BVY 17-001, Response to Request for Supplemental Information Related to Exemption

Response to Request for Supplemental Information Related to Exemption

ML17010A300
Person / Time
Site:	Vermont Yankee, Holtec
Issue date:	01/09/2017
From:	Chappell C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML17010A298	List: BVY 17-001, Response to Request for Supplemental Information Related to Exemption
References
BVY 17-001
Download: ML17010A300 (12)

Text

-;

Withhold from public disclosure under 10 CPR 2.390(a)(4)

~Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

Vernon, VT 05354 802-257-7711 Coley C. Chappell Manager, Design and Programs 10 CFR 72.7 BVY 17-001 January 9, 2017 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to Request for Supplemental Information Related to Exemption Request from certain requirements of 10 CFR 72.212 and 10 CFR 72.214 Vermont Yankee Nuclear Power Station License No. DPR-28 Docket Nos. 50-271, 72-59 and 72-1014

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Exemption Request from certain requirements of 10 CFR 72.212 and 10 CFR 72.214,"

BVY 16-030, dated November 9, 2016 (ML16319A102)

2. E-Mail to T.B. Silko/Entergy from Yen-Ju Chen/DSFM re: "Regarding Need for Supplemental Information for Entergy's Exemption Request for Vermont Yankee ISFSI," dated December 13, 2016(ML16349A249)

Dear Sir or Madam:

By letter dated November 9, 2016 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) submitted a request for exemption from certain requirements of 10 CFR 72.212 and 72.214 for Vermont Yankee Nuclear Power Station (Vermont Yankee). These regulations require, in part, compliance with the terms and conditions of the Holtec International (Holtec) Cask System Certificate of Compliance (CoC) for spent fuel storage at the Vermont Yankee independent spent fuel storage installation. Specifically, the requested exemption would allow for a modification to certain requirements in Appendix B, Table 2.1-3, Note 19 of Amendment 1Oto the Holtec Coe No. 72-1014, thus allowing certain low enriched channeled fuel classified as "undamaged" per the CoC to be loaded in the same Multi-purpose Canister (MPC) as higher enriched fuel.

During discussions with the NRC, a request for supplemental information (Reference 2) was determined to be needed regarding the estimated reduction in dose that would be realized by approval of Reference 1. The response to the Request for Supplemental Information is provided in Attachment 1. Referenced technical reports used to demonstrate the potential dose savings are provided in Attachments 2, 3 and 4. Attachment 5 to this letter is an affidavit [) D l prepared in accordance with 10 CFR 2.390 requesting that Attachments 2, 3 and 4 be withheld }

from public disclosure. Any questions regarding the withholding of proprietary information /V iv1 '.'> S l/p t-J [(_ (0 f\)M? S

BVY 17-001IPage2 of 2 should be addressed to: Holtec International, Ms. Kimberly Manzione, Licensing Manager, One Holtec Drive, Marlton, NJ 08053.

When separated from Attachments 2, 3 and 4, the cover letter and Attachments 1 and 5 are decontrolled.

This letter contains no new regulatory commitments. Should you have any questions conc_erning this letter, please contact me at {802) 451-3374.

Sincerely, (fo;tlyyU-CCC/tbs Attachments: 1. Response to Request for Supplemental Information Related to Exemption Request from certain requirements of 1o CFR 72.212 and 10 CFR 72.214

2. Holtec International Report No: Hl-2146076, Revision 1, "Dose versus Distance from HI-STORM 1OOS Containing MPC-68 and MPC-68M for Vermont Yankee ISFSI"

3. Holtec International Report No: Hl-2146423, Revision 2, "HI-STAR 190 Source Terms and Loading Patterns"

4. Selective Pages from Holtec International Report No: Hl-2167202, Revision 0, "Fuel Compatibility and Loading Plan Report for Vermont Yankee"

5. Holtec International Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555 Ms. Yen-Ju Chen; Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-48-34 Washington, DC 20555 Ms. June Tierney, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601 I __

BVY 17-001 Docket Nos. 50-271, 72-59 and 72-1014 Attachment 1 Vermont Yankee Nuclear Power Station Response to Request for Supplemental Information Related to Exemption Request from certain requirements of 10 CFR 72.212 and 10 CFR 72.214

BVY 17-001IAttachment1IPage1 of 3 REQUEST FOR SUPPLEMENTAL INFORMATION RELATED TO EXEMPTION REQUEST FROM CERTAIN REQUIREMENTS OF 10CFR72212AND10CFR72214 FOR VERMONT YANKEE NUCLEAR POWER STATION Supplemental Information Requested:-

Request:

Please provide the technical justification behind the statement "the requested exemption would result in an estimated reduction in dose rates by a factor of two, and an approximate total reduction in operator dose by one half."

