ML100950449
| ML100950449 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/31/2010 |
| From: | George Gellrich Calvert Cliffs, Constellation Energy Nuclear Group, EDF Group |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| TAC L24350 | |
| Download: ML100950449 (6) | |
Text
,George
ýGeorge H.H. Gellrich Gellrich Calvert Cliffs Nuclear Nuclear Power Plant, LLC Vice President Vice 1650 Calvert Cliffs Parkway 1650 Parkway Lusby, Maryland 20657 Maryland 20657 410.495.5200 410.495.5200 410.495.3500 410.495.3500 Fax CENG CENG a joint venture of of--------,
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0Constellation *eDF Constellation & (Jc;;) eDF
. Energy-Energy' oCJ9I\) D CALVERT CALVERT CLIFFS CLIFFS
,NUCLEAR jNUCLEAR POWER PLANT PLANT March 31, 2010 March 31, 2010 U. S. Nuclear Nuclear Regulatory Commission Commission Washington, DC 20555 20555 ATTENTION: Document Document Control Desk Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Independent Independent Spent Fuel Storage Installation; Docket No. 72-'8 72-8 Supplemental Supplemental Information Information Related to License Amendment Request Request No. 9 (TAC No. L24350)
L24350)
REFERENCE:
REFERENCE:
(a) Letter from Mr. J. A. Spina (CCNPP)
(CCNPP) to Document Control Desk (NRC),
dated June 15,15, 2009, License Amendment Request : Allow Increased Amendment Request: Increased NUHOMS-32P Dry Shielded Burnup Fuel to be Loaded into NUHOMS-32P Shielded Canister Calvert Cliffs submitted submitted a license amendment request request (Reference (Reference a) to allow the loading of increased increased burnup fuel into a NUHOMS-32P Dry Shielded Canister. The Nuclear Regulatory Regulatory Commission (NRC) (NRC) conducted a phone call with Calvert C*liffs staff conducted Cliffs staff on January 5, 2010 to discuss the need for revised structural calculations calculations to be performed to support their review of Reference (a). Specifically, the NRC staff indicated indicated that end drop structural calculations for both the fuel and the canister canister using LS-DYNA LS-DYNA (a finite element analysis code) would need to be provided. The requested calculations attached calculations are attached
[Attachments
[Attachments (1), (1), (2)
(2) and (3)]. (3)].
One of the Transnuclear, Transnuclear, Inc. calculations [Attachment[Attachment (3)] contains information information that that is proprietary proprietary to Transnuclear, Transnuclear, Inc. Therefore, Therefore, it is accompanied by an affidavit [Attachment (4)]
[Attachment (4)] Signedsigned by Transnuclear, Transnuclear, Inc., the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission, Commission, and addresses, with specificity, the considerationsconsiderations listed in 10 CFR 2.390(b)(4).
2.390(b)(4). Accordingly, it is requested that the information proprietary proprietary to Transnuclear, Inc. be withheld from public disclosure. A non-proprietary Transnuclear, non-proprietary version of the calculation calculation is provided [Attachment
[Attachment (2)] for public disclosure.
This supplemental information information does not change the environmental environmental assessment provided provided in Reference (a) and the categorical categorical exclusion set forth in 10 CFR 51.22( 51.22(c)( 11) is still valid.
c)( 11)
Document Document Control Desk March March 31, 2010 31, 2010 Page 2 Should you have questions regarding regarding this matter, please please contact Mr. Douglas E. Lauver at (410) 495-5219.
Very truly yours, STATE OF MARYLAND MARYLAND
- TO WIT:
COUNTY OF CALVERT COUNTY I, George H. Gellrich, being duly sworn, state that tha~ I am Vice President - Calvert Cliffs Nuclear Power Plant, LLC (CCNPP), and that I am duly authorized authorized to execute execute and file this License Amendment Amendment Request Request on behalf of CCNPP. To the best of my knowledge knowledge and belief, belief, the statements contained statements contained in this document document are true and correct. To the extent extent that these statements are not based based on my personal personal knowledge, knowledge, they are based upon information information provided by other CCNPP employees and/or consultants. Such information information has been been reviewed in accordance accordance with company practice and I believe believe it to be reliable.
Subscribe
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and sworn before me, aday this IRý Notary of Public* in and for the State of Maryland 2010. Maryland and County of of
/ . (lIl .~ ,this ,}I:jt' day of ~ ,2010.
