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| issue date = 08/18/2014
| issue date = 08/18/2014
| title = Enclosure - Elements of an AMP CC ISFSI - 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 - Elements of an AMP CC ISFSI - 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 = Goshen J M
| author name = Goshen J
| 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:EltfElements of anAgingManagement ProgramAging Management ProgramDivision of Spent Fuel Storage and TransportationOffifNlMtilSftdSfd Office of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionMeeting to Discuss the Request for Additional Information Responses Regarding the Calvert Cliffs Independent Spend Fuel Storage Facility License Renewal July 17, 2014 1
{{#Wiki_filter:Elements El              t off an Aging Management Program Division of Spent Fuel Storage and Transportation Offi off Nuclear Office   N l    Material M t i l Safety S f t and d Safeguards S f      d U.S. Nuclear Regulatory Commission Meeting to Discuss the Request for Additional Information Responses Regarding the Calvert Cliffs Independent Spend Fuel Storage Facility License Renewal July 17, 2014 1
Regulatory Basis10 CFR 72.42(a), 72.240(c): 1.TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.2.A description of the AMP for management of issues associated with agingthatcouldadverselyaffectITSSSCs aging that could adversely affect ITS SSCs.Guidance: NUREG-1927 AMP Elements:
 
1ScopeoftheProgram 6AcceptanceCriteria 1.Scope of the Program2.Preventive Actions3.Parameters Monitored/Inspected 4.DetectionofAgingEffects 6.Acceptance Criteria7.Corrective Actions 8.Confirmation Process 9.AdministrativeControlsFor in-scope SSCs, detailed AMPs addressing the 10 elements ldtffiittffidfftitfi 4.Detection of Aging Effects5.Monitoring and Trending 9.Administrative Controls10.Operating Experience lead to efficient staff reviews and effective managemen t of aging effects2 AMP Element 1:ScopeoftheProgram Scope of the ProgramNUREG-1927:The scope of the program should include the specific structures andcomponentssubjecttoanAMR and components subject to an AMRIdentifies:In-scope components and subcom ponentspppMaterials of constructionService environmentAging mechanisms for material/environment combination ggAging effects associated with each aging mechanism 3
Regulatory Basis 10 CFR 72.42(a), 72.240(c):
AMP Element 2:PreventiveActions Preventive ActionsNUREG-1927:
: 1. TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.
Preventive actions should mitigate or prevent the applicableagingeffects applicable aging effectsActions to minimize, control, or prevent the degradation mechanism, e.g. NRC-endorsed criteria (peak cladding temperatures below ISG-11, 3liitdidi)ddtddt rev. 3 limit during drying), consensus co des and standards, etc.4 AMP Element 3:ParametersMonitored/Inspected Parameters Monitored/
: 2. A description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs SSCs.
Inspected NUREG-1927:
Guidance: NUREG-1927 AMP Elements:
Parameters monitored or inspected should be linked to the effects ofagingontheintendedfunctionsoftheparticularstructureandcomponent of aging on the intended functions of the particular structure and componentIdentifies:Parameters (e.g. cracking size moni toring, rate of material loss, temperature, neutron fluence, etc.)Location(s) to be monitored or inspected (e.g. at highest heat location, neutron fluenceat 1 m from cask)Learning/Proactive/Responsive AMP:Operational experience and other quality data (tollgates)Informs parameters monitored/inspected (tiered approach) 5 AMP Element 4:DetectionofAging EffectsDetection of Aging EffectsNUREG-1927:Define method or technique, frequency, sample size, data collectionandtimingtoensuretimelydetectionofagingeffects collection
1.
, and timing to ensure timely detection of aging effectsIdentifies:Method/technique (e.g. visual, volumetric, and/or surface inspections or surveys)surveys)Frequency of inspection (e.g. inspection intervals)Sample size (dependent on operational experience trending)CalibrationofequipmentCalibration of equipment Data collection (clearinghouse for operational experience)Timing (new or one-time inspections, time of year)Li/Pti/Ri AMPLearning/Proactive/Responsive AMP:Operational experience and other quality data (tollgates)Consensus codes and standards Ifthd/thifdttiifft/hi6Informs methods/techniques for detecting aging effects/mechanisms (tiered approach)
1  Scope of the Program                  6.
AMP Element 5:Monitoring&Trending Monitoring
6    Acceptance Criteria
& TrendingNUREG-1927:Should provide for prediction of the extent of the effects of aging andtimelycorrectiveor mitigative actionsand timely corrective or mitigative actionsTrending of aging effects (e.g. corrosion rate, crack growth rate, etc.)Assess effects per prior inspections and industry-wide operational iexperienceLearning/Proactive/Responsive AMP
: 2. Preventive Actions                    7. Corrective Actions
:Operational experience and other quality data (tollgates)Informs monitoring and trending 7
: 3. Parameters Monitored/Inspected       8. Confirmation Process
AMP Element 6:AcceptanceCriteria Acceptance CriteriaNUREG-1927:Acceptance criteria, against which the need for corrective action will beevaluated;shouldensurethatSSCfunctionsaremaintained be evaluated; should ensure that SSC functions are maintainedCriteria for inspections, assessing aging effects, and decision-makingEstablish technical basis for s pecific acce ptance criteria ppDomestic and international consensus codes and standards whenever practicable, or previously justified and established criteriaSeparate criteria should be provided for each aging effectAlternative criteria may be used if justified:Supporting technical basis (OpEand/or engineering analysis/standards)Avoid non-quantifiable phrases (e.g. significant, moderate, minor, little, etc.)Learning/Proactive/Responsive AMP
: 4. Detection of Aging Effects            9. Administrative Controls
:Operational experience and other quality data (tollgates)Informs acceptance criteria 8
: 5. Monitoring and Trending              10. Operating Experience For in-scope SSCs, detailed AMPs addressing the 10 elements l d to lead t efficient ffi i t staff t ff reviews i    and d effective ff ti managementt off aging   i effects 2
AMP Element 7:CorrectiveActions Corrective ActionsNUREG-1927:Corrective actions, including root cause determination andpreventionofrecurrenceshouldbetimely prevention of recurrence
 
