SBK-L-13061, Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage

Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage

ML13099A022
Person / Time
Site:	Seabrook
Issue date:	03/27/2013
From:	Walsh K NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-13061, NF-NA-13-48, 2064006, 2064007, CAW-13-3645, TAC ME8688
Download: ML13099A022 (53)

Text

Enclosure and Attachments Contain Proprietary Information \\EXTe ra Withhold Enclosure I and Attachments 1, 3, and 6 from public disclosure EN ERGEF("

under 10 CFR 2.390 E

"".*~S E A B ROO0K March 27, 2013 10 CFR 50.90 SBK-L-1 3061 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage

References:

1. NextEra Energy Seabrook, LLC letter SBK-L-1 1245, "License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage,"

January 30, 2012

2. NRC letter "Seabrook Station, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage (TAC No. ME7946)," March 30, 2012

3. NextEra Energy Seabrook, LLC letter SBK-L-12099, Supplement to LAR 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage, May 10, 2012

4. NRC Letter "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage (TAC No. ME8688)," July 24, 2012

5. NextEra Energy Seabrook, LLC letter SBK-L-12199, Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage, September 20, 2012

6. NRC Letter "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage (TAC No. ME8688)," December 5, 2012 NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

Enclosure and Attachments Contain Proprietary Information Withhold Enclosure I and Attachments 1, 3, and 6 from public disclosure under 10 CFR 2.390 United States Nuclear Regulatory Commission SBK-L-13061 / Page 2 In Reference 1 and supplemented by References 3 and 5, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed change would revise the TS for new and spent fuel storage as the result of a new criticality analyses for the new fuel vault and the spent fuel pool.

In Reference 6, the NRC staff determined that additional information is required to complete its review of the proposed change. This letter provides NextEra's response to the request for additional information (RAI).

Section 1 of Enclosure 1 to this letter responds to RAI questions 14, 15, 19, 22a (the portion associated with plant operation), 24, 27c and 29; and Attachment 1 provides a response to the remainder of the questions. Section 1 of the enclosure also contains the previously mentioned RAI questions, which the NRC determined, as discussed in Reference 6, contain proprietary information. Therefore, NextEra requests that Enclosure 1 to this letter, which contains information proprietary to Holtec International, be withheld from public disclosure in accordance with 10 CFR 2.390. A non-proprietary version is provided in Enclosure 2. to the enclosure, Holtec RAI Responses, contains information proprietary to Holtec International and is supported by an affidavit in Attachment 2, Holtec Proprietary Affidavit for RAI Responses (Holtec Document ID 2064006). Attachment 3, Holtec Proprietary Licensing Report, also contains information proprietary to Holtec International and is supported by an affidavit in Attachment 4, Holtec Licensing Report Proprietary Affidavit (Holtec Document ID 2064007). Both affidavits are signed by Holtec International, the owner of the information and set forth the basis on which the information may be withheld from public disclosure and address with specificity the considerations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations. Accordingly, NextEra requests that the information that is proprietary to Holtec International (Attachments 1 and 3) be withheld from public disclosure in accordance with 10 CFR 2.390. Attachment 5 provides a non-proprietary version of the Holtec Licensing Report. Attachments 3 and 5 supersede and replace the Holtec licensing reports that were provided as Attachments 2 and 4 in Reference 1. to the enclosure, Westinghouse Supporting Data for RAI 15 and Proprietary Affidavit, contains information that is proprietary to Westinghouse Electric Company, LLC, and is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations. Accordingly, NextEra requests that the information that is proprietary to Westinghouse (Attachment 6) be withheld from public disclosure in accordance with 10 CFR 2.390. The Westinghouse document is proprietary in its entirety so a non-proprietary version is not provided.

Enclosure and Attachments Contain Proprietary Information Withhold Enclosure 1 and Attachments 1, 3, and 6 from public disclosure under 10 CFR 2.390 United States Nuclear Regulatory Commission SBK-L-1 3061 / Page 3 to the enclosure contains changes to the TS markups that supersede and replace the corresponding pages previously provided in Attachment 1 to Reference 1 and to Reference 3. The revision to the proposed TS changes does not alter the conclusion in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.

A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91 (b).

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Sincerely, Kevin T. Walsh Site Vice President NextEra Energy Seabrook, LLC Enclosure cc:

NRC Region I Administrator J. G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

SBK-L-13061 Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage Petro, J.

e-mail Dryden, M. S.

e-mail Brown, A.

e-mail Fuentes, E.

e-mail Gurney, P.

e-mail Ossing, M.

e-mail Letter Distribution e-mail File 0018 01-48 File 0052 01-48 RMD 02-06 (Non-Proprietary)

Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage

Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage Table of Contents Section Page Introduction 2

1 Responses to NRC Questions 3

2 Description of Proposed Technical Specification Changes 14 3

References 17 Attachments - Holtec RAI Responses 1-255 - Holtec Proprietary Affidavit for RAI Responses 1-7 - Holtec Proprietary Licensing Report 1-175 - Holtec Licensing Report Proprietary Affidavit 1-7 - Holtec Non-Proprietary Licensing Report 1-175 - Westinghouse Supporting Data for RAI 15 and Proprietary Affidavit 1-11 - Westinghouse Supporting Data for RAI 24 1-4 - Technical Specifications Revised Pages 1-6 I

Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage

==

Introduction:==

By letter SBK-L-11245 dated January 30, 2012, (Reference 1) NextEra Energy Seabrook, LLC (NextEra) requested to amend the Seabrook Unit 1 Technical Specifications (TS). The proposed amendment will revise TSs for new and spent fuel storage as the result of a new criticality analyses for the new fuel vault (NFV) and the spent fuel pool (SFP).

On March 30, 2012, the NRC requested supplemental information (Reference 2) to support acceptance of the requested license amendment request (LAR) 11-04. NextEra supplied the information requested in Reference 3. On June 19, 2012, the NRC accepted the LAR for review (Reference 4).

On July 24, 2012, the NRC transmitted a Request for Additional information in Reference 5. NextEra supplied the information requested in Reference 6.

