BVY 18-042, Thermal Validation Test of HI-STORM 100 Cask System
| ML18346A390 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee, Holtec  |
| Issue date: | 11/29/2018 |
| From: | Daniels C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18346A398 | List: |
| References | |
| BVY 18-042 | |
| Download: ML18346A390 (10) | |
Text
Withhold from public disclosure under 10 CFR 2.390(a)(4)
Entergy Nuclear Operations, lnc.
Vermont Yan.~ee 320 Governor Hunt Rd.
Vernon, \ff 05354
~Ent ergy 802-257-7711 Corey R. Daniels Director, Nuclear Decommissioning 10 CFR 72.4 BVY 18-042 November 29, 2018 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear, Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Thermal Validation Test of HI-STORM 100 Cask System Vermont Yankee Nuclear Power Station Docket Nos. 50-271, 72-59 and 72-1014 License No. DPR-28
REFERENCE:
Letter, USNRC to Holtec International, "Certificate of Compliance No. 1014, Amendment No. 10 for the HI-STORM 100 Cask System (CAC No. L24979),"
dated May 25, 2016 (ML16144A177)
Dear Sir or Madam:
In accordance with the Certificate of Compliance (CoC) No. 1014, Amendment No. 10 for the HI-STORM 100 Cask System (Reference), Entergy Nuclear Operations, Inc. (ENO), as required by Condition 9 of the CoC, hereby submits the results of a thermal validation test conducted at the Vermont Yankee Nuclear Power Station (VY).
Specifically, Condition 9(a) of the referenced CoC requires the submittal of a report to the NRC summarizing the results of the thermal validation test and analysis. Specifically the CoC states:
For the storage configuration, each user of a HI-STORM 100 Cask and HI-STORM 1OOU Cask with a heat load equal to or greater than 20 kW shall perform a thermal validation test in which the user measures the total air mass flow rate through the cask system using direct measurements of air velocity in the inlet vents. The user shall then perform an analysis of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR. The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4 within 180 days of the user's loading of the first cask with a heat load equal to or greater than 20 kW. To satisfy condition 9(~)for casks of the same system type (i.e., HI-STORM 100 casks, HI-STORM 1OOU casks), i~;'li~u of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed
/()N .5 5 2D
- JH55Z /p
- (t-fL-tJJtl6S
Withhold from public disclosure under 10 CFR 2.390(a)(4)
BVY 18-042 / Page 2 of 3 test and analysis submitted by letter report to the NRG that demonstra tes validation of the analytic methods described in Chapter 4 of the FSAR.
A cask system meeting the decay heat threshofd of this CoC condition was loaded at VY on June 18, 2018. This cask system is comprised of Multi-Purpose Canister (MPC) serial number MPC-68M- 568 and HI-STORM 100S Version 8 overpack serial number 1026. Decay heat calculations indicate a total decay heat at the time of loading of 20.3 kW. The thermal validation test was conducted on June 25, 2018.
Attachmen t 1 to this letter is an affidavit prepared in accordance with 10 CFR 2.390 requesting that the proprietary reports provided in Attachmen ts 2 and 3 be withheld from public disclosure.
Any questions regarding the withholding of proprietary information should be addressed to:
Holtec International, Ms. Kimberly Manzione, Licensing Manager, One Holtec Drive, Camden, NJ 08104. The affidavit also includes an authorization for ENO to provide to the NRC the proprietary information.
Attachmen t 2 contains a proprietary Thermal Test report which describes the test process and provides the data collected during the test of the HI-STORM 100 System. Attachment 3 contains a proprietary Thermal Validation Analysis report which documents the evaluations and the results of the analytic models used to predict the total air flow through the cask system. The results indicate that the highest calculated air mass flow rate is lower than the lowest measured mass flow rate from the actual loaded cask. These test and analysis results satisfy the Condition 9(a) requiremen ts specified in the Coe.
When separated from Attachmen ts 2 and 3, this cover letter and Attachmen t 1 are decontrolle d.
This letter contains no new regulatory commitments.
Should you have any questions concerning this letter, or require additional information, please contact me at (802) 451-3196 or Suzanne Leblang at (601) 368-5494.
