HNP-08-018, Request for License Amendment to Appendix a, Technical Specification 5.6.3.d

Request for License Amendment to Appendix a, Technical Specification 5.6.3.d

ML081010208
Person / Time
Site:	Harris
Issue date:	04/03/2008
From:	Duncan R Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-018
Download: ML081010208 (31)

Text

Robert J. Duncan. 11 Progress Energy ViceRer

.Presidentuna.,

Harris Nuclear Plant Progress Energy Carolinas, Inc.

Serial: HNP-08-018 APR 0 3 2008 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATION 5.6.3.d Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, "Application for Amendment of License or Construction Permit," Carolina Power & Light Company (CP&L) doing business as Progress Energy Carolinas, Inc. (PEC), requests an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-63 for Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP).

HNP requests approval of Metamic as an alternate poison for future spent fuel racks to be installed in C and D Spent Fuel Pools (SFP). The neutron poisonmaterial Boral, previously approved in License Amendment No. 103 for use in SFP C and D assembly racks, is currently not available. This proposed change would allow the use of Metamic, which has been approved in multiple industry applications, as an alternative for Boral.

The new spent fuel racks will be needed in SFP C during HNP's Refueling Outage 15 (RFO-15) to support fuel movement.

This proposed change also revises TS 5.6.3.b to reflect a substitution of a limited number of previously approved Boiling Water Reactor (BWR) fuel assembly racks in SFP C with Pressurized Water Reactor (PWR) fuel assembly racks. Supporting analysis verifies that this proposed change is bounded by previously approved spent fuel pool loading configurations.

This request is presented as follows:

1. provides the description, proposed change, background, and technical analysis for the proposed amendment.

2. details, in accordance with 10 CFR 50.92(c), the basis for HNP's determination that the proposed change does not involve a Significant Hazard.

3. provides a statement of Environmental Impact Consideration.

4. contains the affected TS page marked-up to show the proposed change.

5. is the retyped TS page.

P.O.

Box 165 New Hill, NC 27562 T> 919.362.2502 F> 919.362.2095 f

HNP-w08-018 Page 2

6. is the affidavit supporting the request for withholding the proprietary information in Attachment 7 from public disclosure.

7. provides the proprietary version of the report documenting evaluation of the change in rack neutron absorber material.

In accordance with 10 CFR 50.91(b), HNP is providing the State of North Carolina with a copy of the proposed license amendment.

HNP requests approval of this Amendment by December 31, 2008, to support the next refueling outage (RFO-15) scheduled for April 2009, with implementation to occur within 60 days of approval.

This document contains no new Regulatory Commitment.

Please refer any question regarding this submittal to Mr. Dave Corlett at (919) 362-3137.

I declare, under penalty of perjury, that the attached information is true and correct (Executed on APR 0 3 2008

'R. J. D'-ican II Vice President Harris Nuclear Plant RJD/kms Attachments:

1.

2.

3.

4.

5.

6.:

7.

Description, Background, and Technical Analysis 10 CFR 50.92 No Significant Hazards Evaluation Environmental Impact Considerations Proposed Technical Specification (TS) Changes Revised Technical Specification (TS) Page Affidavit for Withholding of Proprietary Information Holtec International Report No. HI-2073849 (Proprietary) c:

Mr. P. B. O'Bryan, NRC Sr. Resident Inspector Ms. B. 0. Hall, N.C. DENR Section Chief Mr. V. M. McCree, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. I

'DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES Request for License Amendment for Technical Specification 5.6.3.b

3.0 BACKGROUND

3.1 HNP Spent Fuel Pools 3.2 Pool Rack Configuration 3.3 Metamic

4.0 TECHNICAL ANALYSIS

4.1 SFP Design 4.2 Configuration 4.3 Metamic 4.4 Criticality

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 Determination of No Significant Hazards Consideration (10 CFR 50.92) 5.4 Conclusion

7.0 REFERENCES

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Attachment Ito SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES

1.0 DESCRIPTION

This evaluation supports a request from Carolina Power & Light Company (CP&L),

doing business as Progress Energy Carolinas, Inc. (PEC), to amend Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP). The proposed change revises TS Section 5.6.3.b to allow a reconfiguration of the racks in Spent Fuel Pool (SFP) C and requests the approval of Metamic as an alternate neutron poison material in the new storage racks for SFP C and D. This proposed revision is needed to support HNP Refueling Outage 15 (RFO-15), scheduled for April, 2009.