The NRC has transmitted another Request for Additional Information (RAI) in Reference 7. The response to these RAIs is provided below in Section 1.0.

In response to the concerns in several of the RAI questions, revisions to several of the proposed TS submitted in Reference 1 and modified in Reference 3 are proposed. These changes will be discussed in Section 2.0. The revised TS pages are presented in Attachment 8. These changes are administrative changes since they are the result of applying the previously calculated data (with the exception of a very minor new uncertainty) in a more conservative manner.

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1.0 Responses to NRC RAIs:

The NRC RAIs consists of 29 questions with some questions having multiple parts. The responsibility for responding to these questions has been split between NextEra and the criticality vendor Holtec International. NextEra will respond to Questions 14, 15, 19, 22a (the portion associated with plant operation), 24, 27c and 29. The responses for the remainder of the questions are provided in Attachment 1 and are considered proprietary to the vendor. The proprietary affidavit for these responses is provided in Attachment 2. A revised Licensing Analysis Report that is consistent with the methods used to respond to the RAIs is provided in Attachment 3. The proprietary affidavit for the new Licensing Analysis Report is provided in Attachment 4. A non-proprietary version of the report is provided in Attachment 5.

The responses for the NextEra items are provided below.

RAI 14

The analysis notes in several places that the 17x17 Vantage 5 assembly design. Table 4.5.1 includes dimensions that are labeled as being for a Vantage 5. From the dimensions provided in Table 4.5.1, it appears that the assembly design is a Vantage 5H. The distinction is important because the fuel rods in the Vantage 5 assembly have a smaller radius. Confirm that the assembly design is the Vantage 5H.

A review of the 2002 RW-859 Commercial Spent Nuclear Fuel (CSNF) inventory data showed that Seabrook assembly IlDs H29, H30, H31 and H32, discharged in May of 2002, contained significantly lower uranium loading than the other assemblies (433 kgU vs. -460 kgU). If these assemblies are still stored in the SFP, describe how these assemblies vary from the design basis assembly and provide the logic showing that the design basis assemblies are bounding for these assemblies. Also, identify any other assemblies that vary from the designs described in Table 4.5.1 and, if such assemblies exist, provide the logic showing that the design basis assemblies are bounding. Note that lower mass does not necessarily equate to lower reactivity.

Response

The fuel documented as the 17x17 Vantage 5 design is more correctly named the Vantage 5H design.

The Seabrook fuel 741 records have been reviewed for fuel assemblies H29, H30, H31, and H32. These assemblies are not unique, i.e., there are no significant differences in uranium loading for these 3

assemblies. Our records show the uranium loading to be approximately 455 kgU, which is consistent with the other fuel in this fuel batch.

All assemblies on site are consistent with the design data described in Table 4.5.1 with the exception of four assemblies that have undergone reconstitution. Those assemblies are described in the response to RAI 22a where it is demonstrated that the impact of reconstitution is small while the burnups of the reconstituted assemblies are significantly higher than the requirement for placement.

RAI 15

Section 4.2.3.5.6 describes the analysis of fuel creep and growth. Provide a reference for the maximum fuel rod growth value that is provided in the section. If this reference is not publicly available, provide a copy.

Consistent with RAI 10 provided by the NRC on March 30, 2012, if the analysis is revised to correct other deficiencies noted in the RAIs, the impact of fuel creep and growth should be handled

. If the analysis is not revised, consistent with the applicant's response to RAI 10 in Holtec Letter RRTI-2064-001 dated April 24, 2012, which was provided by the applicant in an attachment to a letter dated May 20, 2012, NRC Staff will assume the loss of []

margin associated with fuel rod creep and growth.

Response: contains Westinghouse proprietary letter NF-NA-13-47 that justifies the value utilized for maximum fuel rod growth. An affidavit supporting the fact that this data is proprietary to Westinghouse is also included in Attachment 6.

As documented in the response to RAI 25, the impact of fuel creep and growth has been handled as a bias with a bias uncertainty in the generation of new burnup requirements for placement of fuel in the Seabrook Spent Fuel Pool.

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RAI 19

Section 4.2.3.5.3.2 states that Seabrook "typically" operates at all rods out (ARO) at full power.

"Typically" operating at ARO is not an acceptable basis for evaluating only ARO. If atypical rodded operation at power has occurred and some of the fuel has experienced even partially rodded operation for extended periods, this needs to be addressed in the safety analysis. Either confirm that there has not been rodded operation at power for extended periods, or provide justification for not evaluating the impact of rodded operation on fuel compositions.

Response

Seabrook Unit 1 periodically adjusts the location of all the control rods (RCCAs) to prevent fretting wear.

The current seven-step RCCA repositioning guideline places the RCCAs at different positions above the active core during the cycle.

During full power operations, the above guideline is followed and RCCAs are positioned as described.

Bank D RCCAs may be partially inserted during power maneuvers and off-normal operation for reactivity control, but those are not common occurrences during the cycle. There are five Bank D RCCAs in the Seabrook core; therefore, only five assemblies could be impacted during each cycle. Since assemblies are in the core typically for three cycles, the time spent by any particular assembly with a partially inserted RCCA is a small fraction of the total residence time of that assembly in the core.

NUREG/CR-6759, "Parametric Study of the Effect of Control Rods for PWR Burnup Credit," February 2002, documents a study of the impact of control rod insertion on reactivity. The document notes the following conclusions: "These more realistic calculations show that even for significant burnup exposures, minor axial CR insertions (e.g., <20 cm) result in a very small effect on the keff of a burnup credit cask.

Consequently, it is concluded that, based on the assumption that U.S. PWRs do not use CRs to a significant extent (i.e., CRs are not inserted deeper than the top -20 cm of the active fuel and CRs are not inserted for extended burnups), the effect of CRs on discharge reactivity is relatively small (less than 0.2% Ak)." The documented impact in NUREG/CR-6759 is small compared to the margin to the regulatory requirement included in the Seabrook spent fuel pool criticality analysis.

As noted in the response to RAI 21c, the key criticality operating assumptions will be compared to the measured values each cycle to verify that the analysis inputs remain bounding.

