ML22132A072 (31) | |
Text
.) HITACHI Proprietary Information Notice to this letter contains GEH proprietary information to be withheld from public disclosure in accordance with 10 CFR2.390.
Upon removal of Attachment 4, the balance of this letter may be made public.
M220074 May 12, 2022 Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Attn: Document Control Desk GE Hitachi Nuclear Energy Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 scott.murray@ge.com
Subject:
GEH Morris Operation (MO) Response to NRC Request for Additional Information for the Technical Review of the Application for Renewal of the Morris Operation License No. SNM-2500
References:
(1) NRC License SNM-2500, Docket 72-01 (2) Letter K. Banovac (NRC) to S.P. Murray (GEH), Request for Additional Information (RAI) for the Technical Review of the Application for Renewal of NRC License No.
SNM-2500 dated 8/30/2021 - CAC/EPID NOS. 001028/L-2020-RNW-0024 (3) GEH Morris Operation (MO) Response to Request for Additional Information for the Technical Review of the Application for Renewal of the Morris Operation License NO. SNM-2500 dated 1/27/2022 (M220015; ADAMS Accession No. ML22027A515)
(4) NRC 699, 4/6/2022 Record of call with GEH to clarify RAI responses on Morris renewal (ADAMS Accession No. ML22115A202)
(5) E-Mail Request from K. Banovac (NRC) to S.P. Murray (GEH) and A.E. McFadden (GEH) for clarification on GEH responses to RAls on Morris license renewal application dated 4/19/2022 (ADAMS Accession No. ML22116A099)
GE Hitachi Nuclear Energy Americas LLC (GEH) hereby provides responses to the NRC request for clarification (Reference 5) on the previous response provided to the NRC.
(Reference 3).
Attached to this letter are GEH clarification responses to the NRC.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed on May 12, 2022.
Please contact me at (91 O) 819-5950 if there are any additional questions.
M220074 US NRC 5/12/22 Page 2 of 4 Sincerely, te!an@~
Facility Licensing
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Attachments:
- 2) GEH Clarification Responses to RAls 1, 2, 4, & 5
- 3) GEH CSAR Rev 15A (Draft), App A.8 Aging Management Program
Cc: US NRC Region Ill Administrator SPM 22-020
M220074 US NRC 5/12/22 Page 3 of 4 GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Scott P. Murray, state as follows:
(1)
I am the Manager, Facility Licensing of GE-Hitachi Nuclear Energy (GEH), and have been delegated the function ofreviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2)
The information sought to be withheld is provided in Attachment 4 to GEH's letter, M220074, Scott P. Murray to Kristina Banovac, entitled "GEH Morris Operation (MO) Response for Request for Additional Information for the Technical Review of the Application for Renewal of the Morris Operation License No. SNM-2500",
May 12, 2022. GEH proprietary information contained in Attachment 4 is identified by the statement "GEH Proprietary Information Withhold from Public Disclosure Pursuant to 10 CFR 2.390."
(3)
In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4)
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over GEH and/or other companies.
- b.
Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
- c.
Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, that may include potential products of GEH.
- d.
Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(5)
To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best ofmy knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).
( 6)
Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to
M220074 US NRC 5/12/22 Page 4 of4 industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.
(7)
The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.
(8)
The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH's processes, methods, design, or manufacturing facilities.
(9)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 12th day of May 2022.
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STATE OF NORTH CAROLINA )
COUNTY OF NEW HANOVER )
Subscribed and sworn to me, a Notary Public, in and for the State of North Carolina, this 12th day of May 2022.
MORGAN DATEMA Notary Public, North Carolina New Hanover County My Commission Exp ires April 30, 2027 otary ublic in and for the State of North Carolina My Commission Expires: April 30, 2027
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BAl:1-Clarify the CSAR supplement discussion of the aging management activities for the fuel basin crane, fuel handling crane, and cask crane. Specifically, clarify the use of ANSI 830.2 and requirements in 1 O [29] CFR 1910.179 and 29 CFR 1919 in the aging management descriptions in the CSAR supplement (in Table 1, Items # XI.M23; and page 7 under "ancillary equipment important to safety in the CSAR supplement).
GEH Response:
The CSAR (Rev 15A), Section A.8, Aging Management is being revised to clarify/better align page 7 discussion of Ancillary Equipment Important To Safety to Aging Management Program Review Table 1 (See Attachment 3). Upon final approval of RAl's, RAI clarification, and any potential follow-ups, CSAR (Rev 15A) changes will be formalized.
BAl:2-Clarify whether the Structures Monitoring AMP was intended to be included in the Zircaloy cladding entry in CSAR Table 1 on page 17. The staff notes that the proposed revised SOP 16-17 includes inspection of the visible portions of the spent fuel pool cladding from the basin crane and/or basin walkways. Please clarify the CSAR supplement and SOP on the aging management activities for the cladding, including the scope (e.g., extent of cladding surface examined) for any inspections that may be credited for aging management of the cladding, if applicable.
GEH Response:
Yes, Structures Monitoring was intended to be included in the Zircaloy cladding entry in CSAR Table 1 on page 17. The CSAR (Rev 15A), Section A.8, Aging Management is being revised to include the expectations of Zircaloy cladding inspections, as reflected in SOP 16-17. These inspections are completed annually during the Fuel Storage System Inspection and include a visual inspection of 100% of the readily accessible surfaces of the fuel cladding, both stainless steel and zircaloy, from the basin crane and/or the basin walkways. (See Attachment 3). In addition, SOP 16-17 is being revised to clarify spent fuel cladding inspections. Upon final approval of RAl's, RAI clarification, and any potential follow-ups, CSAR (Rev 15A), and SOP 16-17 Fuel Storage System Inspection (Rev 5) changes will be formalized.