, should be timelyCAP commensurate with 10CFR72 Subpart G, or 10CFR50 Appendix BMaintenance plans and/or corrective actions for specific degradation fft(iltitititiiti&ttfeffects (e.g. repa ir, replacement, mitigation activities, & extent of condition)Actions to prevent reoccurrenceJustificationfor actionssuchasrepairreplaceand/ormitigateJustification for actions such as repair, replace, and/or mitigateAnalysis of how action may affect other subcomponentsConsideration of corrective actions on other componentsPlansforOpEincorporationintotheremediationplanPlans for OpEincorporation into the remediation planLearning/Proactive/Responsive AMP
AMP Element 1:
:Operational experience and other quality data (tollgates)Informscorrectiveactions 9Informs corrective actions AMP Element 8:
Scope of the Program NUREG-1927: The scope of the program should include the specific structures and components subject to an AMR Identifies:
Confirmation ProcessConfirmation ProcessNUREG-1927:
p components In-scope     p        and subcomponents p
The confirmation process should ensure that preventive actions areadequateandappropriatecorrectiveactionshavebeencompletedandare are adequate and appropriate corrective actions have been completed and are effectiveElement should reference:Quality Assurance Program consistent with 10CFR72 Subpart G, or 10CFR50 Appendix B.Methods to confirm adequate actions are taken, and are verified as fftieffective10 AMP Element 9:
Materials of construction Service environment Aging g g mechanisms for material/environment combination Aging effects associated with each aging mechanism 3
Administrative ControlsAdministrative ControlsNUREG-1927:
 
Administrative controls should provide a formal review and approvalprocess approval processElements should reference:Quality Assurance Pro gram consistent with 10CFR72 Sub part G, or ygp,10CFR50 Appendix B.Inspector requirementsRecord retention requirementsReview process of inspection resultsFrequency/methods for:reporting inspection results to NRCevaluating suitability of AMP based on industry-wide OpE(tollgates) 11 AMP Element 10:OperatingExperience Operating Experience NUREG-1927:
AMP Element 2:
Include past corrective actions; provide objective evidence to supportadeterminationthattheeffectsofagingwillbeadequatelymanagedso 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 operationCriticalelementtoLearning/Proactive/ResponsiveAMPCritical element to Learning/Proactive/Responsive AMPReferenceand evaluate applicable Operational Experience:Industry-wideCondition Reports, Corrective Action Reports, NRC InformationNotices Applicable industryinitiatives(egDOEcask Information Notices, Applicable industry initiatives (e.g. DOE cask demo, EPRI-sponsored inspections) 12}}
Preventive Actions NUREG-1927: Preventive actions should mitigate or prevent the applicable aging effects Actions to minimize, control, or prevent the degradation mechanism, e.g. NRC-endorsed criteria (peak cladding temperatures below ISG-11, rev. 3 limit li it during d i drying),
d i ) consensus codesd and d standards, t d d etc.t 4
 