5

RAI 22a:

Many of the activities in this list are not described in enough detail to support review. Provide a description of each operation and provide discussion concerning how the analysis in HI-2114996 covers each operation. Where appropriate, potential proximity to other fuel should be addressed. The discussion must also address any accident or abnormal conditions related to these activities.

Response

This section provides the description of the activities. Holtec response to this question will focus on the criticality aspects of the activity.

General Information:

Seabrook Special Nuclear Material (SNM) Material Control and Accounting (MC&A) procedures require that a Material Transfer Form (MTF) be used for any movement of SNM. The movement of any fuel assembly, individual rod, or any other SNM can only be moved per the instructions of an approved MTF.

The MTF contains the required information to uniquely identify and move SNM from one approved storage location to another approved storage location. The spent fuel bridge crane can only move one fuel assembly or fuel rod at a time making it necessary to complete the movement of one assembly or fuel rod prior to beginning to move the next. Examples of approved storage locations are the new fuel storage vault locations, SFP storage racks, fuel rod storage basket, new fuel elevator, fuel transfer upender, and fuel cleaning fixtures. Separate operations procedures for the operation of the spent fuel bridge crane and handling tools are utilized in order to physically move individual fuel assemblies from the designated location to the new designated locations.

Due to the layout of the fuel storage building, the spent fuel bridge crane is the only crane that can operate over the Spent Fuel Pool (SFP) storage rack locations. Both the spent fuel bridge crane and the fuel storage building overhead crane can access the balance of areas that fuel may be moved.

The spent fuel bridge crane operating procedures require the use of spotters to ensure the two cranes are sufficiently separated when both are operating in the same area; a typical administrative control is to require the spent fuel crane to wait near the SFP rack locations to remain outside the travel path of the fuel building crane until it leaves the area accessible by the spent fuel bridge crane.

Any activity in the SFP must be bounded by the applicable seismic and criticality analyses.

6

Detailed Response to RAI:

Movement of fuel into and out of fuel storage racks Movement of fuel into and out of fuel storage racks is a closely monitored activity, with engineering controls to ensure fuel is placed into the correct location. The UFSAR Sections 9.1.2 and 9.1.4 describes the equipment utilized for fuel movement. HI-2114996 documents that an assembly fully inserted into its storage location bounds the reactivity of a partially inserted assembly. Only one assembly or fuel rod can be handled by the spent fuel bridge crane at a time; any mislocation/drop of a single assembly has already been addressed.

Movement of a single fuel assembly in the pool Movement of a single fuel assembly is a closely controled activity. Only one assembly or fuel rod can be handled by the spent fuel bridge crane at a time; any mislocation/drop of a single assembly has already been addressed. The response to RAI 27 considers the accident conditions of 2 assemblies in close approach or an assembly inadvertantly placed between two allowed storage areas such as the new fuel elevator and fuel transfer upender.

Fuel assembly in the fresh fuel elevator The use of the new fuel elevator (NFE) is described in detail in UFSAR Section 9.1.4. The NFE is primarily used to lower new fuel to a level from which the spent fuel bridge crane can move it to its final storage location in the spent fuel pool. A new assembly is placed in the NFE using the fuel storage building crane. The MTF for new fuel receipt would contain steps to move fuel from the NFE to the SFP; returning to the NFE for a second assembly prior to placing the first assembly in storage in the SFP would be a violation of the MTF. Infrequently, the new fuel elevator can be raised or lowered to support inspection and/or repair of new and irradiated fuel assemblies.

RAI 27 describes the normal and accident criticality analysis for use of the new fuel elevator.

Fuel assemblies raised on pedestals Holtec RAI 22 response discusses this potential by assuming 2 pedestals 40" in height separated by 2 fuel storage locations. Administrative controls would be applied to ensure that two fuel assemblies cannot come into close approach under normal operation; RAI 27 discusses the close approach and 3 assembly accident conditions.

7

0 Minor damage to cells Seabrook has experienced instances where a fuel assembly bottom nozzle has made contact with one of the angled lead-in funnels at the top of the storage racks resulting in a lead-in funnel bent out of its original geometry. The plant corrective action program is used to document such instances to assess the potential damage to the structure and initiate repair of the affected area.

This kind of minor damage would have no impact on the results of the criticality analysis.

Reconstitution of fuel assembly Reconstitution of a fuel assembly is decribed in detail in Holtec RAI 22 response. The fuel rod storage basket (FRSB) is analyzed in section 4.6.11 of HI-2114996 and Holtec's response to RAI

22. The movement of a reconstitued fuel assembly is a specific example of moving an individual fuel assembly with the spent fuel bridge crane and bounded by the normal and accident conditions analyzed. Movement of a single fuel rod during reconstitution is described in RAI 22.

Any accident conditions involving mislocation of a single rod are bounded by the assembly mislocation analysis.

The top nozzle, which is also the handling surface to move the assembly, must be removed to access the fuel rods within. While the top nozzle of a fuel assembly could be removed while the fuel assembly is in a SFP storage locaion, the last two times individual rods were removed from a fuel assembly the donor assembly was placed in the NFE location to allow work from the side of the pool in addition to the spent fuel bridge crane. This approach has the added benefit of separating the donor assembly from other fuel to prevent the potential for an FME event.

If this activity were to be performed in the SFP storage rack area, any fuel stored between the donor assembly and FRSB would be relocated to provide similar FME protecton. Where possible, additional assemblies around the donor assembly and FRSB would be moved to improve visability and FME controls.

Fuel rod inspection (ECT, visuals, etc)

An individual fuel rod may be moved for inspection. A typical arrangement is for the inspection equipment to be in a fixed location and the fuel rod to be moved in front of the inspection equipment. As with fuel reconstitution, the top nozzle of the donor assembly must be removed to access the individual fuel rods. The donor assembly cannot be moved until the top nozzle is 8

replaced. While the top nozzle of a fuel assembly could be removed while the fuel assembly is in a SFP storage location, traditionally when individual rods are removed for inspection from a fuel assembly the donor assembly was placed in the NFE location to allow work from the side of the pool in addition to the spent fuel bridge crane. This approach has the added benefit of separating the donor assembly from other fuel to prevent the potential for an FME event.