BAJ.:!. Clarify the discussion between the CSAR supplement and SOP regarding inspection coverage of readily accessible surfaces. The CSAR includes "typically include 100% of readily accessible surfaces [emphasis added]," while the SOP includes "100% of the readily accessible of the concrete walls, floors, and expansion gate from the basin crane and/or the basin walkways
[ emphasis added]" and visual inspection of the visible sections of the stainless-steel liner in the fuel basins from the basin crane and/or the basin walkways [emphasis added]."
GEH Response:
The CSAR (Rev 15A), Section A.8, Aging Management is being revised to remove the word "typically" and to be better aligned to SOP 16-17 (See Attachment 3). Upon final approval of RAl's, RAI clarification, and any potential follow-ups, CSAR (Rev 1 SA) changes will be formalized.
~- Clarify the CSAR supplement discussion on stainless steel baskets and grids.
Specifically, clarify whether Item# 111.AS.T-14 in CSAR Table 1 includes the stainless steel baskets and grids. Page 4 of the CSAR notes, "A visual inspection of normally inaccessible components in the basin, baskets, grid, basin liner, if/when they are moved will identify degradation of the material resulting from corrosion."
GEH Response:
The CSAR (Rev 15A), Section A.8, Aging Management is being revised to include the baskets and grid in Item# 111.AS.T-14 in CSAR Table 1. Upon final approval of RAl's, RAI clarification, and any potential follow-ups, CSAR (Rev 15A) changes will be formalized.
GEH Morris CSAR, Rev 15A (Draft), A.8 Aging Management Program
HITACHI Morris Operation Consolidated Safety Analysis Report A.8 AGING MANAGEMENT This appendix provides a summarized description of the activities for managing the effects of aging at GEH-MO. The evaluations of time-limited aging analyses (TLAAs) for the renewal period are also presented.
An assessment of the GEH-MO inspection activities identified new and existing activities necessary to provide reasonable assurance that Systems, Structures, and Components (SSC) within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the renewal period. This section describes these aging management activities.
This section also discusses the evaluation results for each of the applicable SSCs specific time-limited aging analyses (TLAAs) performed for license renewal. The evaluations have demonstrated that the analyses remain valid for the renewal period; the analyses have been projected to the end of the renewal period; or that the effects of aging on the intended function(s) will be adequately managed for the renewal period.
GEH-MO is an away from reactor ISFSI storing spent fuel under 1 0CFR72 license until such time that the fuel may be shipped off-site for final disposition. The fuel storage basins at GE-MO are designed for below grade storage. Accordingly, the exterior materials can withstand the anticipated effects of "weathering" under normal conditions.
Structures, systems and components at GEH-MO that, while not performing a safety-related function, but do perform a function that demonstrates compliance with NRC regulations on environmental qualification, are identified in the CSAR, section 11, paragraph 11.3, as follows:
11.3 STRUCTURES, SYSTEMS, AND COMPONENTS IMPORTANT TO SAFETY No credible event, planned discharge, or design basis accident at GEH-MO is identified that would expose a member of the public to radiation in excess of limits specified in 10 CFR 72.104 or 10 CFR 72.106.
It is, therefore, the position of GEH-MO that the term "basic components" in the sense defined by 10 CFR 21.3(a)(2) and 10 CFR 21.3 (m) is not applicable to GEH-MO.
However, "structures systems and components important to safety" as promulgated in 10 CFR 72.122, "Overall Requirements" are identified below.
- a. Fuel storage basin (FSB) - concrete walls, floors, and expansion gate are principal elements in protection of stored fuel, and in isolation of basin water from the environment.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 1
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Morris Operation WJ HITA HI Consolidated Safety Analysis Report
- b. Fuel storage basin - stainless steel liner forms a second element in fuel protection and basin water isolation, facilitating decontamination.
- c. Fuel storage system, including baskets and supporting grids is a principal element in protection of stored fuel.
- d. Steel expansion gate - Identified as Gate #4, along the south east corner of fuel basin II. The gate is constructed of reinforced concrete with a thickness of 8" and height and width dimensions of 29'-6" and 5'-0", respectively. The water side of the gate is lined with 16-gauge stainless steel to prevent the reinforced concrete from coming into contact with the water in the basin.
- e. Unloading pit doorway guard - is designed to prevent a loaded fuel basket from being tipped so that fuel bundles could fall into the cask-unloading pit. The unloading pit doorway guard is an element in protection of fuel during movement of a loaded basket.
- f.
Filter cell structure (FCS) - the concrete cell part of the basin pump room area provides radiation shielding to reduce occupational exposure.
- g. Fuel Storage Basin building - the steel structure that surrounds/protects the fuel Basins.
- h. Fuel Basket Grapple - Used to remove the fuel baskets from their storage location in the fuel basin support grid.
- i.
Fuel Grapple - Used to remove the fuel bundles from the fuel baskets when they are in the unloading pit.
- j.
Fuel Basin Crane - Crane utilized to move the full fuel baskets to the unloading pit.
- k. Fuel Handling Crane - Crane used to remove the fuel bundles from the fuel storage baskets and place into a cask.
I.
Cask Crane - 125 Ton overhead crane used to lift a fully loaded cask from the unloading pit and place cask onto transport vehicle.
- m. Spent Fuel Cladding - Fuel in GE-MO basins are clad with SS or zircaloy cladding.
However, since these systems do contain the stored fuel or provide support functions, they have been reviewed for aging management. These SSCs are organized in accordance with NU REG 1801 in Table 1 of this appendix.
