ML110450419

Spent Fuel Pool Criticality Documents

ML110450419
Person / Time
Site:	Peach Bottom
Issue date:	02/09/2011
From:	David Helker Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110450419 (9)

Text

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Exelon Nuclear www.exeloncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 February 9, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Spent Fuel Pool Criticality Documents As requested by the U.S. Nuclear Regulatory Commission Senior Resident Inspector at Peach Bottom Atomic Power Station, attached are several documents for NRC review. We note that there is no outstanding license amendment request associated with this issue.

Attachments 1 through 5 contain information proprietary to Curtiss-Wright Flow Control Service Company (NETCO). Attachments 7 and 8 contain information proprietary to Nuvision Engineering, Inc. These companies request that the information contained in these attachments be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). Affidavits supporting these requests are contained in Attachments 6 and 9. Attachment 10 contains a non-proprietary version of Attachment 1.

If any additional information is needed, then please contact Tom Loomis at (610) 765-5510.

Respectfully, David P. Helker Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1)

"Technical Evaluation to Verify the Adequacy of the Peach Bottom Atomic Power Station Spent Fuel Pool (SFP) Storage Rack Criticality Margins Dated August 16, 2010" (Proprietary Version)

Attachments 1, 2, 3, 4, 5, 7, 8 transmitted herewith contain Proprietary Information.

When separated from attachments, this document is decontrolled.

U.S. Nuclear Regulatory Commission Spent Fuel Pool Criticality Documents February 9, 2011 Page 2

2)

"BADGER Test Campaign at Peach Bottom Atomic Power Station Unit 3," NET-247-01, Revision 1 (Proprietary)

3)

"BADGER Test Campaign at Peach Bottom Unit 2," NET-264-01, Revision 3 (Proprietary)

4)

"BADGER Test Campaign at Peach Bottom Atomic Power Station Unit 3," NET-31 1-01, Revision 0 (Proprietary)

5)

"2010 BADGER Test Campaign at Peach Bottom Unit 2," NET-350-01, Revision 0 (Proprietary)

6)

Affidavit (Curtiss-Wright Flow Control Service Company (NETCO))

7)

"An Assessment of the Possible Effects of Boraflex Degradation on K-Effective for the Peach Bottom Storage Pools," AEAT-0791, AEA Technology Engineering Services, dated November 7, 1996 (Proprietary)

8)

"Criticality Assessment of the Peach Bottom Spent Fuel Ponds with Degraded Boraflex Panels," AEAT/R/NS/0084, Issue 1, AEA Technology Engineering Services, July, 2000 (Proprietary)

9)

Affidavit (Nuvision Engineering, Inc.)

10)

"Technical Evaluation to Verify the Adequacy of the Peach Bottom Atomic Power Station Spent Fuel Pool (SFP) Storage Rack Criticality Margins Dated August 16, 2010" (Non-Proprietary Version) cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Bureau of Radiation Protection (w/o Attachments)

S. T. Gray, State of Maryland (w/o Attachments)

U.S. Nuclear Regulatory Commission Spent Fuel Pool Criticality Documents February 9, 2011 Page 3 bcc:

P. Steinhauer, PSEG Sr. Vice President, Mid-Atlantic Operations Sr. Vice President, Operations Support Site Vice President-PBAPS Plant Manager-PBAPS Director, Operations-PBAPS Director, Engineering Director, Site Engineering-PBAPS Director, Site Training-PBAPS Manager, Regulatory Assurance-PBAPS Manager, Licensing Commitment Coordinator - KSA 3-E Records Management - KSA 1-N-1 A. Levin - Cantera Affidavit (Curtiss-Wright Flow Control Service Company (NETCO))

NETCO 731 Grant Avenue Lake Katine, NY 12449 Phone: 845.382,6912 Fax: 645.382 6917 7low* Control Company NETCO AFFIDAVIT I, Matthew L. Eyre, Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company, do hereby affirm and state:

1. I am the Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company (NETCO), authorized to execute this affidavit on its behalf. I am further authorized to review information submitted to the Nuclear Regulatory Commission (NRC) and apply to the NRC for the withholding of information from disclosure.