Movement of a single fuel rod is discussed in the Holtec RAI 22 response. Movement of only a single assembly or fuel rod at a time ensures that the fuel inspection activity normal operation does not result in a condition not bounded by the safety analysis. Any accident conditions involving mislocation of a single rod are bounded by the assembly mislocation analysis.

0 Storage of damaged fuel rods, fuel rod inserted in FRSB The fuel rod storage basket (FRSB) is analyzed in section 4.6.11 of HI-2114996 and Holtec's response to RAI 22. The FRSB contains 52 fixed vertical tubes in which a fuel rod may be inserted.

Specific examples of moving an assembly that are bounded by the single assembly evaluations:

Ultrasonic testing of fuel assembly to determine leaking rods For this evolution a single assembly is manipulated by the spent fuel bridge crane to allow ultrasonic examinaton of the the fuel assembly. The assembly may be partially inserted in a fuel storage location, or suspended anywhere in the SFP. The accident analyses for a mislocated single assembly bound all possible accident scenarios. Since the spent fuel bridge crane can only manipulate one assembly at a time, it is not possible to have two assemblies in close approach except under accident conditions.

Fuel assembly inspection For this evolution a single assembly is manipulated by the spent fuel bridge crane to allow visual inspection of the the fuel assembly. The assembly may be partially inserted in a fuel storage location, or suspended anywhere in the SFP. The accident analyses for a mislocated single assembly bound all possible accident scenarios. Since the spent fuel bridge crane can only manipulate one assembly at a time, it is not possible to have two assemblies in close approach except under accident conditions.

9

0 UT fuel assembly cleaning With the single chamber cleaner:

This evolution involves manipulating a single fuel assembly with the spent fuel bridge crane; the assembly remained on the handling tool connected to the bridge crane for the duration.

Ultimately this is a manipulation of a single assembly that is bounded by analyses for movement or mislocation of a single assembly.

With the dual-chamber UT cleaner:

Two assemblies can be present in the dual chamber UT cleaner separated by 28 inches center to center. It is not possible to place a third assembly between these two assemblies due to the structure of the cleaner and concrete walls on either side of the location that the cleaner is mounted; it is possible under accident conditions to place a third assembly inline with the two in the cleaner; however, the accident case described in RAI 27 assumes a smaller center to center distance than that possible around the cleaner.

Bottom nozzle inspections For this evolution a single assembly is manipulated by the spent fuel bridge crane to allow visual inspection of the the fuel assembly bottom nozzle. The assembly may be suspended anywhere in the SFP. The accident analyses for a mislocated single assembly bound all possible accident scenarios. Since the spent fuel bridge crane can only manipulate one assembly at a time, it is not possible to have two assemblies in close approach except under accident conditions.

Fuel assembly debris removal Fuel assembly debris removal is performed with an underwater camera and underwater tools.

Debris removal is normally performed in the cask area well away from other fuel or obstructions to provide additional room for removal tools and to prevent relocation of debris. Debris removal is typically performed by use of tri-nuke vacuum and tooling attached to long poles. Debris removal from a top nozzle could also be performed without moving the assembly from an approved storage location. If the assembly is moved to remove debris, the accident analyses for a mislocated single assembly bound all possible accident scenarios. Since the spent fuel bridge crane can only manipulate one assembly at a time, it is not possible to have two assemblies in close approach except under accident conditions.

10

0 Top Nozzle Separation visual inspection For this evolution a single assembly is manipulated by the spent fuel bridge crane to allow visual inspection of the the guidetubes and top nozzle of a fuel assembly. The assembly is partially withdrawn from its fuel storage location for the inspection. The accident analyses for a mislocated single assembly bound all possible accident scenarios. Since the spent fuel bridge crane can only manipulate one assembly at a time, it is not possible to have two assemblies in close approach except under accident conditions.

RAI 24

that [Ml Table 4.5.9 cites Reference 22 for the A 1 *1 R1 1 i+nm 10\\X Provide a reference supporting the

]. To avoid follow-on RAIs, provide the original reference rather than a reference to a chain of other references. The information will be used by NRC staff to confirm that the [

] are acceptable.

Response

The tolerances for the RCCAs provided to Holtec were not provided under a three-party proprietary agreement, that is, the actual Westinghouse source documents could not be transmitted to Holtec.

Therefore, the items were designated as assumptions. In fact the transmitted tolerances on dimensions and compositions were developed by providing conservative values (larger tolerances) when compared to the actual values in the drawings. The information utilized by Holtec therefore bounds the actual values. provides the requested reference that details the axial location of the RCCAs relative to the fuel assembly.

11

RAI 27c:

Confirm that the presence of RCCAs in Patterns B and C has been considered in the seismic analysis.

This is important from a criticality perspective to ensure that a seismic event will not lead to rack, RCCA or assembly changes that could increase reactivity.

Response

The seismic analysis was performed to bound any potential inserts placed into the storage cells.

Specifically, the bounding analysis was performed assuming 2.04 times the mass of an assembly placed into each storage cell. This is significantly larger than the weight of an assembly and an RCCA combined.

RAI 29

The following questions are related to the proposed technical specifications.

a. In Section 5.6.1.3.c there may be a potential conflict between the first and last sentence. The first sentence clearly says any of the identified assemblies may be stored in the first and second row away from the West Wall. The last sentence requires that all assemblies in the 2nd and 3rd rows must meet the requirements of Figure 5.6-2 and Table 5.6-1. Some of the assemblies listed in Table 5.6-2 do not currently meet the requirements for Pattern D. Consistent with the first sentence, the Operations staff may conclude that it is ok to store any of the assemblies in the second row, without regard for the pattern in rows 2 and 3.

If consistent with the intended changes, consider revising to:

Fuel assemblies listed in Table 5.6-2 may be stored in any position in the first row of the Region 1 and Region 2 storage cells closest to the West Wall. No RCCAs are required in the first row. All 2x2 assembly arrays, other than those in the first row closest to the West Wall in Region 2, shall comply with the requirements of Figures 5.6-1 and 5.6-2 and Table 5.6-1.