STRUCTURES MONITORING AGING MANAGEMENT PROGRAM (AMP)
As identified in Table 1, SSCs involving concrete or structural steel, and necessitating periodic examination, are inspected and monitored according to this Structures Monitoring AMP. AMP elements are consistent with those in XI.S6 from NUREG 1801 Rev. 2 and are as follows:
Scope of Program - Inspection and monitoring of SSCs important to safety ensures there is no loss of function. This is facilitated with periodic examinations and select monitoring in accordance with this AMP. The SSCs identified during the AMR that are covered by this AMP are denoted as "Structures Monitoring" in Table 1.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 2
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Morris Operation 9' HIT.A HI Consolidated Safety Analysis Report Preventative Actions - Preventative actions delineated in NUREG-1339 are not applicable to the fuel basin building structure, as bolting used for construction does not form a pressure boundary, is not a reactor internal component, and does not involve high strength >150ksi bolts.
Bolted connections used to construct the basin building structure are, however, inspected every 5 years by qualified personnel in accordance with SOP 16-17. Preventative actions for inaccessible portions of concrete and liner structures include maintenance of water chemistry within approved license specifications through continuous filtration and addition of ultra-pure water (typically 0.056 µmho/cm) as needed to maintain basin level (see Water Chemistry AMP).
Parameters Monitored or Inspected - For each structure / aging effect combination designated as "Structures Monitoring" in Table 1, the following parameters are inspected:
Concrete Structures: loss of material, cracking, increase in porosity and permeability, loss of foundation strength, and reduction in concrete anchor capacity due to local concrete degradation.
Steel Structures including Galvanized Steel: loss of material due to corrosion of any kind.
Stainless Steel Basin Liner: evidence of bulging or depressions and leakage rate via leak detection channels.
Structural Bolting: loose bolts, missing or loose nuts, and other conditions indicative of loss of preload. Loss of material due to general, pitting, and crevice corrosion.
Ground Water Quality: Ground water chemistry (pH, chlorides, and sulfates) are monitored periodically to assess its impact, if any, on below grade concrete structures.
Detection of Aging Effects - Aging is detected by periodic visual inspections for each structure I aging effect denoted in Table 1. Parameters are examined every 5 years by qualified inspectors in accordance SOP 16-17. This SOP incorporates relevant sections of ACI 349.3R and suggested parameters from the NUREG 1801, XI.S6 AMP. Additionally, ground water quality is periodically sampled to ensure a non-aggressive environment for inaccessible concrete structures.
The purpose of the GEH-MO Inspection Activities is to:
- 1. Determine that no significant deterioration of the basin structure has occurred, such that it can still perform its intended function, and
- 2. Confirm that no significant degradation of the fuel storage components in the basin has occurred.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 3
A Hrt CHI Morris Operation
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Consolidated Safety Analysis Report The scope of the Basin Inspection / Monitoring Activities involves; a)
Triennial monitoring of ground water for chemical species that can deteriorate the basin and filter structure inaccessible concrete.
b)
Annual visual inspections of exposed concrete, stainless-steel liner, and building structures housing spent fuel. These inspections will include 100% of readily accessible surfaces.
c) 5-year visual inspections by qualified inspectors of exposed concrete, stainless-steel liner, and building structures. These inspections will include 100% of readily accessible surfaces.
d)
Annual visual inspection of 100% of the readily accessible surfaces of the fuel cladding, both stainless steel and zircaloy, from the basin crane and/or the basin walkways.
e)
Visual inspection of normally inaccessible components of the fuel storage system (e.g.,
baskets and grid) in the event a basket is lifted in preparation for movement.
f)
Continuous monitoring of the leak detection sump level.
Visual inspections identify physical degradation of the exposed surfaces of the concrete structures, and stainless-steel liner. These inspections will include 100% of readily accessible surfaces. Qualified inspectors examine the fuel storage basin concrete, building structure and liner at 5-year intervals relative to the requirements of ACI 349.3R. These examinations are supplemented with annual inspections by operations staff for deterioration of the concrete due to loss of material, cracking or spalling, and steel building structures due to corrosion and paint degeneration. A visual inspection of normally inaccessible components in the basin, baskets, grid, basin liner, if/when they are moved will identify degradation of the material resulting from corrosion. Inspections provide reasonable assurance that any degradation of the fuel storage system is identified.
Monitoring and Trending - All SSCs covered by the Structures Monitoring AMP are non-safety related as defined in 1 0CFRS0.65. These structures have been ranked based on risk significance and are monitored based on condition. Results from condition monitoring activities are analyzed against predetermined goals annually in accordance with SOP 16-17.
Deficiencies are corrected commensurate with the associated safety significance and may necessitate adjustments to monitoring frequency and/or implementation of trending for structures with high-risk significance.
The basin leak detection system continuously monitors the sump level via the Site Instrumentation Monitoring System (SIMS) and constantly displays the level on a monitoring screen. Alarms are triggered if the level exceeds pre-set values.
The eight NRC reviewed and approved ground water sampling wells at MO are used to monitor for any potential leakage of basin water to the surrounding soil. The wells are sampled routinely per SOP 16-102, Sample Well Analysis Compliance Test. In addition, at least 1 of 3 of the wells GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 4
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Morris Operation WJ H ITA HI Consolidated Safety Analysis Report positioned around the basin are used to monitor ground water for potential effects on below grade concrete.
Acceptance Criteria - Table 2 summarizes acceptance criteria based on the type of inspection and the associated structure.
Corrective Actions - Visual inspection acceptance criteria are based on the absence of indications that are signs of degradation. Engineering evaluations determine whether observed deterioration of material condition is significant enough to compromise the ability of the SSC to perform its intended function. Occurrence of degradation that is adverse to quality will be entered into the Corrective Action System. Alarm panel response procedures identify the various criteria for the different fuel storage system monitoring devices at GEH-MO and specify any required corrective actions and responses.
