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| issue date = 08/18/2014
| issue date = 08/18/2014
| title = Enclosure - Example AMP - 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
| title = Enclosure - Example AMP - 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
| author name = Dunn D S
| author name = Dunn D
| author affiliation = NRC/NMSS/SFST
| author affiliation = NRC/NMSS/SFST
| addressee name =  
| addressee name =  
Line 9: Line 9:
| docket = 05000317, 05000318, 07200008
| docket = 05000317, 05000318, 07200008
| license number =  
| license number =  
| contact person = Goshen J M
| contact person = Goshen J
| case reference number = TAC L24475
| case reference number = TAC L24475
| package number = ML14230A903
| package number = ML14230A903
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{{#Wiki_filter:AgingManagementProgramAging Management Program Example for Stress Corrosion CrackingDarrellS.DunnDarrell S. DunnMeeting to Discuss the Request for Additional Information Responses Regarding the Calvert Cliffs Independent Spent pggppFuel Storage Facility License Renewal July 17, 2014 Stress Corrosion Cracking BackgroundInformationBackground Information *304 and 316 Stainless steels are susceptibletochloridestresssusceptible to chloride stress corrosion cracking (SCC)-Sensitization from welding increases susceptibility-Crevice and pitting corrosion can be precursors to SCC-SCC possible with low surface chloride concentrations 2/3oftherequirements*Welded stainless steel canisters have sufficient through wall tensile residual stresses for SCCAthiSCCfldd2/3 of the requirements for SCC are present in welded stainless steel *Atmospheric SCC of welded stainless steels has been observed-Component failures in 16-33 years-Estimated crack growth rates of 0.11 canisters gto 0.91 mm/yr2 Regulatory Basis*10 CFR 72.42(a), 72.240(c): TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.AdescriptionoftheAMPformanagementofissuesassociatedA description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs.*Guidance: NUREG-1927 AMP Elements:1.Scope of the Program2.Preventive Actions 3.Parameters Monitored/Inspected6.Acceptance Criteria7.Corrective Actions 8.Confirmation Process 4.Detection of Aging Effects 5.Monitoring and Trending9.Administrative Controls10.Operating Experience3 AMP Element 1 ScopeoftheProgramScope of the Program NUREG-1927: The scope of the program should include the specific structuresandcomponentssubjecttoanAMR*Welded stainless steel dry storage canistersFabricationandclosureweldsstructures and components subject to an AMR-Fabrication and closure welds -Weld heat affected zones-LocationswheretemporarysupportsorfixtureswereLocations where temporary supports or fixtures were attached by welding-Crevice locations -Surface areas where atmospheric deposits preferentially occursSurfaceareaswithalowerthanaveragetemperature-Surface areas with a lower than average temperature   4 AMP Element 2PreventativeActionsPreventative ActionsNUREG-1927: Preventive actions should mitigate or prevent the applicableagingeffects*Aging Management Program (AMP) is for conditionmonitoringapplicable aging effectscondition monitoring. -Preventative actions are not presently incorporated into existing dry storage canister designs*Future designs or amendments could include -Surface modification to impart compressive residual ffstresses on welds and weld heat affected zones-Materials with improved localized corrosion and SCC resistanceresistance5 AMP Element 3ParametersMonitored/InspectedParameters Monitored/InspectedNUREG-1927: Parameters monitored or inspected should be linked to theeffectsofagingontheintendedfunctionsoftheparticularstructure*Canister surfaces, welds, and weld heat affected the effects of aging on the intended functions of the particular structure and component,,zones for discontinuities and imperfections *Size and location of localized corrosion (e.g., (gpitting and crevice corrosion) and stress corrosion cracks*Appearance and location of atmospheric deposits on the canister surfaces6 AMP Element 4DetectionofAgingEffects(1/2)Detection of Aging Effects (1/2)NUREG-1927: Define method or technique, frequency, sample size, datacollection,andtimingtoensuretimelydetectionofagingeffects*Qualified and demonstrated technique to detect evidence oflocalizedcorrosionandSCC:data collection, and timing to ensure timely detection of aging effectsof localized corrosion and SCC:-Remote visual inspection, e.g. EVT-1, VT-1, VT-3, or Eddy Current Testing (ET) may be appropriatePdidttifidiiiSCCldi*Pending detection findings, sizing SCC would require volumetric methods7 AMP Element 4DetectionofAgingEffects(2/2)Detection of Aging Effects (2/2)*Sample sizep-Minimum of one canister at each site-Canisters with the greatest susceptibility *Data Collection-Documentation of the examination of the