If this was not what was intended, revise the proposed technical specifications to remove the ambiguity.

b. Due to the reliance on RCCAs in the Patterns B and C, guidance should be provided concerning requirements for installation and removal of RCCAs and movement of assemblies to and from the storage rack. Revise Figure 5.6-2 of the proposed technical specifications to include a note that both permanent and transient configurations must meet the requirements of Figure 5.6-2 and Table 5.6-1.

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c. Definitions provided in Figures 5.6-1 and 5.6-2 include the phrase "or fuel of lower reactivity."

Insufficient definition or guidance is provided concerning determination of "fuel of lower reactivity." Since the burnup limits are already defined as minimum burnup limits, it is not clear why the definitions include the phrase "or fuel of lower reactivity." Describe how the determination of "fuel of lower reactivity" is to be made and revise the definitions provided in Figure 5.6-1 and 5.6-2 to clarify how the determination is to be made. Alternatively, remove the phrase "or fuel of lower reactivity" from the definitions.

d. Revise Note 3 under Table 5.6-1 to say "Fresh or irradiated fuel with an initial enrichment of 5.0 w/o U-235."

Response

a. The wording for this Technical Specification has been modified to state the requirements more succinctly. To address the NRC question, it should be noted that the previous wording stated that the fuel assemblies in rows 2 and 3 had to meet Figure 5.6-2 and Table 5.6-1 requirements. As pointed out in the question, since some fuel in row 2 does not meet Pattern D fuel burnups, the previous wording required configuring those 2x2 arrays as Pattern C or Pattern B as appropriate, resulting in the placement of RCCAs or empty cells in row 3 as part of those 2x2 arrays.

b.

Figure 5.6-2 of the proposed technical specifications has been revised to include a note that both permanent and transient configurations must meet the requirements of Figure 5.6-2 and Table 5.6-1.

c. The phrase fuel of lower reactivity was provided since the placement of fuel is described by Reactivity Class (RC). As defined in Table 5.6-1, note 1, Reactivity Classes are presented from High to Low, e.g., RC1 is the most reactive fuel and RC5 is the least reactive fuel. The phrase was added to provide a modifier on the definitions. It has been our experience that confusion can occur when a unique definition for the minimum burnup allowable for fuel placement is provided.

Verbatim compliance to the technical specifications could result in the determination that only a certain RC could be allowed in a given pattern.

To clarify this phrase, it will be modified from fuel of lower reactivity to list the applicable allowable Reactivity Classes.

d.

Note 3 has been revised as suggested.

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2.0 Description of Revised Technical Specification Chanqes As a consequence of the changes in the analysis, a revision to the TS submitted with LAR 11-04 and modified in Reference 3 is needed. The changes are summarized below with revised TS pages provided in Attachment 8.

Technical Specification 5.6.1.3c -- The proposed TS submitted with LAR 11-04 is as follows:

Fuel assemblies documented in Table 5.6-2 may be stored in any position in the two rows of storage cells closest to the West Wall. No RCCAs are required in the 2x2 arrays formed. There are no exceptions allowed to the requirements of Figure 5.6-2 and the requirements of Table 5.6-1 for fuel assemblies stored in the third row closest to the West Wall. Each 2x2 array formed by the fuel assemblies in the second and third row shall comply with the requirements of Figure 5.6-2 and the requirements of Table 5.6-1.

The proposed new wording is as follows:

2x2 arrays fully within the first two rows closest to the West Wall composed only of fuel assemblies documented in Table 5-6.2 or empty locations, are allowed without having to meet the storage requirements defined in Figure 5.6-2 and the requirements of Table 5.6-1.

Justification: The change is provided to more succinctly describe the requirements to be implemented. There is no change is how the fuel can be stored in rows 1 and 2 closest to the West Wall and no change in the need for all other fuel within Region 2 (including the 2x2 arrays defined by the second and third rows) to meet all the requirements of Figure 5.6-1 and Table 5.6-1.

Table 5.6.1 - Burnup Requirement for Each Reactivity Class:

The requirements for each Reactivity Class are changed based on the results of the new more conservative analysis. The changes in Table 5.6-1 are presented in Attachment 8.

Justification: The Table documents the burnup requirements for each Reactivity Class based on the revised analysis presented in Attachment 3. The major changes in the analysis are: a) consideration of the creep and fuel growth as a bias and bias uncertainty, and b) consideration of the eccentric position as a bias and bias uncertainty. The revised 14

analysis results in fuel that requires a higher burnup for placement for Reactivity Classes 2-5.

Table 5.6-1 Note 3 - Burnup Requirements for each Reactivity Class. The proposed TS submitted with LAR 11-04 is as follows:

Fresh un-irradiated fuel with an enrichment of < 5.0 w/o U-235 The proposed wording is as follows:

Fresh and irradiated fuel with an initial enrichment of < 5.0 w/o U-235 Justification: Note 3 is connected to Reactivity Class 1 which allows fuel placement of the highest reactivity fuel allowed in the pool, that is, fresh fuel with an enrichment up to 5.0 w/o U-235. However, there was no intention to require only fresh fuel to be placed into RC 1 locations. The new wording does not change the analysis assumptions since in all cases irradiated fuel would be less reactive than fresh 5.0 w/o fuel, it simply corrects the wording to allow irradiated fuel placement as originally planned.

Figure 5.6 Definition 1. The proposed TS submitted with LAR 11-04 is as follows:

Allowable pattern is Reactivity Class (RC) 1 or fuel of lower reactivity checkerboarded with RC 2 or fuel of lower reactivity. Minimum burnup for RC 1 and 2 is defined in Table 5.6-1 as a function of nominal initial central zone enrichment. Diagram is for illustration only.

The proposed wording is as follows:

Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 1, 2, 3, 4 or 5 checkerboarded with fuel assemblies that meet RC 2, 3, 4 or 5. Requirements for all RC are defined in Table 5.6-1. Diagram is for illustration only.

Justification: The wording change does not alter the requirements for placement or the intent of the TS. It more clearly defines what fuel of lower reactivity means in this context.

