ML14230A910

Enclosure - July 17, 2014, Summary of Meeting with Exelon Corporation to Discuss Request for Additional Information No. 4 to the Calvert Cliffs ISFSI License Renewal Application (Docket No. 72-08) TAC L24475

ML14230A910
Person / Time
Site:	Calvert Cliffs
Issue date:	08/18/2014
From:	Exelon Generation Co
To:	NRC/NMSS/SFST
Goshen J
Shared Package
ML14230A903	List: ML14230A908 ML14230A909 ML14230A910 ML14230A911 ML14230A913
References
TAC L24475
Download: ML14230A910 (36)

Text

C l t Cliff I d d

t S t

Calvert Cliffs Independent Spent Fuel Storage Installation g

License Renewal Application Discussion of Request for f

Additional Information Rockville, Maryland July 17, 2014

Attendees - Calvert Cliffs

• Pamela Cowan - Director, Spent Fuel & Decommissioning Ji W

d M

ISFSI I l

t ti

& S t

• Jim Wood - Manager, ISFSI Implementation & Support

• John Massari - Manager, Nuclear Fuels

• Paul Gregory Sr Program Manager Dry Cask Storage

• Paul Gregory - Sr. Program Manager, Dry Cask Storage

• Tom Konerth - Engineering Manager

• Heidi Valenta - Consultant Engineer, D&Z Heidi Valenta Consultant Engineer, D&Z

• Paul Robbins - Engineer, Mechanical/Civil

• Ken Greene - Principal Engineer, Regulatory Assurance Calvert Cliffs ISFSI Discussion of RAIs 1

Agenda

• Introductions

• Objective of Meeting

• Background

• Discussion of Requests for Additional Information and Calvert Cliffs Proposed Responses

• Closing Remarks Calvert Cliffs ISFSI Discussion of RAIs 2

Acronyms Acronyms ACI American Concrete Institute AMP Aging Management Program AMR Aging Management Review g g g

ANSI American National Standard Institute ASME American Society of Mechanical Engineers CAP Corrective Action Program CISCC Chloride Induced Stress Corrosion Cracking DSC Dry Shielded Canister EPRI Electric Power Research Institute HSM Horizontal Storage Module ISFSI Independent Spent Fuel Storage Installation p

p g

LRA License Renewal Application NDE Non-destructive Examination NRC Nuclear Regulatory Commission OE Operating Experience p

g p

RAI Request for Additional Information RSI Request for Supplemental Information SCC Stress Corrosion Cracking USAR Updated Safety Analysis Report p

y y

p Calvert Cliffs ISFSI Discussion of RAIs 3

Objective of Meeting

• Ensure clear understanding of RAIs

• Reach agreement on response strategies Calvert Cliffs ISFSI Discussion of RAIs 4

=

Background===

ISFSI Operations commenced - 1992 Submitted CCNPP ISFSI License Renewal Application-September 2010 Requested 40 year extension beyond November 2012 Responses to RSIs Submitted - February 2011 Responses to 1st Set of RAIs Submitted - June 2011 Responses to Environmental Set of RAI Responses Submitted -

June 2011 Responses to 2nd Set of RAIs Responses Submitted -

December 2011 Lead Canister Inspection Report Submitted - July 2012 Responses to 3rd Set of RAIs Responses Submitted - June 2013 Calvert Cliffs ISFSI Discussion of RAIs 5

Discussion of RAI-1

• RAI-1

• Revise the evaluation that demonstrates DSC in HSM will maintain design basis confinement integrity and include

1) minimum chloride for SCC, 2) time to develop minimum CI concentration and 3) activation energy for CISCC CI concentration, and 3) activation energy for CISCC propagation rates.

Calvert Cliffs ISFSI Discussion of RAIs 6

Discussion of RAI-1 Response to RAI 1:

Response to RAI-1:

• Toll gates will specify initial and determine subsequent inspection frequency.

inspection frequency.

- Environmental calculation based times no longer being considered and will not be revised.

- Chloride threshold for SCC initiation referenced by NRC staff in RAI-1 supports low probability of CISCC during renewal period.

• Additional dose calculations not required Additional dose calculations not required.

- Existing accident dose calcs (USAR Ch. 12.8.2.8 and CA07718) treat release from confinement failure as a bounding puff release.

Calvert Cliffs ISFSI Discussion of RAIs 7

Discussion of RAI-2

RAI-2

• Provide a revised AMP that considers the potential for CISCC on the DSC.

Calvert Cliffs ISFSI Discussion of RAIs 8

Discussion of RAI-2 R

t

RAI 2

Response to RAI-2:

AMP for DSC CISCC provided in 6/14/2013 RAI response will be revised to address the 10 elements described in NUREG-1927 Section 3.6.

Toll gate inspection planned for 2017.