Response

An analysis was conducted for Vermont Yankee (VY) by Holtec International to document why the exemption request is justified from a shielding perspective, and to estimate the resulting reduction in dose rates. The methodology involved calculating cask side dose rates from a single cask while adjusting the parameters of the fuel loaded based upon the available fuel at VY. Assumptions included the following:

• Casks #14 and #44 provided in Table 7.2 of Holtec International Report No: Hl-2167202 (Attachment 4) are used in this comparison. These casks are representative of the loading plan.

• The burnup, enrichment and cooling time of the fuel assemblies used to calculate dose rates are averaged values from all assemblies in the respective cask regions.

• To simplify calculations, the burnup is rounded up with 5 GWD/MTU step, the enrichment is rounded down to one decimal place and cooling times are rounded down to whole years.

The VY Spent Fuel Pool contains a large number of potential Crud Induced Localized Corrosion (CILC) fuel - approximately 40% out of all assemblies. The average cooling time of the CILC assemblies is approximately 35 years and the average burnup is approximately 25 GWD/MTU.

The remaining fuel has higher burnups (average burnup of approximately 35 GWD/MTU) and shorter cooling times (with an average of approximately 15 years), and higher initial enrichment (about 80% of the remaining fuel assemblies have an initial enrichment of 3.3 wt% or more).

Since the CILC fuel assemblies are typically low burned and long cooled it is preferable to mix them with higher enriched and higher burned fuel in the same cask in order to reduce dose rates emanating from the cask, by self-shielding of low source term assemblies placed on the periphery of the basket.

As a result of applying Coe Amendment 10, Note 19 without the requested exemption, the VY loading plans would effectively contain two sets of casks:

Set 1) 40% of casks containing only low source term CILC fuel; and Set 2) 60% casks containing higher source terms assemblies.

The relatively low burned and long cooled assemblies are ideal candidates to be used as a shielding barrier fuel on the periphery of the MPC basket, blocking the radiation from shorter cooled and higher burned fuel typically stored towards the center of the basket. However, the

BVY 17-001/Attachment1/Page2 of 3 higher burned fuel has higher enrichments, and with the current restriction cannot be mixed with the low source term CILC affected fuel.

In contrast, the requested exemption would allow for a more efficient fuel loading plan to be constructed where the assemblies with higher source terms can be mixed with low source term fuel assemblies. To estimate the dose rate reduction factor, the dose rates were calculated for proposed Casks #14 and #44 with the Note 19 restriction and with the Note 19 restriction as revised by the exemption request. Cask #14 belongs to casks in Set 1, as discussed above, and contains solely Undamaged Fuel Assemblies, limited to 3.3 wt% U-235 and affected by CILC. Cask #44 belongs to casks in Set 2 and is a representative cask containing higher source terms assemblies. Table 1 below summarizes the fuel loading for Casks #14 and #44.

After the proposed exemption request, fuel from Cask #14 and Cask #44 can be mixed. As an example, fuel from the inner region of Cask #14 is swapped with fuel from the outer region of Cask#44.

Table 1: Fuel Parameters Used in the Calculations Inner Region , Outer region Cask Burnup/Enrichment/Cooling Time Burnup/Enrichment/Cooling Time (GWD/MTU I wt% I vears) (GWD/MTU I wt% I vears)

Cask #14 (see Attachment 4) 30 I 2.8 I 28 20 I 2.6 I 39 Cask #44 (see Attachment 4) 45 I 3.8 I 7 45/3.6/14 Cask #14 after mixing of fuel 45I3.6I14 20 I 2.6 I 39 Cask #44 after mixing of fuel 45 I 3.8 I 7 30 I 2.8 I 28 Methodology for Calculation:

In order to demonstrate the dose reduction provided by the requested exemption, a comparative analysis was performed between Vermont Yankee's loading to the existing Amendment 1O (which includes the CILC fuel restriction) and loading with the restriction removed as requested in the exemption. This comparative analysis utilized the dose vs.

distance methodology described in Hl-2146076, Rev 1 (Attachment 2 to this letter). Note that the actual calculations in Hl-2146076 were performed utilizing an older loading configuration that is no longer in place, however the calculation provides the methodology used in the current comparative analysis. Specifically, Hl-2146076 documents a general methodology of how the dose analysis is separated into two distinct parts. The first part is the generation of the radiation source terms to represent the spent nuclear fuel at the appropriate burnup and cooling time. The second part is the radiation transport simulation to calculate the dose rates at various distances from a cask.

The radiation source terms were calculated using the methodology discussed in Hl-2146423, Rev 2 (Attachment 3 to this letter). Specifically, it utilizes the SAS2H and ORIGEN-S modules (references 1and2 from the Hl-2146423 document) from the SCALE 5.1 code system from Oak Ridge National Laboratory. This is a widely accepted means of generating radiation source terms from spent nuclear fuel. Note that this SCALE code system is a more recent version than the one discussed within Hl-2146076.