Sincerely, CRD/tbs Attachments:
- 1. Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure
- 2. Thermal Test of HI-STORM 100 System (Proprietary)
- 3. Thermal Validation Analysis of HI-STORM 100 System (Proprietar y)
Withhold from public disclosure under 10 CFR 2.390(a)(4)
BVY 18-042 / Page 3 of 3 cc: Mr. David C. Lew 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-5A 10 Washington, DC 20555 Ms. June Tierney, Commissioner (w/o Attachments 2 & 3)
Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601
BVY 18-042 Docket Nos. 50-271 and 72-59 Attachment 1 Vermont Yankee Nuclear Power Station Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure
U.S. Nuclear Regulatory Commission Affidavit for Vennont Yankee BVY 18-042 Holtec International Proprietary Infonnation 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 provided in IB-2188213Rl and HI-2188214Rl, which contain Holtec Proprietary Information.
(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies upon the exemption from disclosure set forth in the Freedom oflnfo1U1ation Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, andNRC regulations 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial or 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 ofFOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research
- Group v. FDA, 704F2dl280 (DC Cir. 1983).
- 1 of5
U.S. Nuclear Regulatory Commission Affidavit for Vermont Yankee BVY 18-042 Holtec International Proprietary Infonnation Aii"'FIDAVIT PURSUANT TO 10 CFR 2.390 (4) Some examples of categories of information which 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 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 of Holtec 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. Infonnation 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, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence 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 been made, or must be made, pursuant to 2 of5
U.S. Nuclear Regulatory Commission Affidavit fur Vennont Yankee BVY 18-042 Holtec rnternational Proprietary Infonnation AFFIDAVIT PURSUANT TO 10 CFR 2...190 regulatory provisions or proprietary agreements which provide for maintenance of the infonnation in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent 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 information in 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 document 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 technical content, competitive effect, and determination of the accuracy of the proprietary d~signation. Disclosures outside Holtec International 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 agreements.
(8) The information classified as proprietary was developed and compiled by Holtec Intemationa] 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 Intemational'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 HoJtec' s competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.
3 of5
U.S. Nuclear Regulatory Commission Affidavit for Verni.ant Yankee BVY 18-042 Holtec Inter.national Proprietary Infum1ation AFFIDAVIT PURSUANT TO 10 CJ'R 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 Intemational'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.
Holtec International's competitive advantage will be lost ifits competitors are able to use the results of the Holtec International 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 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 expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec Intemational of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
4of5
U.S. Nuclear Regulatory Commission Affidavit for Vermont Yankee BVY 18-042 Holtec Intm-national Proprietary Informat.fon AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )
) ss:
COUNTY OF CAMDEN )
Kimberly Manzione, being duly sworn, 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 at Camden, New Jersey, this 27th day ofNovem ber 2018.
~
Kimberly Manzione Licensing Manager Holtec International Subscribed and sworn before me this 27th day of Erika Grandrimo NOTARY PUBUC STATE OF NEW JERSEY MY COMMISSION EXPIRES January 17, 2022 5 of5
nnnno LJtlJLSJLfj *. . * .8-?_~t~~ Te?hnology_~m_pus, 1 H?lt~-~~~:.*.9~-~~~~!-~J.-~~-10~
Telephone (856} 797-0900 HOLTEC
!NT[RNAflC>NAL Fax {856} 797-0909 November 14, 20 t8 Document ID: 2569020 Ms. Suzanne LeBlang Dry Fuel Storage Manager 1340 Echelon Parkway M-ECH-36 P.O. Box 31995 Jackson, MS 39211 Attention: Suzanne LeBlang Email: slebla2@entergy.com
Subject:
Release of HI-STORM Thermal Test Reports to the NRC
Dear Ms. LeBlang:
Holtec is pleased to approve the release of the following information to the United States Nuclear Regulatory Commission (USNRC):
- l. Holtec Report HI-2188213, "Thermal Test of HI-STORM 100 System"
- 2. Holtec Report HI-2188214, Thermal Validation Analysis of HI-STORM 100 System" We require that you include this letter along with the affidavit pursuant to 10CFR2.390 when submitting to the USNRC.
Please do not hesitate to contact me at 856-797-0900 x 3739 if you have any questions.
Respectfully,
- JJCli- #f '19 Mathew McKnight Senior Project Manager Holtec International Krishna P. Singh Technology Campus 1 Holtec Boulevard, Camden, NJ 08104 Office
- 856-797-0900 Ext 3739 Cell: 302-290-9383 m.mcknight@ho!tee.com Document ID: 2569020