Confirmation Process - The process of confirmation is controlled by the Morris quality program and is consistent with the requirements of 1 0CFR72, Subpart G.
Administrative Controls - Administrative controls are governed by the Morris quality program.
This program implements controls that are consistent with the requirements of 1 0CFR72, Subpart G.
Operating/ Industry Experience - A review of the results of SOP 16-17, Fuel Storage System Inspection, indicates that although there is some degradation visible in some of the painted structures, 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 inspections have been conducted by veteran operators, one of which has been employed at MO for over 40 years. Minor paint issues are addressed as they are observed and due to the humid conditions in the area of the fuel pools, these minor issues are to be expected.
Regulatory information presented in NUREG-1522 and NUREG/CR-6927 was also reviewed to ensure degradation parameters selected for the identified structures were consistent with the published findings. This review concluded that the aging mechanisms described in NUREG-1801 for fuel storage facilities do indeed cover the concrete and steel deteriorations noted in NUREG-1522 and NUREG/CR-6927. It should also be noted that the concrete structures at GEH-MO were designed and constructed in accordance with the applicable national standards, specifically ACI 318-63, and meet conditions consistent with longevity as described by the Gall Report.
WATER CHEMISTRY AMP GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 5
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Morris Operation W' HITA HI Consolidated Safety Analysis Report As identified in Table 1, SSCs constructed from stainless steel, and necessitating maintenance of water chemistry, are maintained according to this Water Chemistry AMP. AMP elements are consistent with those in XI.M2 from NUREG 1801 Rev. 2 and are as follows:
Scope -Maintenance of water chemistry in contact with stainless steel SSCs ensures there is no material loss that would affect the functionality of structures important to safety. This is facilitated by water replenishing / filtering systems in combination with periodic monitoring in accordance with this AMP. The stainless steel SSCs identified during the AMR that are managed with this AMP are denoted as "Water Chemistry" in Table 1.
Preventative Actions - This AMP involves SOPs that specify limits for the total amount of radioactivity and conductivity in the fuel basin water, sampling and analysis frequencies, and corrective actions for control of water chemistry. Fuel Basin water chemistry is controlled to minimize contaminant concentration thereby mitigating loss of material due to general, crevice, and pitting corrosion and cracking caused by SCC. Water chemistry is maintained within approved license specifications through continuous filtration and addition of ultra-pure water (typically 0.056 µmho/cm) as needed to maintain basin level.
Parameters Monitored/ Inspected - Gross Beta and Conductivity Detection of Aging Effects - Aging is mitigated by maintenance of basin water for structures in Table 1 involving stainless steel by:
a)
Continued analysis of fuel storage basin water quality in accordance with a Compliance Test insuring conformity to license specifications.
b)
Monthly sample analysis of water from the Basins using an independent lab.
Monitoring and Trending - Basin water radioactivity and conductivity is periodically recorded, evaluated and trended in accordance with SOP 16-10.
Acceptance Criteria - Basin water has the following radioactivity and conductivity limits:
a) Conductivity must be <1.35 µMho/cm.
b) Basin water activity (gross beta) must be less than 0.02 µCi/ml Corrective Actions - Non-compliant samples indicating conditions adverse to quality will be entered into the Corrective Action System. Alarm panel response procedures identify the various criteria for the different fuel storage system monitoring devices at GEH-MO and specify any required corrective actions and responses.
Confirmation Process - The process of confirmation is controlled by the Morris quality program and is consistent with the requirements of 10 CFR 72 Part G.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 6
A Hlu C Morris Operation W'
~ HI Consolidated Safety Analysis Report Administrative Controls - Administrative controls are governed by the Morris quality program.
This program implements controls that are consistent with the requirements of 10 CFR 72 Part G.
Operating Experience -All SSC's in the basin are 304 Stainless Steel. Per IAEA-TECDOC-1012, "Durability of Spent Nuclear Fuels and Facility Components in Wet Storage", SS wet storage facility components have excellent histories of durability in periods approaching 40 years provided that good water chemistry control is maintained. The GE-MO basin water chemistry provides an excellent media for SS materials. Combining the basin liner coupon examination, and the guidance from the IAEA Report, corrosion is minimal and should have little or no impact on the basin liner or other stainless-steel components of the fuel storage (baskets and supporting grid) system for the term of the license renewal. In addition, all of these components have been in a static mode since the last fuel receipt in January 1989, so there also hasn't been any mechanical wear.
As shown in GE-MO 72.48 prepared February 16, 1996, conductivity is a more accurate way to measure ultra-pure water quality than pH and a conductivity value of 2.5 µmho/cm was established, corresponding to a pH of 4.5 to 9.0 in keeping with the reference license specification. The 2004 GE-MO 72.48 lowers that value to 1.35 µmho/cm for the basin water, equivalent to a pH value of 5.5 to 8.0. This change is in keeping with the requirements in NUREG 1801, Chapter Ill establishing a lower limit of 5.5 pH for water as non-aggressive to concrete or stainless steel. This value is also representative of the typical GE-MO basin water quality. Since March 1976 the average basin water conductivity has been 1.07 µmho/cm. There are no sources for NaNo3 and Cl in the basin environment and values for these materials repeatedly are below detectable limit. During a recent test, basin water makeup, cooling and filtration were discontinued for a period of 50 days resulting in an actual conductivity increase to 1.22 µmho/cm. A conductivity value of 1.35 µmho/cm also provides a much lower tolerance for ionic impurities allowing the elimination of NaNo3 and Cl measurements since values well below 5 ppm of either cause conductivity to significantly increase beyond 1.35 µmho/cm.