WITNE~S iraiy fIand'and WITNESS
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Imy flandand Notarial Seal: Ua<Žt*? 6bA Notary Public Public My Commission Expires: 7I)0ALJ... D/ao//ll2ol/
, ~D~te Dhte GHG/PSF/bjd GHGIPSF/bjd cc:
cc: J. M. Goshen, NMSS NMSS (including (including DVDs with files as listed in Enclosures 1 and 2) 2)
(Without Attachment Attachment 3)
D. V. Pickett, NRC S. Gray, DNR DNR S. J. Collins, NRC M. F. Weber, NMSS Resident Resident Inspector, NRC V. L. Ordaz, NRC
Document Control Desk Document 31, 2010 March 31, 2010 Page 3 Attachments:
Attachments: (1) NUH32P+.0203, Revision 0, 32P+ Transfer Cask Impact NUH32P+.0203, Impact onto the Concrete Pad LS-DYNA Analysis (80 (80 inch end drop)
Enclosure:
(1) The file listing for Three DVDs Containing LS-DYNA Files for NUH32P+.0203 (2)
(2) NUH312P+.0204, Revision NUH32P+.0204, Revision .0, 0, Fuel End Drop Analysis for NUH32P+
NUH32P+ Using LS-DYNA, Non-proprietary Non-proprietary Version (3) NUH32P+.0204, Revision Revision 0, ,Fuel Fuel End Drop Analysis for NUH32P+
NUH32P+ Using Version LS-DYNA, Proprietary Versiort
Enclosure:
(2)
(2) The file listing for One DVD Containing LS-DYNA LS-DYNA Files for (4) NUH32P+.0204 Proprietary Affidavit for NUH32P+.0204, Revision 0 (4) Proprietary Affidavit for NUH32P+.0204, Revision 0
ATTACHMENT ATTACHMENT (4)
PROPRIETARY AFFIDAVIT FOR NUH32P+
PROPRIETARY NUH32P+.0204,
.0204, REVISION REVISION 0 Calvert Calvert Cliffs Cliffs Nuclear Nuclear Power Power Plant, LLC March March 31, 31, 2010 2010
AFFIDAVIT PURSUANT AFFIDAVIT PURSUANT TO 10 CFR 2.390 Transnuclear, Inc. ))
State of Maryland Maryland SS.
County of Howard ))
I, I, Jayant Jayant Bondre, depose and say that I am Vice President of Transnuclear, Inc., duly execute this affidavit, and have reviewed authorized to execute reviewed or caused caused to have reviewed the the information which is identified information identified as proprietary proprietary and referenced referenced in the paragraph immediately immediately below. I am submitting submitting this affidavit in conformance conformance with the provisions of 10 CFR 2.390 of the the Commission's regulations for withholding this information.
The information information for which proprietary proprietary treatment is sought is contained contained in Enclosure 1 and as listed below:
- TN Calculation Calculation NUH32P+.204, NUH32P+.204, Revision 0 This document document has been appropriately appropriately designated designated as proprietary.
I have personal knowledge of the criteria have personal criteria and procedures procedures utilized by Transnuclear, Inc. in designating information as a proprietary trade secret, privileged or as confidential commercial commercial or financial information.
Pursuant to the provisions provisions of paragraph (b) (4) of Section 2.390 2.390 of the Commission's Commission's regulations, the following is furnished furnished for consideration consideration by the Commission Commission in determining determining whether whether the information sought to be withheld from public included in the above public disclosure, included referenced documents, referenced documents, should be withheld.withheld.
- 1) The information information sought to be withheld from public disclosure involves involves structural NUHOMS 32P+ canister which are owned and have been held calculations of the NUHOMS held in confidence confidence by Transnuclear, Inc.
- 2) information is of a type customarily held in confidence The information confidence by Transnuclear, Inc.
and not customarily disclosed disclosed to the public. Transnuclear; Transnuclear, Inc. has a rational basis for determining determining the types of information information customarily held in confidence confidence by it.
- 3) The information information is being transmitted transmitted to the Commission Commission in confidence confidence under the under the provisions of 10 CFR 2.390 with the understanding understanding that it is to be received in confidence by the Commission.
confidence
- 4) The information, information, to the best of my knowledgeknowledge and belief, is not available in public public sources, and any disclosure to third parties has been made made pursuant to regulatory provisions regulatory provisions or proprietary proprietary agreements which provide provide for maintenance maintenance of the information in confidence.
- 5) Public disclosure disclosure of the information information is likely to cause substantial substantial harm to the the competitive position of Transnuclear, Inc. and to other owners of the information information because:
a) A similar product is manufactured manufactured and sold by competitors competitors of Transnuclear, Inc.
Page 1 of 2
b) Development of this information Development information by Transnuclear, Inc. and other owners owners of the information information required expenditure considerable resources. To the expenditure of considerable the best of my knowledge and belief, a competitor would have to undergo undergo similar expense in generating generating equivalent equivalent information.
c) In order to acquire such information, a competitor competitor would also require require considerable time and inconvenience inconvenience related to the development of a design and analysis of a dry spent fuel transportation transportation system.
d) The information required significant significant effort and expense expense to obtain the the licensing approvals approvais necessary necessary for application applicafion of the information.
Avoidance Avoidance of this expense expense would decrease competitor's cost in applying decrease a competitor's applying information and marketing the information marketing the product to which the information information is applicable.
e) information consists of structural The information calculations related to the design structural calculations design and analysis of dry spent fuel storage storage systems, the application application of which provide a competitive economic advantage. advantage. The availability of such information to competitors would enable information product to enable them to modify their product to unfairly unfairly get a better competitive competitive position with Transnuclear, Inc., take Inc., take marketing or other actions to improve their product's position or impair the marketing the position of Transnuclear, lnc.'s Inc.'s product, while avoiding expense of avoiding the expense developing developing similar data and analyses analyses in supportsupport of their processes, methods or apparatus.
methods apparatus.
f) In pricing Transnuclear, lnc.'s Inc.'s products and services, significant research, research, development, engineering, analytical, licensing, licensing, quality quality assurance and other costs and expenses expenses must be included. included. The ability of Transnuclear, Inc.'s competitors lnc.'s competitors to utilize such information expenditure of information without similar expenditure resources may enable them to sell at prices prices reflecting significantly lower significantly lower costs.
deponent sayeth not.
Further the deponent Ja~
Jaiint Bondre Vice President, Transnuclear, Transnuclear, Inc.
before this 88thth day Subscribed and sworn to me before March 2010.
day of March
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