CY-97-066, Provides Results of Assessment Re Beyond Design Basis Event of Loss of All Water in Spent Fuel Pool.Proprietary Calculations Rev 4 to HI-971705 & Rev 3 to HI-97175,encl. Proprietary Calculations Withheld
| ML20211H694 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/26/1997 |
| From: | Feigenbaum T CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20046D842 | List: |
| References | |
| CY-97-066, CY-97-66, NUDOCS 9710070081 | |
| Download: ML20211H694 (8) | |
Text
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C CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM F3CK PLANT 362 INJUN Hollow ROAD e EAST HAMPToN, CT 064;
- V J9 September 26,1997 Docket No. 50-213 CY-97-066 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
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Haddam Neck Plant Assessment Of The Beyond Design Basis Event Loss Of All Water in The Soent Fuel Pool l
1 The purpose of this letter is for Connecticut Yankee Atomic Power Company (CYAPCO) to provide the results of an assessment of the Haddam Neck Plant (HNP)
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with respect to the beyond design basis event of a loss of all water in the spent fuel l
l pool.
In a letter dated December 5,1996,W CYAPCO informed the NRC that the Board of Directors of CYAPCO had decided to permanently cease operations at the HNP and that the fuel had been permanently removed from the reactor.
The plant was shutdown on July 22,1996 and in a letter dated May 30,1997,<2)
CYAPCO etc;osed a calculation that provided the decay heat curves for the HNP spent fuel. In additio-1, CYAPCO decided to determine the potential off-site consequences if there was a total loss of water from the spent fuel pool. The enclosed proprietary calculations (Attachments 2 and 3), which are being provided to the NRC for information only, address this issue.
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(1)
T. C. Feigenbaum letter to the U. S. Nuclear Regulatory Commission,
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" Certifications Of Permanent Cessation Of Power Operation And That Fuel Has A[O r 6 C 0 [ O E!een Permanently Removed From The Reactor," dated December 5,1996.
(2)
T. C. Feigenbaum letter to the U. S. Nuclear Regulatory Commission, ~ Proposed Revision To Operating License And Technical Specifications Defueled Operating
,,J.jcense And Technical Spegcations," dated May 30,1997 9710070091 9Y Nb V
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U. S. Nucle:r Regul tory Commission CY-97-066/P ga 2 4
10CFR2.790 Provided as Attachment 1 is an " Affidavit Pursuant To 10CFR2.790." The developer of
- the enclosed calculations (Attachments 2 and 3), Holtec International; considers these calculations proprietary, and therefore requests that-they be exempt from public disclosure pursuant to 10CFR2.790(a)(4),10CFR2.790(b)(1), and 10CFR9.17(a)(4). is Holtec International's application for withholding from public disclosure and the affidavit of Dr. Indresh Rampall (Principal Engineer - Holtec International) as required by 10CFR2.790(b)(1).
Accordingly, CYAPCO respectfully requests that Attachments 2 and 3, which are proprietary to Holtec International, be withheld from
-public disclosure in accordance with 10CFR2.790 of the Nuclear Regulatory Commission's regulations.
t DISCUSSlQN L Presently there are 1019 spent fuel assemblies in the HNP spent fuel pool.- Of these, 858 fuel assemblies are stainless steel-clad and 161 fuel assemblies are zircaloy clad.
If this beyond design basis event of a loss of spent fuel pool water is postulated, the following conditions would occur:
Depending on the " fuel assembly age" (i.e., time since irradiated) and placement of each fuel assembly with respect to other fuel assemblies, an individual fuel assembly could heat up several j
hundred degrees before reaching an equilibrium temperature.
The zircaloy-clad fuel assemblies would retain their integrity as long as the clad temperature did not exceed 650 C.
If any zircaloy-clad fuel assembly exceeds 650 C, there is the possibility of an exothermic chemical reaction causing a rapid oxidation of the zircaloy clad (i.e., a zircaloy fire).
The enclosed calculation (Attachment 2), which used an optimum fuel storage arrangement, looked at two scenarios. The first case assumed a loss of all water in the
. pool. The second case, which was the more limiting scenario, assumed that some water remained in the pool. This water level was below the fuel assemblies, but high enough to block the lower channels in the racks. With such a configuration, cooling due to air convection is reduced. However, the calculation indicates that with the spent fuel
. in the optimum storage configuration and with the limiting scenario of water remaining in the spent fuel pool, that the 650 C temperature will not be exceeded after 4-i October 1,1997.