15

Figure 5.6 Definition 1. The proposed TS submitted with LAR 11-04 is as follows:

Allowable pattern is Reactivity Class (RC) 3 or fuel of lower reactivity in each of the 2x2 array locations combined with two RCCAs in any two locations within the 2x2 array.

Minimum burnup for RC 3 is defined in Table 5.6-1 as a function of nominal initial central zone enrichment. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

The proposed wording is as follows:

Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 3, 4 or 5 in each of the 2x2 array locations combined with two RCCAs in any two locations within the 2x2 array. Requirements for all RC are defined in Table 5.6-1. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

Justification: The wording change does not alter the requirements for placement or the intent of the TS. It more clearly defines what fuel of lower reactivity means in this context.

Figure 5.6 Definition 2. The proposed TS submitted with LAR 11-04 is as follows:

Allowable pattern is Reactivity Class (RC) 4 or fuel of lower reactivity in each of the 2x2 array locations combined with one RCCA placed anywhere in the 2x2 array. Minimum burnup for RC 4 is defined in Table 5.6-1 as a function of nominal initial central zone enrichment. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

The proposed wording is as follows:

Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 4 or 5 in each of the 2x2 array locations combined with one RCCA placed anywhere in the 2x2 array.

Requirements for all RC are defined in Table 5.6-1. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

16

Justification: The wording change does not alter the requirements for placement or the intent of the TS. It more clearly defines what fuel of lower reactivity means in this context.

Figure 5.6 Note 2. A new note is proposed to clarify that all configurations, including transient or temporary fuel placement must meet the Figure 5.6-2 requirements.

The proposed wording for Note 2 is as follows:

All permanent and transient configurations for fuel placed within Region 2 must meet the requirements of Figure 5.6-2 and Table 5.6-1.

Justification: This addition is provided to clearly document that all configurations must meet the TS requirements at all times. This wording is provided so that movement of a RCCA out of a required location is not performed without a compensating action (placement of another RCCA in the 2x2) prior to movement of the credited RCCA.

3.0 References

1. Seabrook Station License Amendment Request 11-04, "Changes to the Technical Specifications for New and Spent Fuel Storage, "SBK-L-1 1245, January 30, 2012.

2.

NRC letter to Seabrook Station, "Seabrook Station, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request 11-04, Change to Technical Specifications for New and Spent Fuel Storage," (TAC No. ME7946) March 30, 2012.

3.

Seabrook letter to NRC, "Supplement to LAR 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage," SBK-L-12099, May 10, 2012.

4.

NRC letter to Seabrook Station, "Seabrook Station, Unit No. 1 - Acceptance Letter Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage," (TAC No. ME8688) June 19, 2012.

5.

NRC letter to Seabrook Station, "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage," (TAC No. ME8688) July 24, 2012.

17

6. Seabrook letter to NRC, "Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage, "SBK-L-12199, September 20, 2012.

7.

NRC letter to Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage," (TAC No. ME8688) December 5, 2012.

18

ATTACHMENT 2 Holtec Proprietary Affidavit for RAI Responses

Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O LT E C Fax (856) 797-0909 INTERNATIONAL March 19, 2013 Mr. Emilio Fuentes NextEra Energy 700 Universe Blvd Juno Beach, FL 33408-0420 Document ID: 2064006

Subject:

Holtec Responses to RAI Regarding LAR 11-04 Deal Mr. Fuentes:

Holtec is pleased to approve tile release of the following information to the United States Nuclear Regulatory Commission (USNRC) and is requesting that these documents be withheld from public disclosure:

1. RRTI-2064-003, "Response to Request for Technical Information", Seabrook, RAI We require that you include the attached affidavit pursuant to I OCFR2.390 when submitting either of these documents to the USNRC.

Please do not hesitate to contact me at 856-797-0900 x 3685 if you have any questions.

4ly**JSely, Savit Sinha Project Manager Holtec International Cc:

Pankaj Chaudhary - Holtec Tom Fitzpatrick - Holtec Stefan Anton - Holtec Page lof 1

M EN HEM Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 H O LTEC Telephone (856) 797-0900 INTERNATIONAL Fax (856) 797-0909 Holtec International Document ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Savit Sinha, being duly sworn, depose and state as follows:

(1)

I have reviewed the information described in paragraph (22) which is sought to be withheld, and am authorized to apply for its withholding.

(2)

The information sought to be withheld is information provided with Holtec letter 2064006, specifically Holtec RRTI-2064-003, which contains Holtec Proprietary information and is appropriately marked as such.

(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 firom a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and sorne 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 Regulatoiw Commission, 975F2d871 (DC Cir. 1992),

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

1983).

I of 5

Holtec International Document ID 2064-AFFI-04 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 paragraph 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 regulatory provisions or proprietary 2 of 5

Holtec International DocumenIt ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 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.

3 of 5

Holtec International Document ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 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 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 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 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.

4 of 5

Holtec Internalionai Document ID 064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY

)

)

ss:

COUNTY OF BURLINGTON )

Mr. Savit Sinha, 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 19th day of March, 2013 avit Sinha Holtec International Subscribed and sworn before me this / C day ofl1_/..-,

2013.

day 25,2213 5 of 5

ATTACHMENT 4 Holtec Licensing Report Proprietary Affidavit

mmmmm HOLTEC INTERNATIONAL Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 Fax (856) 797-0909 March 19,2013 Mr. Emilio Fuentes NextEra Energy 700 Universe Blvd Juno Beach, FL 33408-0420 Document ID: 2064007

Subject:

Holtec Responses to RAI Regarding LAR 11-04

Dear Mr. Fuentes:

Holtec is pleased to approve tile release of the following information to the United States Nuclear Regulatory Commission (USNRC) and is requesting that these documents be withheld fiom public disclosure:

1. HI-2114996, "Licensing Report for Seabrook Spent Fuel Pool and New Fuel Vault Analyses" We require that you include the attached affidavit pursuant to I OCFR2.390 when submitting either of these documents to the USNRC.

Please do not hesitate to contact me at 856-797-0900 x 3685 if you have any questions.