canisterLocationandappearanceofdeposits-Location and appearance of deposits*Frequency-Every5yearsEvery 5 years*Timing of Inspections -Within 25 years of initial loading8 AMP Element 5MonitoringandTrendingMonitoring and TrendingNUREG-1927:Should provide for prediction of the extent of the effects ofagingandtimelycorrectiveormitigativeactions*Document canister condition particularly at welds andcrevicelocationsusingimagesandvideoof aging and timely corrective or mitigativeactionsand crevice locations using images and video that will allow comparison in subsequent examinations *Changes to the size and number of any corrosion product accumulations *Location and sizing of localized corrosion and stress corrosion cracking 9 AMP Element 6 AcceptanceCriteria(1/2)Acceptance Criteria (1/2)NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated; should ensure that SSC functions *No indications of: ;are maintained-Pitting or crevice corrosion  -Stress corrosion cracking -Corrosion products near crevices -Corrosion products on or adjacent to fabrication welds, closureweldsandweldsfortemporarysupportsorclosure welds, and welds for temporary supports or attachments10 AMP Element 6 AcceptanceCriteria(2/2)Acceptance Criteria (2/2)*Locations with corrosion products require additional examination for localized corrosion and/or SCC*Size of the area affected and the depth of penetration if localized corrosion and/or SCC is identifiedidentified*Canisters with localized corrosion and/or SCC mustbeevaluatedforcontinuedserviceinmust be evaluated for continued service in accordance with ASME B&PV Code Section XI IWB-3514.1 and IWB-3640 11 AMP Element 7CorrectiveActionsCorrective ActionsNUREG-1927:Corrective actions, including root cause determination andpreventionofrecurrence,shouldbetimely*Supplemental inspections to determine the extentofconditionatthesiteand prevention of recurrence, should be timelyextent of condition at the site *Subsequent inspections of canisters with indications*Canisters that do not meet the prescribed evaluation criteria must be repaired or removed pfrom service12 AMP Element 8ConfirmationProcessConfirmation ProcessNUREG-1927:Confirmation process should ensure that preventive actions are adequate & appropriate corrective actions have been *Licensee Quality Assurance Program consistent with10CFR72SubpartGor10CFR50qpppcompleted & are effectivewith 10 CFR 72 Subpart G, or 10 CFR 50 Appendix B*Ensure that inspections, evaluations, and p,,corrective actions are completed in accordance with the Site Specific or General Licensees CorrectiveActionProgram(CAP)Corrective Action Program (CAP)-Extent of condition-Evaluation for continued service-Repair, replace, mitigation actions13 AMP Element 9AdministrativeControlsAdministrative ControlsNUREG-1927: Administrative controls should provide a formal review andapprovalprocess*Licensee Quality Assurance Program consistent with10CFR72SubpartGor10CFR50and approval processwith 10 CFR 72 Subpart G, or 10 CFR 50 Appendix B*Trainingrequirementsforinspectors*Training requirements for inspectors*Records retention requirements14 AMP Element 10OperationalExperienceOperational ExperienceNUREG-1927:Include past corrective actions; provide objective evidencetosupportadeterminationthattheeffectsofagingwillbe*NoreportedcasesoflocalizedcorrosionorSCCinevidence to support a determination that the effects of aging will be adequately managed so that the SSC intended functions will be maintained during the period of extended operation*No reported cases of localized corrosion or SCC in welded stainless steel canisters*Atmospheric deposits on canister surfaces have been observed *Several reported cases of chloride induced SCC from atmosphericdepositsobservedinoperatingreactorsatmospheric deposits observed in operating reactors (NRC Information Notice 2012-20)*Laboratory and field test data on conditions necessary for yychloride induced SCC and SCC growth rates 15 AcronymsAcronymsAMP: Aging management program TLAA: time limiting aging analysisAMR: Aging management reviewASME B&PV code: American Society ITS: Important to safety SCC: Stress corrosion crackingyof Mechanical Engineers Boiler and Pressure Vessel code CAP: Corrective action programgSSC: Structures systems and componentspgCFR: Code of Federal RegulationsEVT1:Enhancedvisualtesting1VT-1: Visual Testing-1 (ASME B&PV code Section XI, Article IWA-2200) VT3:VisualTesting3(ASMEB&PVEVT-1: Enhanced visual testing-1(Boiling water reactor vessels and internals project, BWRVIP-03)VT-3: Visual Testing-3 (ASME B&PV code Section XI, Article IWA-2200)16}}
{{#Wiki_filter:Aging Management Program Example for Stress Corrosion Cracking Darrell S. Dunn Meeting to Discuss the Request for Additional Information Responses p        Regarding g    g the Calvert Cliffs Independent p      Spent p
Fuel Storage Facility License Renewal July 17, 2014
 