Vi l b d

t d t d

d d hl id li Visual based on accepted standards and chloride sampling.

Subsequent toll gate will apply information from prior toll gate and OE from other inspections and research to determine future p

inspection frequency and technique.

AMP will be included in a revision to Appendix A of the 9/17/2010 License Renewal Application License Renewal Application.

Calvert Cliffs ISFSI Discussion of RAIs 9

Discussion of RAI-3

RAI-3

• Revise the Transfer Cask Lifting Yoke AMP and include standards for visual examination methods and details of magnetic particle testing.

Calvert Cliffs ISFSI Discussion of RAIs 10

Discussion of RAI-3 Response to RAI-3:

• Perform NDE Inspections IAW ANSI/ASME III Div.1 1986 and ANSI N14.6 1978 (refer to MPM10151G-Hook and Yoke Baseline data).

• Perform MT IAW ANSI/ASME Section III Div 1 1986 PAR

• Perform MT IAW ANSI/ASME Section III Div.1, 1986 PAR.

NF 5340.

Calvert Cliffs ISFSI Discussion of RAIs 11

Discussion of RAI-4

RAI-4

• Revise the Transfer Cask AMP and include standards for visual examination methods and details of penetrant testing.

Calvert Cliffs ISFSI Discussion of RAIs 12

Discussion of RAI-4 Response to RAI-4:

• Visual evidence of degradation of external surfaces of f

C f

Transfer Cask once every five years or prior to each use.

• Perform inspections of coated materials for degradation.

• Acceptance criteria not met if corrosion is observed

• Acceptance criteria not met if corrosion is observed.

See RAI-6.

• Corrective Action Program relies on engineering g

g g

evaluation for further action.

Calvert Cliffs ISFSI Discussion of RAIs 13

Discussion of RAI-5

RAI-5

• Address aging effects/mechanisms for concrete structures consistent with ACI 349.3R or provide detailed site-specific technical justifications.

Calvert Cliffs ISFSI Discussion of RAIs 14

Discussion of RAI-5 Response to RAI-5:

• Revise HSM AMP to address aging effects/mechanisms i t t

ith ACI 349 3R consistent with ACI 349.3R.

• Revise HSM AMP to include inspections and acceptance criteria IAW criteria IAW ACI 349.3R.

• Will provide site specific technical justification if any exclusions taken.

Calvert Cliffs ISFSI Discussion of RAIs 15

Discussion of RAI-6

RAI-6

• Define and justify the use of other codes, standards, or quantitative guidelines for the acceptance criteria of stainless and carbon steel in the HSMs.

Calvert Cliffs ISFSI Discussion of RAIs 16

Discussion of RAI-6 Response to RAI-6:

• Acceptance Criteria for the HSM AMP for both stainless d

b t

l t

h ll b b

d th d

i and carbon steel components shall be based on the design methodologies defined in CCNPP ISFSI USAR Section 4.2.1.1.

• CCNPP ISFSI USAR Section 4.2.1.1 references American Institute of Steel construction (AISC), Specification for the Design Fabrication and Erection of Structural Steel for Design, Fabrication and Erection of Structural Steel for Buildings 8th Edition.

Calvert Cliffs ISFSI Discussion of RAIs 17

Discussion of RAI-7

RAI-7

• Revise the HSM AMP to include inspections of the interior and underground foundation consistent with ACI 349.3R.

Calvert Cliffs ISFSI Discussion of RAIs 18

Discussion of RAI-7 Response to RAI-7:

• Prioritization and selection for periodic evaluation of interior and underground foundation is based on 10 program elements in NUREG-1927.

• Periodic internal inspection by remote device to inspect

• Periodic internal inspection by remote device to inspect interior of HSM.

Calvert Cliffs ISFSI Discussion of RAIs 19

Discussion of RAI-8

RAI-8

• Revise HSM AMP to include a groundwater chemistry program.

Calvert Cliffs ISFSI Discussion of RAIs 20

Discussion of RAI-8 Response to RAI-8:

• Revise HSM AMP to include a groundwater chemistry program.

• Groundwater sampling of ISFSI pad in a minimum of 3 locations every 10 years to trend potential for corrosive locations every 10 years to trend potential for corrosive environment.

• Provide technical basis for deviation from ACI 349.3R acceptance criteria.

Calvert Cliffs ISFSI Discussion of RAIs 21

Discussion of RAI-9

RAI-9

• Confirm if HSMs contain BISCO NS-3.

Calvert Cliffs ISFSI Discussion of RAIs 22

Discussion of RAI-9 Response to RAI-9:

• There is no NS-3 in the HSMs at CCNPP.

• The 2" of NS-3 in the HSM door of the original NUHOMS design described in NUH-002 was replaced by 10.75" of concrete for the CCNPP site specific design to concrete for the CCNPP site specific design to accommodate a higher neutron source.