The proposed amendment will: 1) revise the rack configuration in SFP C to allow the substitution of four previously approved (13 x 13 cell) Boiling Water Reactor (BWR) racks with an equal number of (9 x 9 cell) Pressurized Water Reactor (PWR) racks and

2) authorize the use of Metamic as an alternate spent fuel rack poison material.

Amendment 103 (Reference 1), issued December 21, 2000, approved the use of Boral, a boron carbide and aluminum composite sandwich, as the neutron absorber material for the new storage racks to be placed in SFPs C and D. This Amendment also licensed SFP C to contain two (11 x 9 cell) and nine (9 x 9 cell) PWR storage racks, for storage-of.a total of 927 PWR assemblies, in addition to two (8 x 13 cell), two (8 x 11 cell), six,(.1 3 x 11 cell) and nine (13 x 13 cell) BWR storage racks, for a storage of a total of 2763 BWR assemblies.

2.0 PROPOSED CHANGE

Specifically, the proposed change makes the following revision to HNP's TS 5.6.3.b:

The storage capacity of PWR assemblies would be revised to "1251" assemblies (instead of "927") and the storage capacity of BWR assemblies revised to "2087" assemblies (instead of "2763"). Additionally, the number of (9 X 9 cell) PWR racks would be revised to "thirteen" (instead of "nine") and the number of (13 X 13 cell) BWR racks revised to "five" (instead of "nine").

Incorporating the above changes, TS 5.6.3.b would then reflect:

Page A1-2 of 15

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES "Pool "C" is designed to contain a combination of PWR and BWR assemblies. Pool "C" can contain two (11 x 9 cell) and thirteen (9 X 9 cell)

PWR racks for storage of 1251 PWR assemblies. Pool "C" can contain two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell), and five (13 x 13 cell) BWR racks for storage of 2087 BWR assemblies. The (9 x 9 cell)

PWR racks and the (13 x 13 cell) BWR racks are dimensioned to allow interchangeability between PWR or BWR storage rack styles as required.

The racks in pool "C" will be installed as needed."

In summary, CP&L, doing business as PEC, proposes to modify HNP's TS to support reconfiguration of SFP C to allow substitution of an equal number (four) of previously approved BWR storage racks with dimensionally equivalent PWR storage racks. In addition, authorization is requested for the use of Metamic as an alternate neutron absorber in the spent fuel racks.

3.0 BACKGROUND

3.1 HNP Spent Fuel Pools HNP is designed with four SFPs, divided into two complexes. The pools are identified as follows:

" New Fuel Pool Unit 1 (Pool A), current licensed capacity 723 cells Spent Fuel Pool Unit 1 (Pool B), current licensed capacity 2946 cells Spent Fuel Pool Unit 2 (Pool C), current licensed capacity 3690 cells Spent Fuel Pool Unit 2 (Pool D), current licensed capacity 1025 cells Two pools, A and B, are located in the south end of the Fuel Handling Building (FHB).

Pools C and D (SFP C/D or north pool complex) are located on the north end of the FHB.

Spent fuel storage is provided by the New Fuel Storage Pool (Pool A) and the three spent fuel pools commonly referred to as Pool B, C, and D. The pools contain a combination of PWR and BWR fuel storage racks. During refueling, spent fuel recently discharged from HNP is stored in pool A/B. A system of transfer canals connects the four pools and a Cask Loading Pool.

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Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES OFUNIT 4

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- !U!4TIIE1RS 3.2 Pool Rack Configuration In order to accommodate the spent fuel shipping program permitted by HNP's Operating License, CP&L requested approval for activation of SFPs C and D (Serial: HNP-98-188),

dated December 23, 1998. This activation was approved via License Amendment 103, dated December 21, 2000.

Page A1-4 of 15 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES Current TS 5.6.3.b permits storage in SFP C of 927 PWR assemblies, in two (11 x 9 cell) and nine (9 x 9 cell) PWR storage racks, and the storage of 2763 BWR assemblies, in two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell) and nine (13 x 13 cell) BWR storage racks, as authorized by Amendment 103.

In accordance with Amendment 103, the racks in SFP C and D may be installed on an "as needed" basis. Since its approval for activation, both BWR and PWR fuel racks have been installed in SFP C. The (9 X 9 cell) PWR racks and the (13 X 13 cell) BWR racks have also been evaluated and approved for dimensional interchangeability "as required" (Reference 1).