The radiation transport simulation is performed with MCNP 4A (reference 6 from the Hl-2146076 document) from Los Alamos National Laboratory. This is a state of the art Monte

BVY 17-001 I Attachment 1 I Page 3 of 3 Carlo code that offers coupled neutron-gamma transport using continuous energy cross sections in a full three-dimensional geometry.

Results of Calculation The comparison of dose rates at distance from the HI-STORM 100 is shown in Table 2 below.

The comparison shows that the dose rates from Cask #44 are reduced by approximately a factor of 2. While the dose rate of cask #14 would see an increase, a net reduction can be observed on the sum of dose rates from the two casks. These casks are considered representative of casks loaded across the whole campaign, and therefore a similar reduction in sum total dose across the campaign is expected. Note that this case is only an illustration of typical dose rate reduction, and further optimization may be performed forthe entire loading plan with the revised Coe.

Table 2: Side Dose Rates at Approximately 100 m from the HI-STORM 100 Cask Dose Rate Cask

'(mrem/hr)

Cask #14 (see Attachment 4) 1.0?E-04 Cask #44 (see Attachment 4) 2.06E-03 Cask #14 after mixing of the fuel 3.62E-04 Cask #44 after mixing of the fuel 8.07E-04

BVY 17-001 Docket Nos. 50-271, 72-59 and 72-1014 Attachment 5 Vermont Yankee Nuclear Power Station Holtec International Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

AFFIDAVIT PURSUANT TO 10 CFR2~390 I, Kimberly Manzione, being *duly sworn, depose and state as follows:

(1) I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is Attachment 2, 3, and 4;, which are Holtec Report Numbers HI-2146076Rl, HI-2167202RO, and HI-2146423R2 which contain Holtec Proprietary information.

(3) In making this application for withholding of proprietary information ofwhich it is the owner, Holtec International relies upon the exemption from disclosure set forthinthe Freedom of Information Act ("FOIA"), 5 USC Se_c. 552(b)(4)and the Trade Secrets Act, 18 USC Sec. --1905, and NRC regulations 10CFR Part 9.17(a)(4), 2390(a)(4), and 2390(b)(l) for "trade secrets and commercial ot financial information obtained from a person.and privileged or confidential"

• (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information, and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical: Mass:

.EnergyPro.iectv. Nuclear Regulatory Conimission,.975F2d871 (De Cir. 1992),

and Public'c!t!Zen 1983).. - -

Heaith Research Group v .. FDA, 704F2d1280 (DC Cit\

- - .. . .. -- --- - .. . . **~"

1 of5

AFFIDAVIT PU)lSUANT TO 10 CFR 2.390 (4) Some examples of categorie~ of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including

• supporting data ruid analyses, where prevention of its use by Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar* product.

c., Information which reveals cost or price information, production,*

capacities, budget levels, or commercial strategies C)fHoltec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International customer~funded development plans and programs. of potential commercial value to Holtec International;

• e.. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a and 4.b above.

(5) The information sought to be withheld is being submitted to the NRC in

• confidence~ The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, andis in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in ~onfidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have 2of5

AFFIDAVIT PURSUANT TO 10 CFR 2.390 been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to preyent its unauthorized disclosure, are as set forth in paragraphs (6} and (7) following. *

( 6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the inforniation. irt relation to industry knowledge.

Access to such documents within Holtec International is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a docwnent typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing :function (or his designee), and by the Legal Operation, for technfoal content, competitive effect, and determination of the accuracy of the proprietary designation; Disclosures outside Hohec International are limited to regulatory bodies, cµstorilers, 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 agreements.

(8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to*Holtec International. This information* is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to oopy our technology and offer it for sale in competition with our. 9ompany, causing us financial injury.

3 of5

AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage 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. ,

• The research, development, engineering, .and analytical costs comprise a substantial investment of time and money. by Holtec International.

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.

Holte.c Intemational's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or ifthey 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 Holtec International 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 expenditur.e of resources would unfairly provide competitors with a windfall, and deprive Holtec International ofthe opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developingthese very valuable analytical tools.

4of5

AFFIDAVIT PURSUANT TO 10 .CFR 2.390 STATEOFNEWJERSEY )

) SS*:

COUNTY OF BURLINGTON )

Mrs. Kimb¢rly Manzione, being duly swom, deposes and says:

That .*she has .read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.

Executed atMarlton, New Jersey, this 21st day of December, 2016.

1. 4t1"/¥J;,:- "'-'4 1~,

/Z" -~,--

Kimberly Manzione Holtec International

.L ,~

Subscribed and sworri before me this JI~ day ofJ\~~' 2016.

Erika Gr~ndrimo NOTARY PUBLIC STATE OF NEW JERSEY

\fY C0'.\1MISSION EXPIRES January 17. 20i2

--~ -*-- *-* _,_ ~- ' - - ~~. .* **'-

S .~-.-

Sof5