ANCILLARY EQUIPMENT IMPORT ANT TO SAFETY All cranes considered to be Important to Safety under Section 11.3 are maintained in compliance with the requirements specified in Aging Management Program Review Table 1, Items# XI.M23 and tracked by our Preventive Maintenance (PM) program described in MOI 401. The cranes are inspected, and routine maintenance items performed quarterly by on-site Maintenance personnel per the manufacturers recommended schedule. Annually, an independent inspection company performs a complete inspection, including non-destructive testing, of all cranes and hoists on site.
All grapples and miscellaneous tooling used for moving fuel bundles or fuel baskets are laid away. Each tool will undergo thorough inspection and testing to insure it complies with the original manufacturers specifications prior to utilizing it for lifting any fuel bundle or basket.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 7
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Morris Operation 9' HITA HI Consolidated Safety Analysis Report When in use, these tools are only exposed to treated water described in the Water Chemistry AMP.
FUEL BASIN LINER TLAAs In June 1993, the fuel storage basin was inspected to confirm expectations of continued structural integrity, as well as confirm the absence of microbe-induced corrosion (MIC). To confirm and document the integrity of the liner, a routine inspection plan was developed in accordance with ASME Boiler and Pressure Vessel Code and other industry approved IWI procedures. The inspection plan included use of underwater TV cameras to inspect the basin welds.
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.
The above is detailed in report GENE 689-013-0893, "Morris Fuel Recovery Center Fuel Storage Basin Liner Visual Examination Summary Report", dated September 1993.
Additionally, in 1994 an approximately 1.5" x 3.5" coupon was cut from the basin liner in the cask unloading pit. This area then had a patch welded over it. The sample was sectioned for optical metallography and scanning electron microscopy (SEM). Cross sectional views did not find evidence of significant surface attack, and the maximum surface penetration was 0.4 mils.
SEM examination of the surface found oxide deposits, which is expected for a stainless steel that has been exposed to a water environment for 20+ years. Chemical analysis of the deposits determined the composition to be mostly iron oxide. No detrimental chemical species were found. No evidence of MIC phenomena was observed.
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.
See report number GENE-689-003-0494, "Morris Fuel Recovery Center Fuel Storage Basin Liner Metallurgical Evaluation"; dated May 1994.
FUEL BUNDLE STORAGE In broad, generic terms, the design and operation of the GEH-MO spent fuel pool is similar to a spent fuel storage pool at a nuclear power plant and some aspects of the reference NUREGs may be applicable, however, significant differences between GEH-MO basins and support systems and a nuclear power plants fuel storage basins and the fuel stored in both must also be GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 8
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Morris Operation WJ HITA HI Consolidated Safety Analysis Report taken into account. The GE-MO basins are below ground, in native bedrock, water level is maintained at or below grade level. All stored fuel is held in GEH-MO unique stainless-steel baskets (CSAR Section 5.0,,i 5.4.4.2) that are a "can" style container minus a lid, providing individual support and additional containment and shielding for each fuel bundle. Fuel is not routinely shuffled nor is new fuel added unlike the spent fuel pool in a nuclear power plant, (last fuel moved was January 1989) and there are no plans to do so. The static state of the GEH-MO fuel assures there are no mechanical or dynamic stresses placed on the fuel. The large basin water volume and low decay heat input from the stored fuel provide an extended period of time to take corrective action in case of a malfunction of any of the basin support systems. In the event of an earthquake or other extreme natural phenomena, sufficient makeup water is available through either on-site or off-site means to maintain safe storage conditions.
Fuel stored at GEH-MO has reactor discharge dates that range from April 1970 through October 1986. The last fuel was received at GEH-MO in January 1989. Burnup rates range from a high of 36.71 GWD/MTU to a low of 0.18 GWD/MTU, and an average burnup of 17.74 GWD/MTU.
Due to the robust design of the pool (CSAR Section 5.0,,i 5.5) and the time interval from reactor discharge, there are no postulated events that would result in exposure to a member of the public in excess of the limits of 10CFR72.104, as stated in the CSAR, Section 8.0,,i 8.1.1. The condition of the fuel is monitored as part of routine activities conducted at GEH-MO through basin water analysis and air quality monitoring. The design of the pool, and operational requirements for the basin area assure a depth of water over the stored fuel, which provides for extended passive heat dissipation capability. In May of 2004, a test was performed in to demonstrate the water quality would be minimally affected if there were a total loss of the Basin cooling and filtration systems. Results of the test revealed the conductivity approached 1.24µmho/cm, well below the license specification. Also demonstrated in the test was that heat dissipation from the basin was adequate as the basin water temperature reached a mere 123°F.
Basin water level decreased to the 46' 9" el., 9' 6" above the upper most portion of the fuel bundle, leaving an additional 6" before reaching the license limit of 9' above the upper most part of the fuel bundle.
In general, safe storage of the spent fuel is achieved by maintaining the integrity of the fuel cladding through maintaining a high quality of basin water (CSAR Section 10.0,,i 10.4.5) and substantiated by IAEA-TECDOC-1012, "Durability of Spent Nuclear Fuels and Facility Components in Wet Storage". Fuel cladding is designed to withstand a far more severe environment in a reactor than in static storage at GEH-MO. The low temperature conditions, removal of both particulate and ionized impurities from the basin water, and absence of chemical materials provides high water clarity, limits corrosion and maintains radiation exposure rates in the vicinity of the basin as low as reasonably achievable. The cladding provides an effective primary barrier to the escape of fission or activation products from stored fuel. The basin water is an effective secondary barrier for the confinement of the small amounts of radioactive materials that may be released from the spent fuel.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 9
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Morris Operation
'W' H ITA HI Consolidated Safety Analysis Report The GEH-MO radiation protection program is previously established in the current approved revision of the GEH-MO Consolidated Safety Analysis Report (CSAR) Section 7.0, Radiation Protection. Subsection 7.7, Estimated Man-Rem Off Site Dose Assessment, specifies the current approved environmental monitoring program. Under normal operating conditions, Kr-85 provides essentially all the exposure from the GEH-MO ventilation exhaust stack. The sum of the values for annual whole-body exposure due to inhalation and skin dose out to a radius of 50 miles gives a total of less than 2 x 1 o-6 man-Rem/yr whole body and less than 0.12 man-Rem skin dose. Routine air samples continue to show that exhaust emissions are below detectable limit, as follows:
Vent Supply Stack Inlet Alpha (µCi/ml) 3.0 X 10-13 Beta (µCi/ml) 6.0 x 10-13 MDA (~3x10-15)
MDA (~3x10-15)
The vent supply is air intake to the facility and stack inlet is air being released to the exhaust stack.