Presently there are five (13 x 13 cell) BWR racks installed in SFP C, with approval to increase this number of (13 x 13 cell) BWR racks to nine. The BWR racks are used for storage of spent fuel assemblies from Brunswick Nuclear Plant (BNP), as authorized by HNP's Operating License. However, the shipping of these BWR assemblies from BNP has concluded. The five currently installed (13 x 13 cell) BWR racks contain adequate capacity to store the remainder of the BWR fuel which has been shipped from BNP for storage in SFP C. Therefore, the installation of the remaining four (13 x 13 cell).BWR storage racks, as previously approved in License Amendment 103, is no longer needed.

In this current request, CP&L, doing business as PEC, seeks to revise the SFP C'rack configuration to eliminate four of the previously approved (13 x 13 cell) BWR racks and install four additional (9 x 9 cell) PWR racks. This change will result in a net decrease, from 3690 to 3338, in the licensed amount of assemblies that can be stored in SFP C.

3.3 Metamic This license amendment also requests the optional use of Metamic as the spent fuel rack poison material. Boral, the material used as poison material in the existing storage racks, is not currently available for use in new rack construction. It has been determined that the metal-matrix composite Metamic, manufactured by Metamic LLC of Lakeland, Florida, is a suitable substitute for the unavailable Boral and will provide the necessary criticality control.

License Amendment No. 103, which approved the addition of rack modules to spent fuel pools C and D and the placement of the pools in service, specified "[t]he only non-stainless material is the neutron absorber material, which is a boron carbide and aluminum composite sandwich commonly called Boral." With Boral currently unavailable, CP&L, doing business as PEC, requests approval of the comparable material Metamic for use as an alternate neutron absorber in the proposed PWR racks.

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Attachment Ito SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES

4.0 TECHNICAL ANALYSIS

4.1 SFP Design The SFPs are an integral part of the FHB structure. The FHB is designed and constructed as Seismic Category I. A stainless steel liner is attached to the inside surface of the pools. The racks are Seismic Category I. The revised rack configuration, which includes the addition of four PWR racks in phase IV and three PWR racks in phase V, was re-evaluated by Holtec International in calculation HI-2073787, Revision 1 (Reference 2).

As a result of the Whole Pool Multi-Rack Analysis performed individually for Phase IV, Phase V and Alternate Phase V Rack Installation, it was determined that all racks are structurally secure under all postulated loading conditions. This evaluation concluded that adequate design margin exists to allow for the proposed reconfiguration (replacing four BWR racks with four PWR racks) without exceeding allowable stresses.

4.2 Configuration The existing configuration of the SFP C, as previously approved under Amendment No.

103, will be revised to reduce the licensed number of (13 x 13 cell) BWR racks from nine to five. This will result in a reduction in licensed storage capacity of BWR assemblies in SFP C from 2,763 to 2,087. The existing configuration of SFP C will also be revised to increase the licensed number of (9 x 9 cell) PWR racks from nine to thirteen, resulting in an increase in the licensed storage capacity of PWR assemblies in SFP C from 927 to 1,251. The overall net affect is that the licensed number of fuel assemblies in SFP C will decrease by 352 from 3,690 to 3,338.

The physical configuration of the racks in SFP C was previously evaluated for Amendment 103, which approved the statement to HNP TS 5.6.3.b that the (9 x 9 cell)

PWR racks and the (13 x 13 cell) BWR rack styles are dimensioned such that interchangeability between the two is possible.

Additionally, TS 5.6.3.d specifies that the maximum heat load from fuel stored in SFP C

& D is 7.0 MBTU/hr. Since existing fuel handling procedures (Reference 3) require verification of heat load prior to installing additional fuel assemblies into SFP C, this proposed re-configuration of racks in SFP C will not affect HNP's ability to maintain this maximum heat load requirement.

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Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES 4.3 Metamic The impact of the substitution of Metamic for Boral was analyzed by Holtec International

("Holtec") using bounding assemblies in the following calculation:

Holtec Report HI-2073849, Revision 0 (proprietary)

The only change in the material to be used in the construction of the fuel racks for HNP SFP C and D is the substitution of Metamic as the neutron absorber. The rack construction structural material itself will not change from that as approved in License Amendment No. 103.

HI-2073849, Revision 0, which is the proprietary Holtec report entitled "License Amendment Report for Change in Rack Neutron Absorber Material," provided with this current request, evaluates Metamic as a substitute for Boral. This report addresses the impact of the substitution with respect to key areas discussed in the previously approved licensing amendment report HI-971760, Revision 2 (Reference 4). These include thermal-hydraulic performance, rack structural performance, mechanical accident performance and pool structural performance.

As demonstrated by Holtec, Metamic's properties and behavior are comparable to those of Boral. Holtec's comparison of the two materials indicates that Metamic is equivalent to Boral and, in certain cases, has properties superior to those of Boral.