Project Manager Holtec International Cc:

Pankal Chaudhary - Holtec Tom Fitzpatrick - Holtec Stefan Anton - Holtec Page lof 1

M EU MEM Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 HO LTEC Telephone (856) 797-0900 INTERNATIONAL Fax (856) 797-0909 Holtec International Document ID 2064-AFFI-05 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Savit Sinha, being duly sworn, depose and state as follows:

(1) 1 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 information provided with Holtec letter 2064007, specifically Holtec Report HI-2114996, which contains Holtec Proprietary information and is appropriately marked as such.

(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).

I of 5

Holtec International Document I D 2064-AFFI-04 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 cormnercial strategies of Holtec International, its customers, or its suppliers;

d.

Information which reveals aspects of past, present, or future Holtec International customner-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 paragraph 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 regulatory provisions or proprietary 2 of 5

Holtec International Document ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 infonnation 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 fr'om 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.

3 of 5

Holtec International Document ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 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 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 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 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.

4 of 5

Holtec International Document ID 2064-AFFI-04 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY

)

)

ss:

COUNTY OF BURLINGTON )

Mr. Savit Sinha, 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 1 9 th day of March, 2013

>Atnha Holtec International Subscribed and sworn before me this _

day of

-- 7 2013.

?=-'2&,2ir3 2'z~a ON&-<

5 of 5

Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: NF-NA-13-47 CAW-13-3645 March 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Supporting Figure for Response to RAI 15 of Seabrook LAR for New and Spent Fuel Storage (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3645 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by NextEra Energy.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3645, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Verytrl Au,

.ames A. Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3645 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit onl behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

6ames A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this i day of 7vT*.L*

2013 Notary Public COMMONWEALTH OF PENNSYLVANIA FI Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County L

MY commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW-13-3645 (1)

I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it fal Is in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3645 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c)

Its use 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 a similar product.

(d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f)

It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a)

The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c)

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3645 (d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e)

Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage, to the competition of those countries.

(f)

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii)

The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not bcen previously employed in the same original manner or method to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is contained in "Attachment 1 - Supporting Figure for Response to RAI 15" (Proprietary) for submittal to the Commission, being transmitted by NextEra Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of Seabrook's License Amendment Request, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a)

Assist customer in obtaining NRC review of their License Amendment Request.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.

COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

ATTACHMENT 7 Westinghouse Supporting Data for RAI 24

Westinghouse Non-Proprietary Class 3 0Westinghouse Westinghouse Electric Company Nuclear Fuel Columbia Fuel Site 5801 Bluff Rd Hopkins, South Carolina 29061 USA Mr. Jimmie Perryman Direct tel: 803 647 3694 Seabrook Fuel Project Engineer Direct fax: 803 647 2027 NextEra Energy e-mail: kerrrw@westinghouse.com 700 Universe Boulevard P.O. Box 14000 Juno Beach, Florida 33408-0420 Our ref: NF-NA-13-48 March 14, 2013 NEXTERA ENERGY SEABROOK Seabrook Station Transmittal of Seabrook Fuel / RCCA Interface Drawing

References:

I. Nuclear Fuel Fabrication and Related Services Contract between Florida Power and Light Company and Westinghouse Electric Company LLC dated September 12, 2003, as amended.

2.

"Design Interface procedure between FPL Energy Seabrook, LLC and Westinghouse Electric Company, LLC," Revision 0, dated April 23, 2004.

3. "Design Interface Exception Log, Revision 5," dated February 14, 2009.

4.

"Request for Seabrook Fuel/RCCA Interface Drawing", NF-13-066, dated February 5, 2013 (NF-NA-13-23).

5. "Revision I Design Verification List Package for Region 18 (NADQ)", NF-NA-12-11 Rev. I, dated March 2, 2012.

6.

"Transmittal of Seabrook Fuel/RCCA Interface Drawing", NF-NA-13-24, dated February 6, 2013.

7.

"Fuel Assembly /RCCA Interface Drawing Information for Seabrook" SFAD-13-8 Rev.l, dated March 14, 2013.

Dear Mr. Perryman,

Per your request, this transmits "Fuel Assembly/RCCA Interface Drawing Information for Seabrook",

(Reference 7). Revision 1 is issued to note that the information in the attached figure is NOT proprietary.

This document defines Seabrook fuel assembly (NADQ) with an inserted RCCA showing the relative axial positions of the active fuel stack and the RCCA absorber. This infonnation was extracted from the Seabrook Unil Cycle 16 Region 18 Design verification List (Reference 5). It should support your response for an NRC Request for Additional Information (RAI) regarding the Seabrook Spent Fuel Pool criticality analyses currently under review.

The information in this letter is transmitted in accordance with the above references and in accordance with the Westinghouse Quality Management System.

Electronically Approved Records are Authenticated in the Electronic Document Management System

©0 2013 Westinghouse Electric Company LLC All Rights Reserved

Westinghouse Non-Proprietary Class 3 Page 2 of 2 Our ref: NF-NA-13-48 March 14, 2013 Please let me know if you have any questions or if I can be of further assistance.

Sincerely, Electronically Approved Richard W. Kerr Project Manager Americas Region

Attachment:

(I page) cc:

C. O'Farrill G. Strussion W. Rosette P. Schueren D. Samara M. James J. Kabadi R. Rodriguez C. Ginsberg D. Huegel J. Akers L. Roy E. Malek Electronically Approved Records are Authenticated in the Electronic Document Management System

Westinghouse Non-Proprietary Class 3 Page A-I Our ref: NF-NA-13-48 March 14,2013 Plant Seabrook Unit 1 Region NADQ (ReglonIS)

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ATTACHMENT 8 Technical Specifications Revised Pages

INSERT 1 5.6 FUEL STORAGE CRITICALITY 5.6.1.1 The spent fuel storage racks are designed and shall be maintained with:

a.

A keff less than 1.0 when flooded with unborated water, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

b.

A keff less than or equal to 0.95 when flooded with water borated to 500 ppm, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

c.

A nominal 10.35 inch center-to-center distance between fuel assemblies placed in the storage racks.

5.6.1.2 The new fuel storage racks are designed and shall be maintained with:

a.