There are no planned or unplanned releases of liquid wastes from the site boundaries.
Analysis of postulated accidents including the causes of such events, consequences, and the ability of GEH-MO to cope with each are previously established in the CSAR, Section 8.0, Accident Safety Analysis. The Structures, Systems, and Components (SSCs) Important to Safety are described in Section 11.0, Quality Assurance. Both have been in the CSAR since the original Part 50 license, SNM-1265 was issued for GEH-MO and were included during the 1979 license renewal application and subsequent issue of the current Part 72 license SNM-2500 in 1982. As such, both are considered part of the original licensing basis for Morris Operation.
Given the robust design of the Morris pool and the passive nature of the SSCs Important to Safety, no scenario involving a support system would result in an exposure to the public in excess of the criteria established in 1OCRF72.104.
The current approved safety basis for the Morris facility as defined in the CSAR, designated items important to safety (CSAR Section 11.0, sub-section 11.3) demonstrates that no accident postulated (CSAR Section 8.0) will result in exceeding the limits of 10 CFR 72.104 and 10 CFR 100.20 to demonstrate protection of the public.
As shown in CSAR Sections 7.0 and 8.0, the low value of credible doses which could be received from normal operating and credible accident releases are many orders of magnitude below regulatory limits.
Unlike similar support systems at a nuclear power plant, the combination of the GEH-MO radiation safety program, accident analysis and functional classification of equipment demonstrates that failure of a SSC supporting fuel storage basin operation will not cause an immediately reportable event. Ample time has been demonstrated for repair, temporary GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 10
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Morris Operation V
HITA HI Consolidated Safety Analysis Report substitution, or permanent replacement of any SSC to prevent any Technical Specification violation and without exceeding any regulatory limits for radiation exposure is postulated.
Summary Based on the reference information supplied in IAEA-TECDOC-1012, "Durability of Spent Nuclear Fuels and Facility Components in Wet Storage", and NUREG 1801, "Generic Aging Lessons Learned (GALL) Report", the effects of aging are minimal and will be adequately managed for the duration of the license period through the GE-MO Aging Management Program.
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 11
A Morris Operation V
HITACHI Consolidated Safety Analysis Report Ill Aging Management Program Review Table 1 STRUCTURES AND COMPONENT SUPPORTS A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)
Item Link Structure and/or Material Environment Component III.A5.TP-25 III.A5-2 FSB/FCS Concrete Any (T-03)
Concrete environment (accessible areas): all III.A5.TP-27 I I I.A5-4(T-FSB/FCS Concrete Ground
- 05)
Concrete water/soil (accessible areas): below-grade exterior; foundation III.A5.TP-23 I I I.A5-6(T-FSB/FCS Concrete Air - outdoor
- 01)
Concrete (accessible areas): exterior above-and below-grade; foundation III.A5.TP-24 III.A5-7(T-FSB/FCS Concrete Water - flowing
- 02)
Concrete (accessible areas): exterior above-and below-grade; foundation Aging Effect I Mechanism Cracking due to expansion from reaction with aaareQates Cracking; loss of bond; and loss of material (spalling, scaling) due to corrosion of embedded steel Loss of material (spalling, scaling) and cracking due to freeze-thaw Increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT Page 12 REVISION 15A Aging Management Further Program (AMP)
Evaluation "Structures Monitoring" No "Structures Monitoring" No "Structures Monitoring" No "Structures Monitoring" No
Morris Operation HITACHI Consolidated Safety Analysis Report Item Link Structure and/or Material Component 111.AS.TP-26 I I I.A5-9(T-FSB/FCS Concrete
- 04)
Concrete (accessible areas): interior and above-grade exterior GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Environment Aging Effect/
Mechanism Air - indoor, Cracking; loss of uncontrolled or bond; and loss of Air - outdoor material (spalling, scaling) due to corrosion of embedded steel PAGE DATE DRAFT Page 13 REVISION 15A Aging Management Further Program (AMP)
Evaluation "Structures Monitoring" No
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component 111.AS.TP-Ill.AS-FSB/FCS Concrete 204 2(T-03)
Concrete (inaccessible areas): all 111.AS.TP-Ill.AS-FSB/FCS Concrete 212 4(T-0S)
Concrete (inaccessible areas): below-grade exterior; foundation 111.AS.TP-Ill.AS-FSB/FCS Concrete 29 S(T-07)
Concrete (inaccessible areas): below-grade exterior; foundation III.AS.TP-Ill.AS-FSB/FCS Concrete 67 7(T-02)
Concrete (inaccessible areas):
exterior above-and below-grade; foundation GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Environment Mechanism Any Cracking environment due to expansion from reaction with aggregates Ground Cracking; loss of water/soil bond; and loss of material (spalling, scaling) due to corrosion of embedded steel Ground Increase in porosity water/soil and permeability; cracking; loss of material (spalling, scaling)
Water-Increase in porosity flowing and permeability; loss of strength due to leaching of calcium hydroxide and carbonation P.AGE DATE DRAFT REVISION 15A Aging Management Program (AMP)
The concrete structures at GEH-MO were designed and constructed in accordance with ACI 318-63 and meet conditions for longevity as described by the Gall Report.