In analyzing thermal-hydraulic performance, the previously submitted report took no credit for conduction through the neutron absorber. Since the heat capacity of water is greater than that of Metamic, the neutron absorber material only enters the thermal-hydraulic calculations through the amount of pool water it displaces. Therefore, if the Metamic were to displace much more water than the original Boral, the total pool heat capacity could be significantly reduced. As presented in HI-2073849, Revision 0, Section 1.0 (Attachment 7), the Metamic and Boral panels used at HNP are nominally the same size and the total pool heat capacity is essentially unchanged with Metamic instead of Boral.

Regarding rack structure performance, the original report also took no credit for the strength of the neutron absorber. As a result, the neutron absorber material only enters the calculations through its weight, which affects the applied dead loads and seismic loads applied to the rack structure. Per HI-2073 849, Revision 0 (Attachment 7),

since the density of Metamic and Boral are nearly identical, the neutron absorber weight and associated structural loads will also be nearly identical.

Page A1-7 of 15 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES When mechanical accident performance was analyzed in the previous report, only fuel drops onto the top of the racks had the potential to be affected by the neutron absorber material change. The description of the evaluated events states that the depth of damage to the affected cell walls must be demonstrated to remain limited to the portion of the cell above the top of the 'active fuel region,' which is essentially the elevation of the top of the Boral neutron absorber.

Therefore, the dropped fuel assembly should not alter the geometry of the rack where the neutron absorber is mounted. Since the dropped fuel assembly must stop before it can affect the neutron absorber, the use of Metamic as the absorber material does not change the accident results.

The pool structural performance analysis in the previous report indicated that the rack weight affects the applied dead loads and seismic loads applied to the pool structure. As provided in the submitted Holtec report, Section 1.0 (Attachment 7), since the replacement Metamic panels will be the same size as the Boral panels and the density of Metamic and Boral are nearly identical, the neutron absorber weight and associated rack weight and structural loads were determined to also be nearly identical.

In 2003, the NRC approved a topical report submitted by Entergy supporting the use of Metamic in SFP applications (Reference 5). The associated Safety Evaluation (SE) referenced Holtec International Report HI-2022871, Revision 1, "Use of Metamic in Fuel Pool Applications," which provided the NRC with information concerning Metamic's material composition and physical properties, the manufacturing process, corrosion testing results, its resistance to radiation damage and a comparison of Metamic to Boral. The SE itself then further discussed the composition of Metamic, various testing performed (including the establishment of a Metamic coupon surveillance program for the monitoring of physical and chemical property changes over time) and the Metamic - Boral comparison.

Subsequent licensee applications for Metamic approval in SFPs have incorporated coupon surveillance programs as presented in the SE for the Entergy 2003 topical report (Reference 5). Such programs provide a defense-in-depth measure for the monitoring of integrity and performance of Metamic. In accordance with the conditions and limitations placed on Metamic approval in the SE for the Entergy topical report, HNP will also implement a coupon surveillance program in conjunction with the future installation of the new Metamic racks in spent fuel pools C and D. The purpose of such a surveillance program is to characterize certain properties of Metamic in order to provide the data needed to evaluate the ability of Metamic to perform its intended function. Additionally, the surveillance program provides a method of detecting any significant degradation, which allows sufficient time for implementation of corrective actions.

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Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES This surveillance program utilizes representative coupon samples to monitor the performance of the absorber material without a disruption in the integrity of the storage system. The coupons are suspended on a mounting called a "tree", placed in a designated cell, and surrounded by spent fuel. This coupon "tree" will contain 10 Metamic test coupons, taken from the same lot as used for rack construction. Pre-characterization of each coupon will be done prior to insertion to obtain "before" reference initial values for, comparison with "after" irradiation measurements. The coupons are removed from the array on a prescribed schedule for testing. The stability and integrity of the Metamic in.

the storage cells may be inferred from the measurement of certain physical properties.