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 Identifies:
Parameters (e.g. cracking size monitoring, rate of material loss, temperature, neutron fluence, etc.)
Location(s) to be monitored or inspected (e.g. at highest heat location, neutron fluence at 1 m from cask)
Learning/Proactive/Responsive AMP:
Operational experience and other quality data (tollgates)
Informs parameters monitored/inspected (tiered approach) 5
 
AMP Element 4:
Detection of Aging Effects NUREG-1927: Define method or technique, frequency, sample size, data collection and timing to ensure timely detection of aging effects collection, Identifies:
Method/technique (e.g. visual, volumetric, and/or surface inspections or surveys)
Frequency of inspection (e.g. inspection intervals)
Sample size (dependent on operational experience trending)
Calibration of equipment Data collection (clearinghouse for operational experience)
Timing (new or one-time inspections, time of year)
Learning/Proactive/Responsive L      i /P      ti /R        i AMP:
AMP Operational experience and other quality data (tollgates)
Consensus codes and standards Informs I f      methods/techniques th d /t h i      ffor detecting d t ti aging i effects/mechanisms ff t /    h i (tiered approach) 6
 
AMP Element 5:
Monitoring & Trending NUREG-1927: Should provide for prediction of the extent of the effects of aging and timely corrective or mitigative actions Trending of aging effects (e.g. corrosion rate, crack growth rate, etc.)
Assess effects per prior inspections and industry-wide operational experience i
Learning/Proactive/Responsive AMP:
Operational experience and other quality data (tollgates)
Informs monitoring and trending 7
 
AMP Element 6:
Acceptance Criteria NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated; should ensure that SSC functions are maintained Criteria for inspections, assessing aging effects, and decision-making Establish technical basis for specific p      acceptance p      criteria Domestic and international consensus codes and standards whenever practicable, or previously justified and established criteria Separate criteria should be provided for each aging effect Alternative criteria may be used if justified:
Supporting technical basis (OpE and/or engineering analysis/standards)
Avoid non-quantifiable phrases (e.g. significant, moderate, minor, little, etc.)
Learning/Proactive/Responsive AMP:
Operational experience and other quality data (tollgates)
Informs acceptance criteria 8
 
AMP Element 7:
Corrective Actions NUREG-1927: Corrective actions, including root cause determination and prevention of recurrence, recurrence should be timely CAP commensurate with 10CFR72 Subpart G, or 10CFR50 Appendix B Maintenance plans and/or corrective actions for specific degradation effects ff t ((e.g. repair, i replacement, l        t mitigation iti ti    activities, ti iti    & extent t t off condition)
Actions to prevent reoccurrence Justification for actions such as repair repair, replace replace, and/or mitigate Analysis of how action may affect other subcomponents Consideration of corrective actions on other components Plans for OpE incorporation into the remediation plan Learning/Proactive/Responsive AMP:
Operational experience and other quality data (tollgates)
Informs corrective actions 9
 
AMP Element 8:
Confirmation Process NUREG-1927: The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been completed and are effective Element should reference:
Quality Assurance Program consistent with 10CFR72 Subpart G, or 10CFR50 Appendix B.
Methods to confirm adequate actions are taken, and are verified as effective ff ti 10
 
AMP Element 9:
Administrative Controls NUREG-1927: Administrative controls should provide a formal review and approval process Elements should reference:
Qualityy Assurance Program  g    consistent with 10CFR72 Subpart p G,, or 10CFR50 Appendix B.
Inspector requirements Record retention requirements Review process of inspection results Frequency/methods for:
reporting inspection results to NRC evaluating suitability of AMP based on industry-wide OpE (tollgates) 11
 
AMP Element 10:
Operating 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 Critical element to Learning/Proactive/Responsive AMP Reference and evaluate applicable Operational Experience:
Industry-wide Condition Reports, Corrective Action Reports, NRC Information Notices, Notices Applicable industry initiatives (e.g.
(e g DOE cask demo, EPRI-sponsored inspections) 12}}

Latest revision as of 02:17, 4 November 2019

Enclosure - Elements of an AMP CC ISFSI - 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
ML14230A908
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/18/2014
From: Goshen J
NRC/NMSS/SFST
To:
Goshen J
Shared Package
ML14230A903 List:
References
TAC L24475
Download: ML14230A908 (12)
v • d • e


Text

Elements El t off an Aging Management Program Division of Spent Fuel Storage and Transportation Offi off Nuclear Office N l Material M t i l Safety S f t and d Safeguards S f d U.S. Nuclear Regulatory Commission Meeting to Discuss the Request for Additional Information Responses Regarding the Calvert Cliffs Independent Spend Fuel Storage Facility License Renewal July 17, 2014 1

Regulatory Basis 10 CFR 72.42(a), 72.240(c):

1. TLAAs that demonstrate that ITS SSCs will continue to perform their intended function for the period of extended operation.
2. A description of the AMP for management of issues associated with aging that could adversely affect ITS SSCs SSCs.