Stress Corrosion Cracking Background Information
* 304 and 316 Stainless steels are susceptible to chloride stress corrosion cracking (SCC)
                          - Sensitization from welding increases susceptibility
                          - Crevice and pitting corrosion can be precursors to SCC
                          - SCC possible with low surface chloride concentrations
* Welded stainless steel canisters have sufficient through wall tensile residual stresses for SCC 2/3 of the requirements
* At Atmospheric h i SCC off welded ld d stainless steels has been observed for SCC are present in    - Component failures in 16-33 years welded stainless steel    - Estimated crack ggrowth rates of 0.11 to 0.91 mm/yr canisters 2
 
Regulatory Basis
* 10 CFR 72.42(a), 72.240(c):
TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.
A description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs.
* Guidance: NUREG-1927 AMP Elements:
: 1. Scope of the Program              6. Acceptance Criteria
: 2. Preventive Actions                 7. Corrective Actions
: 3. Parameters Monitored/Inspected    8. Confirmation Process
: 4. Detection of Aging Effects         9. Administrative Controls
: 5. Monitoring and Trending            10. Operating Experience 3
 
AMP Element 1 Scope of the Program NUREG-1927: The scope of the program should include the specific structures and components subject to an AMR
* Welded stainless steel dry storage canisters
    - Fabrication and closure welds
    - Weld heat affected zones
    - Locations where temporary supports or fixtures were attached by welding
    - Crevice locations
    - Surface areas where atmospheric deposits preferentially occurs
    - Surface areas with a lower than average temperature 4
 
AMP Element 2 Preventative Actions NUREG-1927: Preventive actions should mitigate or prevent the applicable aging effects
* Aging Management Program (AMP) is for condition monitoring monitoring.
    - Preventative actions are not presently incorporated into existing dry storage canister designs
* Future designs or amendments could include
    - Surface modification to impart compressive residual stresses on welds and weld heat affected ff      zones
    - Materials with improved localized corrosion and SCC resistance 5
 
AMP Element 3 Parameters Monitored/Inspected NUREG-1927: Parameters monitored or inspected should be linked to the effects of aging on the intended functions of the particular structure and component
* Canister surfaces,, welds,, and weld heat affected zones for discontinuities and imperfections
* Size and location of localized corrosion (e.g.,           ( g pitting and crevice corrosion) and stress corrosion cracks
* Appearance and location of atmospheric deposits on the canister surfaces 6
 
AMP Element 4 Detection of Aging Effects (1/2)
NUREG-1927: Define method or technique, frequency, sample size, data collection, and timing to ensure timely detection of aging effects
* Qualified and demonstrated technique to detect evidence of localized corrosion and SCC:
    - Remote visual inspection, e.g. EVT-1, VT-1, VT-3, or Eddy Current Testing (ET) may be appropriate
* PPending di d  detection t ti fifindings, di    sizing i i SCC would     ld require i
volumetric methods 7
 
AMP Element 4 Detection of Aging Effects (2/2)
* Sample p size
  - Minimum of one canister at each site
  - Canisters with the greatest susceptibility
* Data Collection
  - Documentation of the examination of the canister
  - Location and appearance of deposits
* Frequency
  - Every 5 years
* Timing of Inspections
  - Within 25 years of initial loading 8
 
AMP Element 5 Monitoring and Trending NUREG-1927: Should provide for prediction of the extent of the effects of aging and timely corrective or mitigative actions
* Document canister condition particularly at welds and crevice locations using images and video that will allow comparison in subsequent examinations
* Changes to the size and number of any corrosion product accumulations
* Location and sizing of localized corrosion and stress corrosion cracking 9
 
AMP Element 6 Acceptance Criteria (1/2)
NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated;; should ensure that SSC functions are maintained
* No indications of:
    - Pitting or crevice corrosion
    - Stress corrosion cracking
    - Corrosion products near crevices
    - Corrosion products on or adjacent to fabrication welds, closure welds welds, and welds for temporary supports or attachments 10
 
AMP Element 6 Acceptance Criteria (2/2)
* Locations with corrosion products require additional examination for localized corrosion and/or SCC
* Size of the area affected and the depth of penetration if localized corrosion and/or SCC is identified
* Canisters with localized corrosion and/or SCC must be evaluated for continued service in accordance with ASME B&PV Code Section XI IWB-3514.1 and IWB-3640 11
 