Aggregates per ACI 318-63 conform with ASTM C33 "Specifications for Concrete Aggregates" as referenced by ASTM C29S.
"Structures Monitoring" "Structures Monitoring" N/A - There are no exterior GEH-MO concrete structures in contact with untreated flowing water.
Page 14 Further Evaluation No No No N/A
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component 111.AS.TP-Ill.AS-FSB/FCS Concrete 108 6(T-01)
Concrete (inaccessible areas):
foundation III.AS.TP-Ill.AS-FSB/FCS Concrete 114 1(T-10)
Concrete: all III.AS.TP-Ill.AS-FSB/FCS Concrete 30 3(T-08)
Concrete: all III.AS.TP-Ill.AS-FSB/FCS Concrete; 31 8(T-09)
Concrete:
porous foundation; concrete sub-foundation 111.AS.TP-Ill.AS-FSB/FCS Concrete 28 1 0(T-06)
Concrete:
interior; above-grade exterior GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Environment Mechanism Air - outdoor Loss of material (spalling, scaling) and cracking due to freeze-thaw Air - indoor, Reduction of strength uncontrolled and modulus due to elevated temperature (>1 S0°F general; >200°F local)
Soil Cracking and distortion due to increased stress levels from settlement Water-Reduction of foundation flowing under strength and cracking foundation due to differential settlement and erosion of porous concrete sub-foundation Air - indoor, Increase in porosity uncontrolled or and permeability; Air - outdoor cracking; loss of material (spalling, scaling) due to aggressive chemical attack PAGE DATE DRAFT Page 15 REVISION 15A Aging Management Further Program (AMP)
Evaluation N/A. There are no GEH-MO N/A inaccessible areas are subject to outdoor air.
N/A. There are no GEH-MO N/A concrete structures subject to temperatures above 1 S0°F "Structures Monitoring" No GEH-MO does not have a de-watering system.
"Structures Monitoring" No GEH-MO does not have a de-watering system.
"Structures Monitoring" No
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component 111.AS.TP-High-strength Low-alloy 300 structural
- steel, bolting actual measured yield strength~
150 ksi 111.AS.T-12 Ill.AS-Masonry Concrete 11 (T-12) walls: all block 111.AS.TP-Masonry Concrete 34 walls: all block 111.AS.TP-Ill.AS-FSB Building Steel 302 12(T-11)
Steel components:
all structural steel GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Aging Management Program Environment Mechanism (AMP)
Air - indoor, Cracking N/A. There are no GEH-MO uncontrolled or due to stress structures secured with High-Air - outdoor corrosion cracking strength (~ 150 ksi) bolts.
Air - indoor, Cracking NIA. There are no masonry uncontrolled or due to restraint structures at GEH-MO.
Air - outdoor shrinkage, creep, and aggressive environment Air - outdoor Loss of material N/A. There are no masonry (spalling, scaling) and structures at GEH-MO.
cracking due to freeze-thaw Air - indoor, Loss of material "Structures Monitoring" uncontrolled or due to corrosion Air - outdoor PAGE DATE DRAFT Page 16 REVISION 15A Further Evaluation N/A N/A N/A No
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component III.A5.T-14 Ill.AS-FSB S-Steel Stainless 13(T-14) components:
steel fuel pool liner,
- Grapples, Doorway
- Guard, Expansion Gate, Fuel
- Cladding, Baskets, Grid N/A N/A FSB Zircaloy Zircaloy components:
Fuel Cladding GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Environment Mechanism Treated water Cracking or Treated due to stress borated water corrosion cracking; Loss of material due to pitting and crevice corrosion Treated water Cracking or Treated due to stress borated water corrosion cracking; Loss of material due to pitting and crevice corrosion PAGE DATE DRAFT REVISION 15A Aging Management Program (AMP)
"Water Chemistry" and "Structures Monitoring" Additionally, spent fuel pool water level is maintained in accordance with SOP 1-10 technical specifications and leakage from the leak chase channels is monitored in accordance with SOP 1-27. TLAAs involving IWI inspections and liner coupon extractions provide additional support that water chemistry control is effective at managing aging effects.
"Water Chemistry" and "Structures Monitoring" Additionally, spent fuel pool water level is maintained in accordance with SOP 1-10 technical specifications and leakage from the leak chase channels is monitored in accordance with SOP 1-27. TLAAs involving IWI inspections and liner coupon extractions provide additional support that water chemistry control is effective at managing aging effects.
Page 17 Further Evaluation No, unless leakages have been detected through the SFP liner that cannot be accounted for from the leak chase channels No, unless leakages have been detected through the SFP liner that cannot be accounted for from the leak chase channels
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component 111.AS.TP-FSB Building Any 261 Structural bolting 111.AS.TP-FSB Building Steel 248 Structural bolting 111.AS.TP-FSB Building Steel; 274 Structural galvanized bolting steel GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Aging Management Program Environment Mechanism (AMP)
Any Loss of preload "Structures Monitoring" environment due to self-loosening Air - indoor, Loss of material "Structures Monitoring" uncontrolled due to general, pitting and crevice corrosion Air - outdoor Loss of material "Structures Monitoring" due to general, pitting, and crevice corrosion PAGE DATE DRAFT Page 18 REVISION 15A Further Evaluation No No No
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component XI.M23 Fuel Basin Structural
- Crane, steel including bridge and trolley XI.M23 Fuel Handling Structural
- Crane, steel including bridge and trolley GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Environment Mechanism Air - indoor, Cumulative fatigue uncontrolled damage I fatigue.