The conditions and limitations presented in the NRC SE for the previously approved topical report supporting the use of Metamic in spent fuel pools (Reference 5) have been considered. The specific criteria of HNP's surveillance program are:

1)

Metamic coupon dimensions: 8" x 6" x 0.098 minimum thickness (0.104" nominal);

2)

Coupons are from the actual base panels with no welds; proximity to stainless steel (rack wall) is accomplished via bolt/stainless steel washer combination where the coupon is attached to the tree;

3)

Initial B4C content of the coupons determined by measuring constituents during.,

material manufacture;

4)

B4C measured content: 30.5 weight percent nominal with a minimum of 29.5 weight percent (not to exceed 31 weight percent);

5)

Boron in B 4C shall contain a minimum of 18.3 weight percent of B-10;

6)

Coupon scratches and other surface anomalies will not be added to individual coupons since coupons are of the same lot/sections as the production Metamic and will contain same surface defects;

7)

Nominal B-10 areal density of 0.0304 g/cm 2 (0.0302 g/cm2 minimum areal density);

8)

Any bubbling, blistering, cracking or flaking of the coupons, any dose changes to the coupons, the effects of any fluid movement and temperature fluctuations of the pool water will all be addressed through visual observation, dimensional measurement, weight measurement and specific gravity measurements; any areal density changes of the coupons will be monitored through neutron attenuation measurements;

9)

Description of the anodizing process is not applicable since the Metamic used in the racks is not anodized;

10)

Cleaning technique will include a demin wash prior to shipping/installation to ensure surfaces of Metamic are thoroughly cleaned of all foreign items.

HNP will utilize the following methods to monitor the physical properties of the Metamic Page A1-9 of 15

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES coupons in the surveillance program for changes:

1)

Visual observation and photography

2)

Neutron attenuation

3)

Dimensional measurements (length, width, thickness)

4)

Weight and specific gravity The acceptance criteria and indications of the need for further attention are provided in Section 2.4.2.4 of the provided Holtec report, HI-2073849, Revision 0 (Attachment 7).

Table 2.3 of this report contains the sample coupon measurement schedule.

4.4 Criticality Holtec Report HI-971760, Revision 2, as previously submitted (Reference 4), verified that the Boral PWR racks conform to the regulatory criteria requirement of a keff less than 0.95. To evaluate the change from Boral to Metamic in the HNP SFP C/D racks, an additional calculation was performed to measure the negative reactivity effect. The new calculation, which used the same computer code as the previous calculation, evaluated both the material and the minor geometry changes of the new Metamic racks. As shown in Attachment 7, the reactivity of the Metamic racks is lower than that of the previously analyzed Boral racks. Based on this lower reactivity value for Metamic, the analysis and acceptance criteria contained in HI-971760, Revision 2, for the Boral racks will also be applicable to the new Metamic racks.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine that applicable regulations and requirements for HNP will continue to be met. PEC has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the change to Technical Specifications. Applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained.

Holtec International Reports HI-971760, Revision 2, "Licensing Report for Expanding Storage Capacity in Harris Spent Fuel Pools C and D," submitted with the prior License Amendment Request, and HI-2073 849, Revision 0, "Licensing Amendment Report for Change in Rack Neutron Absorber Material," as contained in Attachment 7, provide the basis for support of this current license amendment request. These two reports document Page Al-10 of 15 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES the design and analyses performed by Holtec to demonstrate that the construction of the new racks, including the use of Metamic as an alternate neutron absorber, meet all governing requirements of the applicable codes and standards.

10 CFR 50 Appendix A General Design Criterion 61, "Fuel Storage and Handling and Radioactivity Control," requires that the fuel storage and handling systems be designed to assure adequate safety under normal and postulated accident conditions. As previously discussed in this request, the proposed substitution of four PWR racks for four BWR racks does not impact HNP's compliance with this criterion.

10 CFR 50 Appendix A General Design Criterion 62, "Prevention of Criticality in Fuel Storage and Handling," specifies that criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations. The changes proposed in this request do not impact the capability of the existing storage racks in SFPs C and D to comply with this Criterion. Additionally, the new storage racks with the alternate neutron absorber have been designed to comply with this Criterion.

The design and operation of the fuel pool meets the requirements of 10 CFR 50.68(b);

"criticality accident requirements," per the HNP Final Safety Analysis Report (FSAR).

Since the proposed change continues to result in a klff less than or equal to 0.95, continued compliance with 10 CFR 50.68(b) is maintained.

The NRC's Safety Evaluation in support of License Amendment No. 103 analyzed the installation of maximum density spent fuel storage racks to allow expansion of spent fuel pools C and D. The racks would be installed in phases on an as-needed basis. As evaluated, the new racks are free-standing and self-supporting. The primary material of construction is stainless steel and the only non-stainless material is the neutron absorber material, Boral.

As a result of Amendment 103, Pool C is approved to contain a combination of PWR and BWR assemblies and authorized to contain two (11 x 9 cell) and nine (9 x 9 cell) PWR racks for storage of 927 PWR assemblies. Pool C can contain two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell) and nine (13 x 13 cell) BWR racks for storage of 2763 BWR assemblies. The (9 x 9 cell) PWR racks and the (13 x 13 cell) BWR racks are dimensioned to allow interchangeability between PWR and BWR storage rack styles as required.