AMP Element 7 Corrective Actions NUREG-1927: Corrective actions, including root cause determination and prevention of recurrence, should be timely
* Supplemental inspections to determine the extent of condition at the site
* Subsequent inspections of canisters with indications
* Canisters that do not meet the prescribed evaluation criteria must be repaired     p      or removed from service 12
 
AMP Element 8 Confirmation Process NUREG-1927: Confirmation process should ensure that preventive q
actions are adequate & appropriate pp p      corrective actions have been completed & are effective
* Licensee Quality Assurance Program consistent with 10 CFR 72 Subpart G          G, or 10 CFR 50 Appendix B p
* Ensure that inspections,        , evaluations,, and corrective actions are completed in accordance with the Site Specific or General Licensees Corrective Action Program (CAP)
    - Extent of condition
    - Evaluation for continued service
    - Repair, replace, mitigation actions 13
 
AMP Element 9 Administrative Controls NUREG-1927: Administrative controls should provide a formal review and approval process
* Licensee Quality Assurance Program consistent with 10 CFR 72 Subpart G        G, or 10 CFR 50 Appendix B
* Training requirements for inspectors
* Records retention requirements 14
 
AMP Element 10 Operational Experience NUREG-1927: Include past corrective actions; provide objective evidence to support a determination that the effects of aging will be adequately managed so that the SSC intended functions will be maintained during the period of extended operation
* No reported cases of localized corrosion or SCC in welded stainless steel canisters
* Atmospheric deposits on canister surfaces have been observed
* Several reported cases of chloride induced SCC from atmospheric deposits observed in operating reactors (NRC Information Notice 2012-20)
* Laboratoryy and field test data on conditions necessaryy for chloride induced SCC and SCC growth rates 15
 
Acronyms AMP: Aging management program       TLAA: time limiting aging analysis AMR: Aging management review        ITS: Important to safety ASME B&PV code: American Societyy    SCC: Stress corrosion crackingg of Mechanical Engineers Boiler and Pressure Vessel code                 SSC: Structures systems and components CAP: Corrective action pprogram g
VT-1: Visual Testing-1 (ASME B&PV CFR: Code of Federal Regulations    code Section XI, Article IWA-2200)
EVT-1:
EVT  1: Enhanced visual testing testing-1 1  VT-3:
VT 3: Visual Testing-3 Testing 3 (ASME B&PV (Boiling water reactor vessels and  code Section XI, Article IWA-2200) internals project, BWRVIP-03) 16}}

Latest revision as of 02:17, 4 November 2019

Enclosure - Example AMP - 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
ML14230A911
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/18/2014
From: Darrell Dunn
NRC/NMSS/SFST
To:
Goshen J
Shared Package
ML14230A903 List:
References
TAC L24475
Download: ML14230A911 (16)


Text

Aging Management Program Example for Stress Corrosion Cracking Darrell S. Dunn Meeting to Discuss the Request for Additional Information Responses p Regarding g g the Calvert Cliffs Independent p Spent p

Fuel Storage Facility License Renewal July 17, 2014

Stress Corrosion Cracking Background Information

- Sensitization from welding increases susceptibility

- Crevice and pitting corrosion can be precursors to SCC

- SCC possible with low surface chloride concentrations

  • Welded stainless steel canisters have sufficient through wall tensile residual stresses for SCC 2/3 of the requirements
  • At Atmospheric h i SCC off welded ld d stainless steels has been observed for SCC are present in - Component failures in 16-33 years welded stainless steel - Estimated crack ggrowth rates of 0.11 to 0.91 mm/yr canisters 2

Regulatory Basis

TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.

A description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs.

1. Scope of the Program 6. Acceptance Criteria
2. Preventive Actions 7. Corrective Actions
3. Parameters Monitored/Inspected 8. Confirmation Process
4. Detection of Aging Effects 9. Administrative Controls
5. Monitoring and Trending 10. Operating Experience 3

AMP Element 1 Scope of the Program NUREG-1927: The scope of the program should include the specific structures and components subject to an AMR

  • Welded stainless steel dry storage canisters

- Fabrication and closure welds

- Weld heat affected zones

- Locations where temporary supports or fixtures were attached by welding

- Crevice locations

- Surface areas where atmospheric deposits preferentially occurs

- Surface areas with a lower than average temperature 4

AMP Element 2 Preventative Actions NUREG-1927: Preventive actions should mitigate or prevent the applicable aging effects

- Preventative actions are not presently incorporated into existing dry storage canister designs