2. The information sought to be withheld is contained in the "Technical Evaluation to Verify the Adequacy of the Peach Bottom Atomic Power Station Spent Fuel Pool (SFP) Storage Rack Criticality Margins, Dated August 16, 2010" and in the NETCO technical reports, "BADGER Test Campaign at Peach Bottom Atomic Power Station Unit 3," designated as NET-247-01, Rev 1; "BADGER Test Campaign at Peach Bottom Unit 2," designated as NET-264-01, Rev 3; "BADGER Test Campaign at Peach Bottom Atomic Power Station Unit 3," designated as NET-31 1-01, Rev 0; and "2010 BADGER Test Campaign at Peach Bottom Unit 2," designated as NET-350-01, Rev 0.

3. In making this application for withholding of proprietary information of which it is the owner, NETCO relies on provisions of NRC regulation 10 CFR 2.390(a) 4. The information for which exemption from disclosure is sought is confidential commercial information.

4. Some categories of information which fit into the definition of proprietary information are:

a) Information that discloses a process or a method including data and supporting analysis and use of such information by a competitor would constitute a competitive advantage over other companies; b) Information if used by a competitor would reduce the competitor's expenditure of resources or improve his competitive position in the implementation of a similar product.

5. Initial approval of proprietary treatment of a document is made by the Director of NETCO, the person most likely to be familiar with the value and sensitivity of the information and its relation to industry knowledge. Access to such information within NETCO is on a "need to know" basis.

Page 2 of 2

6. The information referred to in paragraph (2) above is classified as proprietary because it contains details of NETCO's spent fuel pool criticality analysis methodology. The development of methods used in these analyses was achieved at significant cost.

7. Public disclosure of the information sought to be withheld may cause harm to NETCO's competitive position and may reduce profit-making opportunities.

I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information and belief.

Matthew L. Eyre Director NETCO, a business unit of Curtiss-Wright Flow Control Service Company January 26, 2011 C~~~ý i:

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ýtte OfNew York 0 1 SM6O43170 NETCO 731 Grant Avenue - Lake Katnne. NY 12449 - Phone 845,382.6912 - Fax: 845.382.6917 Affidavit (Nuvision Engineering, Inc.)

Affidavit Page 1 of 2 ATTACHMENT AFFIDAVIT I, Van B. Walker, President and Chief Executive Officer of Nuvision Engineering, Inc., do hereby affirm and state:

1. I am an officer of Nuvision Engineering Inc. authorized to execute this affidavit on its behalf. I am further authorized to apply for the withholding of information from disclosure.

2. The information sought to be withheld is:

i)

"An Assessment of the Possible Effects of Boraflex Degradation on K-Effective for the Peach Bottom Storage Pools," AEAT-0791, AEA Technology Engineering Services, dated November 7, 1996 ii)

"Criticality Assessment of the Peach Bottom Spent Fuel Ponds with Degraded Boraflex Panels," AEAT/RJNS/0084, Issue 1, AEA Technology Engineering Services, July, 2000

3. Exelon Generation Company, LLC (Exelon) is submitting this information at the U.S. Nuclear Regulatory Commission's request. This information constitutes proprietary information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4), because:

i.

This information is marked as "Restricted Commercial" information and has been held in confidence by Nuvision Engineering, Inc. and Exelon.

ii.

This information is of a type that is held in confidence by Nuvision Engineering Inc. and Exelon, and there is rational basis for doing so because the information contains methodology, data, and supporting information identified as "Restricted Commercial."

iii.

This information is being transmitted to the NRC in confidence.

iv.

This information sought to be withheld, to the best of my knowledge and belief, is not available in public sources and no public disclosure has been made.

v.

Public disclosure of this information could create substantial harm to Nuvision Engineering Inc.'s business interests because it expended considerable resources in developing and protecting the information.

Affidavit Page 2 of 2

4. Accordingly, Nuvision Engineering, Inc. requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4).

COMMONWEALTH OF PENNSYLVANI Notarial Seal N

Dana L. Scarfo, Notaiy Putbk COty of pittsburgh, Allegheny Cou*t My Commissio Expires Sep, 2,.2014 Subscribed and swo before me, A Notary Public in and for the Commonwealth of Pennsylvania this Lk day of p,,. 2011 Nuvision Engineering Inc.

Van B. Walker President and Chief Executive Officer