Page Al-lI of 15 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES 5.2 Precedent The new racks proposed for installation in Spent Fuel Pools C and D contain Metamic as an alternate fixed neutron absorber. Metamic has been subjected to rigorous tests by various organizations, including Holtec, for determination of its physical stability and performance characteristics. In accordance with the submitted report (Attachment 7),

testing of Metamic's functional performance at elevated temperatures and radiation levels has shown that it maintains its physical and neutron absorption properties with little variation in its properties from the unirradiated state. Based on these results, Metamic has been endorsed by both EPRI and the NRC for dry and wet storage applications.

5.2.1 NRC Topical Safety Evaluation Licensing precedent for using Metamic in spent fuel pools was established in 2003, when the NRC issued its topical SE (Reference 5) on Holtec International Report HI-2022871, Revision 1, "Use of Metamic in Fuel Pool Applications," for the use of Metamic poison panel inserts in existing spent fuel racks at Arkansas Nuclear One, Units 1 and 2, SFPs.

In the model SE, the NRC conditioned the use of Metamic for the identified purpose upon implementation of a coupon surveillance program to assure that the Metamic application, as approved, would exhibit performance results consistent with those evaluated in the report provided. Additionally, any subsequent application of the SE was to include a discussion of the following items:

1)

Size and types of coupons to be used (i.e., similar in fabrication and layout to the proposed application, including welds or mechanical fasteners and proximity to stainless steel);

2)

The technique for measuring the initial B 4C content of the coupons;

3)

Scratches and other surface anomalies on the coupons to simulate as-installed conditions of Metamic;

4)

Frequency and justification of the coupon sampling;

5)

The tests to be performed on coupons (e.g., weight measurement, measurement of dimensions (length, width and thickness), and B4C content);

6)

Tests to address any bubbling, blistering, cracking, flaking or areal density changes of the coupons, any dose changes to the coupons, or the effects of any fluid movement and temperature fluctuations of the pool water;

7)

Description of the anodizing process used (if any) and the cleaning technique to ensure sufficient removal of surface contaminants prior to installation;

8)

Assurance that the maximum B4C content of the Metamic is 31 Wt. %.

The specifics of HNP's coupon surveillance program are addressed in Section 4.3 of this document. The use of Metamic as a neutron absorber in the SFP application requested Page Al-12 of 15

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES (i.e., panel inserts) was found acceptable contingent upon the implementation of the above conditions and limitation.

5.2.2 Spent Fuel Pool Rack Approvals The NRC had previously approved Holtec spent fuel storage racks, with Boral neutron absorber inserts, for use in HNP's spent fuel pools C and D (Reference 1). Although the substitution of Metamic was not an option at that time, other nuclear plants have received approval from the NRC for Metamic as a neutron absorber (References 6 and 7).

Subsequent to the NRC's 2003 approval of Metamic panel inserts, Clinton Power Station requested and received approval for new Holtec spent fuel storage racks, fabricated from the same structural materials as the already approved HNP racks, but with Metamic as the neutron absorbing material, integrated within the rack structure (Reference 7). In the Safety Evaluation dated October 31, 2005, the NRC concluded that:

... the materials in the CPS [Clinton Power Station] spent fuel racks, including the Metamic neutron absorber, are compatible with the environment of the SFP. Also, the staff finds the proposed surveillance program, which includes visual, physical and confirmatory tests, is capable of detecting potential degradation of the Metamic material that-could impair its neutron absorption capability. Therefore, the staff concludes that the use of Metamic as a neutron absorber panel in the new spent fuel racks is acceptable. (Reference 7) 5.3 Determination of No Significant Hazards Consideration (10 CFR 50.92) provides the Determination of No Significant Hazards Consideration (NSHC) required by 10 CFR 50.92 in conformance with the guidance provided in NRC Regulatory Issue Summary RIS 2001-22.

5.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Page A1-13 of 15

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES

6.0 ENVIRONMENTAL CONSIDERATION

provides the Determination of Environmental Impact Consideration (EIC) required by 10 CFR 50.92. In summary, the Determination of EIC concludes that the proposed amendments do not require preparation of an Environmental Impact Statement or Environmental Assessment because the amendments meet the criteria for categorical exclusion.

7.0 REFERENCES

1.