  • Future designs or amendments could include

- Surface modification to impart compressive residual stresses on welds and weld heat affected ff zones

- Materials with improved localized corrosion and SCC resistance 5

AMP Element 3 Parameters Monitored/Inspected NUREG-1927: Parameters monitored or inspected should be linked to the effects of aging on the intended functions of the particular structure and component

  • Canister surfaces,, welds,, and weld heat affected zones for discontinuities and imperfections
  • Size and location of localized corrosion (e.g., ( g pitting and crevice corrosion) and stress corrosion cracks
  • Appearance and location of atmospheric deposits on the canister surfaces 6

AMP Element 4 Detection of Aging Effects (1/2)

NUREG-1927: Define method or technique, frequency, sample size, data collection, and timing to ensure timely detection of aging effects

  • Qualified and demonstrated technique to detect evidence of localized corrosion and SCC:

- Remote visual inspection, e.g. EVT-1, VT-1, VT-3, or Eddy Current Testing (ET) may be appropriate

  • PPending di d detection t ti fifindings, di sizing i i SCC would ld require i

volumetric methods 7

AMP Element 4 Detection of Aging Effects (2/2)

  • Sample p size

- Minimum of one canister at each site

- Canisters with the greatest susceptibility

  • Data Collection

- Documentation of the examination of the canister

- Location and appearance of deposits

  • Frequency

- Every 5 years

  • Timing of Inspections

- Within 25 years of initial loading 8

AMP Element 5 Monitoring and Trending NUREG-1927: Should provide for prediction of the extent of the effects of aging and timely corrective or mitigative actions

  • Document canister condition particularly at welds and crevice locations using images and video that will allow comparison in subsequent examinations
  • Changes to the size and number of any corrosion product accumulations

AMP Element 6 Acceptance Criteria (1/2)

NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated;; should ensure that SSC functions are maintained

  • No indications of:

- Pitting or crevice corrosion

- Stress corrosion cracking

- Corrosion products near crevices

- Corrosion products on or adjacent to fabrication welds, closure welds welds, and welds for temporary supports or attachments 10

AMP Element 6 Acceptance Criteria (2/2)

  • Locations with corrosion products require additional examination for localized corrosion and/or SCC
  • Size of the area affected and the depth of penetration if localized corrosion and/or SCC is identified
  • Canisters with localized corrosion and/or SCC must be evaluated for continued service in accordance with ASME B&PV Code Section XI IWB-3514.1 and IWB-3640 11

AMP Element 7 Corrective Actions NUREG-1927: Corrective actions, including root cause determination and prevention of recurrence, should be timely

  • Supplemental inspections to determine the extent of condition at the site
  • Subsequent inspections of canisters with indications
  • Canisters that do not meet the prescribed evaluation criteria must be repaired p or removed from service 12

AMP Element 8 Confirmation Process NUREG-1927: Confirmation process should ensure that preventive q

actions are adequate & appropriate pp p corrective actions have been completed & are effective

  • Ensure that inspections, , evaluations,, and corrective actions are completed in accordance with the Site Specific or General Licensees Corrective Action Program (CAP)

- Extent of condition

- Evaluation for continued service

- Repair, replace, mitigation actions 13

AMP Element 9 Administrative Controls NUREG-1927: Administrative controls should provide a formal review and approval process

  • Training requirements for inspectors
  • Records retention requirements 14

AMP Element 10 Operational Experience NUREG-1927: Include past corrective actions; provide objective evidence to support a determination that the effects of aging will be adequately managed so that the SSC intended functions will be maintained during the period of extended operation

  • No reported cases of localized corrosion or SCC in welded stainless steel canisters
  • Atmospheric deposits on canister surfaces have been observed
  • Laboratoryy and field test data on conditions necessaryy for chloride induced SCC and SCC growth rates 15

Acronyms AMP: Aging management program TLAA: time limiting aging analysis AMR: Aging management review ITS: Important to safety ASME B&PV code: American Societyy SCC: Stress corrosion crackingg of Mechanical Engineers Boiler and Pressure Vessel code SSC: Structures systems and components CAP: Corrective action pprogram g

VT-1: Visual Testing-1 (ASME B&PV CFR: Code of Federal Regulations code Section XI, Article IWA-2200)

EVT-1:

EVT 1: Enhanced visual testing testing-1 1 VT-3:

VT 3: Visual Testing-3 Testing 3 (ASME B&PV (Boiling water reactor vessels and code Section XI, Article IWA-2200) internals project, BWRVIP-03) 16