Currerilly, the fuel is not in the arrangement discussed in the analysis. CYAPCO intends to rearrange the fuel into a configuration consistent with the analysis.
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U. S. Nuclear R:gubtory Commission -
CY-97-066/Page 3
- The sccond enclosed-calculation (Attachment 3), performed the same analysis but used a maximum clad temperature of 565*C. These results indicate that, with the spent fuel in the optimum storage configuration and with the limiting scenario of water remaining in the spent fuel pool, a temperature of 569'C will not be exceeded after January 1,1998 and a temperature -of 553*C will not be exceeded after February 1,1998 (Attachment 3, Table 8.1). These results are consistent with recent studies performed by Brookhaven National Laboratory as discussed in SECY-96-256.*
CONCLU210N Therefore, once the fuel is stored in a configuration consistent with the analysis, there are no significant off-site consequerices to a postulated beyond design basis event of a loss of all spent fuel pool water, after October 1,1997.
If the NRC should have any questions, please contact Mr. G. P. van Noordennen at (860) 267-3938.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY t
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T. C. FeigerAstfn Executive Vice President and Chief Nuclear Officer Attachments cc:
H. J. Miller, NRC Region i Administrator M. B. Fairtile, NRC Senior Project Manager, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant D. Galloway, Acting Director, CT DEP Monitoring and Radiation Division (3)
SECY-96-256, " Changes To The Financial Protection Requirements For Permanently Shutdown Nuclear Power Reactors, 10CFR50.54(w) And 10CFR140.11," dated December 17,1996.
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Docket Nos. 50-213 CY-97-063 i
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Haddam Neck Plant Assessment Of The Beyond Design Basis Event Loss Of All Water in The Spent Fuel Pool Affidavit Pursuant To 10CFR2,790 l
l September 1997
AFFIDAVIT PURSUANT TO 10CFR2.790 1, Indresh Rampall, being duly sworn, depose and state as follows:
(1)
I am Principal Engineer, Holtec International, and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2)
The information sought to be withheld is contained in the documents entitled " Dry Condition Thermal Analysis of CY Pool for a 565 Degrees Centigrade Clad Temperature Limit" (Holtec Report HI-971745), and " Thermal Analysis of the Haddam Neck Fuel Pool Under Loss of Water Investory Scenarios" (Holtec Report HI-971705).
(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 of Information Act ("FOIA"),5 USC Sec. 552(b)(4) and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10CFR Part 9.17(a)(4),
2.790(a)(4), and 2.790(b)(1) 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 of FOIA Exemption 4 in, respectively, Critical Mass Enercy Proiect v.
Nuclear Reculatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun v. FDA,704F2dl280 (DC Cir.1983).
(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.
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- AFFIDAVIT PURSUANT TO 10CFR2.790 4 -
c.
Info _miation which reveals cost or price information, production, capacities,-
budget levels,- or. commercial strategies of Holtec - International, its j
customers, or itt suppliers; b
- d.
Information which reveals aspects of-past, present,L 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.
i The infonnation v"ght to be withheld is considered to be proprietary for the:
reasons set forth in gragraphs 4.a,4.b,4.d, and 4.e, above.
(5)
The information sought to be wisheld 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, Econsistently been held in confidence by Holtec International. No public disclosure
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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 regulatory provisions or proprietary agreements which provide -
l for maintenance-of the information in confidence.- Its initial: designation as proprietary information, and the subsequent steps taken to prevent its unauthorized l
disclosure, are as set forth in paragraphs (6) and (7) following.
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-(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 1:
such documents within Holtec International is limited on a "need to know" basis.
f(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 cogr.irant marketing function (or his designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside l
Holtec International are limited to regulatory bodies, customers, and potential 2
AFFIDAVIT PURSUANT TO 10CFR2.790 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 classined 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 historical data and analytical-results not available elsewhere. This information would provide other parties, including competitors, with infonnation from Holtec International's technical database and the results of evaluations performed using codes developed by Holtec International. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A substantial effort has been expended by Holtec International to develop this information.
(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 thne and money by Holtec International.
4 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 if its 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.
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l AFFIDAVIT PURSUANT TO 10CFR2.790 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 International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools, STATE OF NEW JERSEY
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COUNTY OF BURLINGTON
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Dr. Indresh Rampall, being duly sworn, deposes and says:
hat he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at Marlton, New Jersey, this 1Ith day of September,1997 1 sat 1
' " Dr. indresh Rampall Holtec International Subscribed and sworn before me this day of G - / C,1997.
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