Letter from U. S. Nuclear Regulatory Commission to Mr. James Scarola (Carolina Power & Light Company), "Shearon Harris Nuclear Power Plant, Unit 1 -

Issuance of an Amendment Re: Expansion of Spent Fuel Storage Expansion (TAC NO. MA4432)," dated December 21, 2000, and accompanying Safety Evaluation

2.

"WPMR Analysis for Phase IV and V," Holtec International Document No. HI-2073787, Revision 1 (2008) (Proprietary)

3.

Progress Energy, Nuclear Generation Group BNP, HNP Standard Procedure, Volume 99, NFP-NGGC-0003, Revision 17, "Procedure for Selection of Irradiated Fuel for Shipment in the IF-300 Spent Fuel Cask to Harris or For Movement Between Harris Pools A or B and Pool C"

4.

Letter from J. Scarola (Carolina Power & Light Company) to the Nuclear Regulatory Commission (Serial: HNP-98-188), "Shearon Harris Nuclear Power Plant Request for License Amendment Spent Fuel Storage," dated December 23, 1998 (includes proprietary Holtec International Licensing Report HI-971760, Revision 2)

5.

Letter from T. W. Alexion (NRC) to C. G. Anderson (Entergy Operations, Inc.), "Arkansas Nuclear One, Units 1 and 2 - Review of Holtec Report Re: Use of Metamic in Fuel Pool Applications (TAC NOS. MB5862 and MB5863)," dated June 17, 2003, and accompanying Safety Evaluation

6.

Letter from U. S. Nuclear Regulatory Commission to Mr. Timothy G. Mitchell (Entergy Operations, Inc.), "Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment Re: Revisions to Technical Specifications to Support Partial Re-Rack and Revised Loading Patterns in Spent Fuel Pool (TAC NO. MD4994),"

Page Al-14 of 15

Attachment I to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EVALUATION OF PROPOSED CHANGES dated September 28, 2007, and accompanying Safety Evaluation

7.

Letter from U. S. NRC to Mr. Christopher M. Crane (AmerGen Energy Company, LLC), "Clinton Power Station, Unit 1 - Issuance of an Amendment - Re: Onsite Spent Fuel Storage Expansion (TAC NO.

MC4202)," dated October 31, 2005, and accompanying Safety Evaluation Page Al-15 of 15 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes will modify the HNP TSs related to fuel storage in SFP C.

License Amendment 103 allows current storage in SFP C of 927 PWR assemblies, consisting of two (11 x 9 cell) and nine (9 x 9 cell), and the storage of 2763 BWR assemblies, consisting of two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell) and nine (13 x 13 cell), with Boral as the approved neutron absorption material. However, since Boral is no longer available, the use of the substitute neutron absorption material Metamic is requested. In addition, the proposed change substitutes four PWR racks for four previously approved BWR racks, with no impact on the maximum allowable heat load for SFP C.

The above proposed changes will result in modifications to TSs concerning the number and type of fuel racks in SFP C. Additionally, a coupon surveillance sampling program will be added to plant procedures.

PEC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The license amendment only revises the SFP C configuration and provides an optional poison material Metamic for the spent fuel pool racks. These changes do not modify the design of Structures, Systems and Components (SSCs) that could initiate an accident. This system has been evaluated for the conditions that would exist with the new configuration and new poison materials. It was found that the rack configuration has been previously evaluated for all enveloping accidents.

Also, the Metamic poison material has been evaluated for all enveloping accidents and it can be concluded that there would be no increase in dose from a fuel handling accident in the FHB.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page A2-1 of 3 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The license amendment only revises the SFP C configuration and allows the optional poison material Metamic for the spent fuel pool racks. License Amendment 103 Safety Evaluation addressed applicable design basis accidents for the addition of the SFP racks. Since no structural properties are attributed to the Boral or Metamic, this is an acceptable substitution. The properties of Metamic are equal to or better than Boral in ensuring criticality control. No significant impact on any postulated accident is made due to this change. The Fuel Pool Cooling and Cleanup System (FPCCS) and Spent Fuel Pool Racks will operate within design parameters.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in the margin of safety?

Response: No.

In accordance with License Amendment 103 and the submitted Holtec report in, the change in the Spent Fuel Pool Rack configuration and poison substitution is bounded by previous evaluations of the safety-related systems to design basis accidents. The fixed neutron absorber (Metamic) has been demonstrated as acceptable for dry and wet storage applications on a generic basis. Additionally, the NRC has approved the use of Metamic in both wet storage and dry storage nuclear plant applications.