• This is described in Table 4.1-1 of the CCNPP ISFSI USAR.

Calvert Cliffs ISFSI Discussion of RAIs 23

Discussion of RAI-10

RAI-10

• Clarify if HSMs have experienced freeze-thaw degradation at anchor bolts of the outlet vents.

• Revise Table 3.4-1 of License Renewal Application to remove subscript Note 1 remove subscript Note 1.

• Revise OE subsection of HSM AMP.

Calvert Cliffs ISFSI Discussion of RAIs 24

Discussion of RAI-10 Response to RAI 10:

Response to RAI-10:

• The in-service HSMs (#1 through #72) have embedment around the vent areas to which the vent screens are bolted.

The new modular HSMs have structural mounting bolts attaching the outlet vent modules. To date there has been no Freeze-Thaw degradation on either the in-service or no Freeze Thaw degradation on either the in service or new HSMs.

• Remove Note 1 from Table 3.4-1 of License Renewal A

li ti Application.

• Revise CCNPP HSM AMP Operating Experience to include applicable TMI-2 (INL) experience applicable TMI 2 (INL) experience.

Calvert Cliffs ISFSI Discussion of RAIs 25

Discussion of RAI-11

RAI-11

• Discuss the CAP and when inspection results of the concrete pad will initiate an Action request, change to the AMP, or notification to the NRC. Also address use of OE from other ISFSIs.

from other ISFSIs.

Calvert Cliffs ISFSI Discussion of RAIs 26

Discussion of RAI-11 Response to RAI-11:

• Section A 2.1 of the CCNPP HSM AMP will reflect the ACI 349 3R tit ti th ti t

it i

f i

l 349.3R quantitative three-tier acceptance criteria for visual inspections of concrete.

• Degradations identified are entered into sites 10 CFR 50 g

Appendix B CAP.

• OE is reviewed as part of the sites CAP for ISFSI issues identified by NRC and industry identified by NRC and industry.

Calvert Cliffs ISFSI Discussion of RAIs 27

Discussion of RAI-12

RAI-12

• Revise HSM AMP to include details of the scope of rebar inspections in the HSMs.

Calvert Cliffs ISFSI Discussion of RAIs 28

Discussion of RAI-12 Response to RAI-12:

• HSM AMP to be revised to include greater detail on the t

it i

d f f

it i

scope, acceptance criteria, and frequency for monitoring rebar.

• Revised HSM will address the 10 program elements Revised HSM will address the 10 program elements detailed in NUREG-1927.

Calvert Cliffs ISFSI Discussion of RAIs 29

Discussion of RAI-13

RAI-13

• Revise OE in HSM AMP to include results of engineering evaluation used to determine the concrete degradation mechanisms identified in site condition reports.

Calvert Cliffs ISFSI Discussion of RAIs 30

Discussion of RAI-13 Response to RAI-13:

Professional Structural Engineering firm conducted an evaluation f

l t d HSM i J

2012 C

i t d f

l i

l of selected HSMs in June 2012. Consisted of up-close visual survey and hammer sounding of selected units where degradation was previously identified in CAP.

CRs evaluated as being non age-related degradation were assessed against age-related degradation definition contained in ACI 349.3R-02.

Results of evaluation to be incorporated in HSM AMP OE.

Calvert Cliffs ISFSI Discussion of RAIs 31

Discussion of RAI-14

RAI-14

• Clarify the normal and off normal doses presented in RAI response and confirm confinement release calculations are correct.

Calvert Cliffs ISFSI Discussion of RAIs 32

Discussion of RAI-14 Response to RAI-14:

• Page 7 of the 6/14/2013 Attachment (1) RAI response contained an editorial error.

• The units on the Normal and Off-Normal doses indicated should have been µrem rather than mrem should have been µrem rather than mrem.

• With that change, the results indicated are identical to those provided in the QAd calculation CA07718 provided in the p

Q p

12/15/2011 RAI response.

Calvert Cliffs ISFSI Discussion of RAIs 33

Discussion of RAI-15

RAI-15

• Provide an AMP for high burnup fuel behavior addressing the elements indicated in Section 3.6 of NUREG-1927.

Calvert Cliffs ISFSI Discussion of RAIs 34

Discussion of RAI-15 Response to RAI-15:

• CCNPP will provide an AMP based on the DOE High Burnup Cask Demonstration test plan.

• AMP will address the 10 elements described in NUREG-1927 Section 3 6 1927 Section 3.6.

• AMP will include Toll Gate Assessments.

• AMP will be included in a revision to Appendix A of the

• AMP will be included in a revision to Appendix A of the 9/17/2010 License Renewal Application.

Calvert Cliffs ISFSI Discussion of RAIs 35

Closing Remarks g

Calvert Cliffs ISFSI Discussion of RAIs 36