Guidance: NUREG-1927 AMP Elements:

1.

1 Scope of the Program 6.

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 For in-scope SSCs, detailed AMPs addressing the 10 elements l d to lead t efficient ffi i t staff t ff reviews i and d effective ff ti managementt off aging i effects 2

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 Identifies:

p components In-scope p and subcomponents p

Materials of construction Service environment Aging g g mechanisms for material/environment combination Aging effects associated with each aging mechanism 3

AMP Element 2:

Preventive Actions NUREG-1927: Preventive actions should mitigate or prevent the applicable aging effects Actions to minimize, control, or prevent the degradation mechanism, e.g. NRC-endorsed criteria (peak cladding temperatures below ISG-11, rev. 3 limit li it during d i drying),

d i ) consensus codesd and d standards, t d d etc.t 4

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 Identifies:

Parameters (e.g. cracking size monitoring, rate of material loss, temperature, neutron fluence, etc.)

Location(s) to be monitored or inspected (e.g. at highest heat location, neutron fluence at 1 m from cask)

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs parameters monitored/inspected (tiered approach) 5

AMP Element 4:

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

Method/technique (e.g. visual, volumetric, and/or surface inspections or surveys)

Frequency of inspection (e.g. inspection intervals)

Sample size (dependent on operational experience trending)

Calibration of equipment Data collection (clearinghouse for operational experience)

Timing (new or one-time inspections, time of year)

Learning/Proactive/Responsive L i /P ti /R i AMP:

AMP Operational experience and other quality data (tollgates)

Consensus codes and standards Informs I f methods/techniques th d /t h i ffor detecting d t ti aging i effects/mechanisms ff t / h i (tiered approach) 6

AMP Element 5:

Monitoring & Trending NUREG-1927: Should provide for prediction of the extent of the effects of aging and timely corrective or mitigative actions Trending of aging effects (e.g. corrosion rate, crack growth rate, etc.)

Assess effects per prior inspections and industry-wide operational experience i

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs monitoring and trending 7

AMP Element 6:

Acceptance Criteria NUREG-1927: Acceptance criteria, against which the need for corrective action will be evaluated; should ensure that SSC functions are maintained Criteria for inspections, assessing aging effects, and decision-making Establish technical basis for specific p acceptance p criteria Domestic and international consensus codes and standards whenever practicable, or previously justified and established criteria Separate criteria should be provided for each aging effect Alternative criteria may be used if justified:

Supporting technical basis (OpE and/or engineering analysis/standards)

Avoid non-quantifiable phrases (e.g. significant, moderate, minor, little, etc.)

Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs acceptance criteria 8

AMP Element 7:

Corrective Actions NUREG-1927: Corrective actions, including root cause determination and prevention of recurrence, recurrence should be timely CAP commensurate with 10CFR72 Subpart G, or 10CFR50 Appendix B Maintenance plans and/or corrective actions for specific degradation effects ff t ((e.g. repair, i replacement, l t mitigation iti ti activities, ti iti & extent t t off condition)

Actions to prevent reoccurrence Justification for actions such as repair repair, replace replace, and/or mitigate Analysis of how action may affect other subcomponents Consideration of corrective actions on other components Plans for OpE incorporation into the remediation plan Learning/Proactive/Responsive AMP:

Operational experience and other quality data (tollgates)

Informs corrective actions 9

AMP Element 8:

Confirmation Process NUREG-1927: The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been completed and are effective Element should reference:

Quality Assurance Program consistent with 10CFR72 Subpart G, or 10CFR50 Appendix B.

Methods to confirm adequate actions are taken, and are verified as effective ff ti 10

AMP Element 9:

Administrative Controls NUREG-1927: Administrative controls should provide a formal review and approval process Elements should reference:

Qualityy Assurance Program g consistent with 10CFR72 Subpart p G,, or 10CFR50 Appendix B.

Inspector requirements Record retention requirements Review process of inspection results Frequency/methods for:

reporting inspection results to NRC evaluating suitability of AMP based on industry-wide OpE (tollgates) 11

AMP Element 10:

Operating 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 Critical element to Learning/Proactive/Responsive AMP Reference and evaluate applicable Operational Experience:

Industry-wide Condition Reports, Corrective Action Reports, NRC Information Notices, Notices Applicable industry initiatives (e.g.

(e g DOE cask demo, EPRI-sponsored inspections) 12

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