The margin of safety for sub criticality is maintained by having keff equal to or less than 0.95 under all normal storage, fuel handling and accident conditions, including uncertainties. Since Metamic provides a lower calculated keff than does Boral, 0.90929 versus 0.91062, the margin of safety slightly increases with the use of Metamic. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above, PEC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, Page A2-2 of 3 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION paragraph (c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page A2-3 of 3 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Paragraph (c)(9).

Therefore, pursuant to 10 CFR 51.22, Paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page A3-1 of 1 to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. I DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PROPOSED TECHNICAL SPECIFICATION (TS) CHANGES MARKED-UP TS PAGE (1 Page)

DESIGN FEATURES 5.6.3.b Pool "C" is designed to contain a combination of PWR and BWR assemblies.

Pool "C can contain two (11 x 9 cell) and (9 X 9 cell) PWR racks for storage of '-PWR assemblies.

Pool "C" can contain two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell), and 4

(13 x 13 cell) BWR racks for storage of BWR assemblies.

The (9 x 9 cell) PWR racks and the (13 x 13 cell) BWR racks are dimensioned to allow intechangeability between PWR or BWR storage rack styles as required.

The racks in pool "C" will be installed as needed.

5.6.3.c Pool "D" contains a variable number of PWR storage spaces.

These racks will be installed as needed.

Pool "D" is designed for a maximum storage capacity of 1025 PWR assemblies.

5.6.3.d The heat load from fuel stored in Pools "C" 7.0 MBtu/hr.

and "D" shall not exceed 5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components identified in Table 5.7-1 are maintained within the cyclic or transient limits of SHEARON HARRIS - UNIT 1 5-7b designed and shall be Table 5.7-1.

Amendment No. 121 I

to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PROPOSED TECHNICAL SPECIFICATION (TS) CHANGES RETYPED TS PAGE 5-7b (1 page)

DESIGN FEATURES 5.6.3.b Pool "C" is designed to contain a combination of PWR and BWR assemblies.

Pool "C" can contain two (11 x 9 cell) and thirteen (9 X 9 cell)

PWR racks for storage of 1251 PWR assemblies.

Pool "C" can contain two (8 x 13 cell), two (8 x 11 cell), six (13 x 11 cell), and five (13 x 13 cell)

BWR racks for storage of 2087 BWR assemblies.

The (9 x 9 cell)

PWR racks and the

(.13 x 13 cell) BWR racks are dimensioned to allow interchangeability between PWR or BWR storage rack styles as required.

The racks in pool "C" will be installed as needed.

5.6.3.c Pool "D" contains a variable number of PWR storage spaces.

These racks will be installed as needed.

Pool "D" is designed for a maximum storage capacity of 1025 PWR assemblies.

5.6.3.d The heat load from fuel stored in Pools "C" and "D" shall not exceed 7.0 MBtu/hr.

5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components identified in Table 5.7-1 are designed and shall be maintained within the cyclic or transient limits of Table 5.7-1.

SHEARON HARRIS

- UNIT 1 5-7b Amendment No.

to SERIAL: HNP-08-018 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT HOLTEC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (5 pages)

• M**M Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O L T E C Fax (856) 797-0909 INTERNATIONAL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, John Catanio, being duly sworn, depose and state as follows:

(1)

I am the Holtec International Project Manager for the Progress Energy Harris Plant Phase IV Racks Project and 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 Holtec Report [I-2073849 Revision 0 containing 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 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), 2.390(a)(4), and 2.390(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 Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992),

and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir.

1983).

1 of 5

• M**M Holtec Center; 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O0 L T E C Fax (856) 797-0909 INTERNATIONAL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT 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.

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 2 of 5

• M**M Holtec Center,'555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O L T E C Fax (856) 797-0909 INTERNATIONAL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 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 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 designation.

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 International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical 3 of 5

S*Holtec Center,555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O L T E C Fax (856) 797-0909 INTERNATIONAL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 copy our technology and offer it for sale in competition with our company, causing us financial injury.

(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.

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 orif they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

4 of 5

I'll' HOLTEC INTERNATIONAL Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 Fax (856) 797-0909 U.S. Nuclear Regulatory Commission ATTN: Document Control. Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 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

))

ss:

COUNTY OF BURLINGTON)

Mr. John Catanio, being duly sworn, deposes and says:

That 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 10 th day of March, 2008.

John Catanio Holtec International Subscribed and sworn before me this /

o lday of

, 2008.

MARIA C. MASSI NOTARY PUBLIC OF NEW JERSEY My Cmnnmsslon ExpireS Apr 25*. 201 5 of 5