Loss of material /
General corrosion &
wear.
Air - indoor, Cumulative fatigue uncontrolled damage I fatigue.
Loss of material I General corrosion &
wear.
PAGE DATE DRAFT Page 19 REVISION 15A Aging Management Program Further (AMP)
Evaluation Maintained under the GEH-No MO preventive maintenance program and inspected in accordance with the requirements specified in 10 CFR 1910.179 and ANSI 830-
- 2. Yearly inspections are performed by an independent contractor whose crane inspection services are accredited by the U.S.
Department of Labor under 29 CFR 1919; to inspect, test and certify cranes.
Maintained under the GEH-No MO preventive maintenance program and inspected in accordance with the requirements specified in 10 CFR 1910.179 and ANSI 830-
- 2. Yearly inspections are performed by an independent contractor whose crane inspection services are accredited by the U.S.
DepartmentofLaborunder29 CFR 1919; to inspect, test and certify cranes.
Morris Operation HITACHI Consolidated Safety Analysis Report Structure Item Link and/or Material Component XI.M23 Cask Crane, Structural including steel bridge and trolley GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 Aging Effect/
Environment Mechanism Air - indoor, Cumulative fatigue uncontrolled damage I fatigue.
Loss of material I General corrosion &
wear.
PAGE DATE DRAFT Page 20 REVISION 15A Aging Management Program Further (AMP)
Evaluation Maintained under the GEH-No MO preventive maintenance program and inspected in accordance with the requirements specified in 1 O CFR 1910.179 and ANSI 830-
- 2. Yearly inspections are performed by an independent contractor whose crane inspection services are accredited by the U.S.
Department of Labor under 29 CFR 1919; to inspect, test and certify cranes.
A Morris Operation
'W/ HITACHI Consolidated Safety Analysis Report Structures Monitoring Table 2 - Acceptance Criteria Concrete Surfaces Concrete Em bedments Steel Structures Absence of leaching and chemical Concrete surface condition attributes Loss or degraded areas of paint less attack are met than or equal to 4,000 mm2 (6 in. 2) at one area Absence of abrasion, erosion, and Absence of corrosion of the exposed Loss or degraded areas of paint less cavitation embedded metal surfaces and than or equal to 10,000 mm2 (16 in.2) corrosion stains around the embedded over the gross surface of the metal structure Popouts and voids less than 20 mm Absence of detached embedments or (3/4 in.) in diameter or equivalent loose bolts surface area Scaling less than 5 mm (3/16 in.) in Absence of indications of degradation depth due to vibratory loads from piping and equipment Spalling less than 10 mm (3/8 in.) in depth and 100 mm (4 in.) in any dimension Absence of any signs of corrosion in the steel reinforcement or anchorage components Passive cracks less than 0.4 mm (0.015 in.) in maximum width (note 1)
GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT Page 21 REVISION 15A Stainless Steel Liner (with Leak Detection)
No increase in leakage rate observed in leak-detection system Absence of bulges or depressions in liner plate -
related to aging not construction Basin Water Analysis:
- Gross beta < 0.02 µCi/ml
- Conductivity <1.35
µMho/cm.
HITACHI Morris Operation Consolidated Safety Analysis Report Concrete Surfaces Concrete Embedments Steel Structures Stainless Steel Liner (with Leak Detection)
Absence of excessive deflections, settlements, or other physical movements that can affect structural performance Monitoring Well Analysis (at least 1 of 3):
- Verification of non-aggressive ground water or soil (pH > 5.5, chlorides < 500 ppm, or sulfates <1500 ppm)
Notes:
- 1.
passive cracks are defined as those having and absence of recent growth and an absence of other degradation mechanisms at the crack GE HITACHI NUCLEAR ENERGY AMERICAS, LLC SNM-2500 CSAR Appendix A.8 PAGE DATE DRAFT REVISION 15A Page 22
REV.
SEC11ON(S)
MODIFIED 15A A.8, pg 4 15A A.8, pg 4 15A A.8, pg 4 15A A.8, Table 1 15A A.8, Table 1 15A A.8, Table 1 15A A.8, Table 2 15A A.8, pg 4 15A A.8, pg 4 15A A.8, pg 4 15A A.8, pg 7 15A A.8, Table 1 DOCUMENT REVISION
SUMMARY
CSAR Rev 15, App A-8 REVISION DESCRIPTION Added stainless-steel liner to "b" and "c" of the scope of Basin Inspection/Monitoring Activities Added "These inspections will typically include 100% of readily accessible surfaces."
Changed "coating" to "paint" III.A5.TP-25 & III.A5.TP-300 (Admin correction)
Added Zircaloy fuel cladding Added Fuel Basin Crane, Fuel Handling Crane,
& Cask Crane Changed "coatings" to "paint" Removed "typically" from inspections Added "d)": "Annual visual inspection of 100% of the readily accessible surfaces of the fuel cladding, both stainless steel and zircaloy, from the basin crane and/or the basin walkways."
Moved previous "d)" & "e )" to "e )" & "O.
Added "(e.g., baskets and grid)" to "e)"
Added "considered to be Important to Safety under Section 11.3 are maintained in compliance with the requirements specified in Aging Management Program Review Table 1, Items# XI.M23" Revised to include the baskets and grid in Item #
111.AS.T-14 DATE AUTHOR 1/25/22 AEM 1/25/22 AEM 1/25/22 AEM 1/25/22 AEM 1/25/22 AEM 1/25/22 AEM 1/25/22 AEM 5/10/22 AEM 5/10/22 AEM 5/10/22 AEM 5/10/22 AEM 5/10/22 AEM