A keff equivalent to less than or equal to 0.95 when fully flooded with unborated water, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

b.

A keff equivalent to less than or equal to 0.98 if moderated by aqueous foam, which includes an allowance for biases and uncertainties as described in USFAR Chapter 9.

c.

At least a nominal 21 inch center-to-center distance between fuel assemblies placed in the storage racks with a nominal 33 inches center-to-center distance (east to west) between fuel assemblies in the center column and adjacent columns.

5.6.1.3 Fresh or irradiated fuel assemblies shall be stored in the spent fuel pool in compliance with the following:

a.

Any 2x2 array of Region I storage cells containing fuel shall comply with the storage pattern in Figure 5.6-1 and the requirements of Table 5.6-1. The reactivity ranks of fuel assemblies in the 2x2 array (rank determined using Table 5.6-1) shall be equal or less that defined for the 2x2 array.

b.

Any 2x2 array of Region 2 storage cells containing fuel shall comply with the storage requirements defined in Figure 5.6-2 and the requirements of Table 5.6-1 or with the allowable exception of evaluated assemblies stored on the periphery of Region 2 as defined in 5.6.1.3.c. The evaluated assemblies are listed in Table 5.6-2.

c.

2x2 arrays fully within the first two rows closest to the West Wall composed only of fuel assemblies documented in Table 5-6.2 or empty locations, are allowed without having to meet the storage requirements defined in Figure 5.6-2 and the requirements of Table 5.6-I.

d.

In addition to meeting the requirements defined in 5.6.1.3.a, fuel assemblies placed in Region 1 in the row adjacent to Region 2 shall continue the Region 2 patterns as defined in Figure 5.6-2 and shall meet the associated Region 2 reactivity class requirements.

e.

Any fuel assembly (with or without an RCCA) may be replaced by an empty water cell, non-fuel hardware or a fuel rod storage basket.

Table 5.6-1 BURNUP REQUIREMENTS FOR EACH REACTIVITY CLASS Bounding Polynomial Fits for Minimum Burnup Requirements See Notes 1, 2 and 3 for use of Table 5.6-1 Reactivity Cooling Class l Time Coefficient A(2)

Coefficient B Coefficient C RC I N/A N/A N/A N/A RC 2 N/A

-23.9486 7.4857 0.0000 Enrichment <3.6 w/o Enrichment > 3.6 w/o Coefficients Coefficients A

B C

A B

C 0 years

-46.4893 24.2342

-1.4689

-46.9639 23.9883

-1.4535 2.5 years

-45.3671 23.6083

-1.4430

-44.6422 22.7925

-1.3592 RC 3 5 years

-43.3626 22.3467

-1.2912

-42.8691 21.5892

-1.2031 10 years

-41.2729 21.3176

-1.2238

-40.4786 20.4229

-1.1214 15 years

-37.5450 19.2208

-0.9792

-36.5543 18.2164

-0.8607 20 years

-37.1511 19.1067

-0.9965

-35.8945 17.9317

-0.8518 0 years

-39.4986 24.8329

-1.4714

-35.5129 22.5425

-1.2508 2.5 years

-42.0614 26.2021

-1.7536

-31.0986 20.3032

-1.0635 RC 4 5 years

-43.5036 26.7220

-1.8423

-28.4171 18.8863

-0.9270 10 years

-40.2450 24.8908

-1.6792

-32.5900 20.6289

-1.1778 15 years

-39.4193 24.3389

-1.6482

-35.7271 22.0541

-1.3825 20 years

-38.0193 23.4289

-1.5482

-33.6429 20.7970

-1.2397 0 years

-18.6729 17.1776

-0.3238 15.4943 0.4484 1.5317 2.5 years

-22.0079 18.6718

-0.6196 27.0014

-5.0979 2.0587 5 years

-24.5664 19.9913

-0.8744 20.9571

-2.1108 1.6159 10 years

-25.9493 20.7089

-1.0982

-0.9900 8.4067 0.2667 15 years

-26.8021 21.1165

-1.2220

-13.6314 14.4202

-0.5032 20 years

-26.3500 20.8067

-1.2333

-20.7757 17.7162

-0.9238 SEABROOK - UNIT 1 5-11 Amendment No.

Table 5.6-1 (continued)

BURNUP REQUIREMENTS FOR EACH REACTIVITY CLASS Bounding Polynomial Fits for Minimum Burnup Requirements See Notes 1, 2 and 3 for use of Table 5.6-1 Notes

1. Reactivity Classes are presented from High to Low, e.g., RC 1 is most reactive fuel, RC 5 is least reactive fuel.

2. The specific minimum burnup (Bu) required for each fuel assembly for Reactivity Classes 2-5 are calculated from the following equation:

Bu = A + B x En + C x En' where the coefficients A, B and C are defined above for each Reactivity Class and cooling time (if applicable) and En is defined as the nominal initial central zone enrichment. Actual cooling time is rounded down to the nearest value, e.g., an assembly with an actual cooling time of 12 years would utilize the 10 year coefficients. No uncertainties should be applied when determining the minimum burnup requirement; all appropriate uncertainties have been included during the coefficient generation.

3. Fresh or irradiated fuel with an initial enrichment of< 5.0 w/o U-235.

SEABROOK-UNIT 1 5-12A Amendment No

ALLOWABLE STORAGE PATTERN REGION 1 (See Notes 1 and 2)

Pattern "A" See Definition 1 RC RC 1

2 RIC RIC 2

1 DEFINITIONS:

1. Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 1, 2, 3, 4, or 5 checkerboarded with fuel assemblies that meet RC 2, 3, 4, 5. Requirements for all RC are defined in Table 5.6-1. Diagram is for illustration only.

NOTES

1. There are no interface limitations within Region 1 between rack modules or within racks. Each cell is a part of up to four 2x2 arrays, and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

2.

Replacement of any fuel assembly by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable.

Figure 5.6-1 SEABROOK - UNIT I 5-14 Amendment No.

ALLOWABLE STORAGE PATTERNS REGION 2 (See Notes 1, 2)

Pattern "B" RCS3 RC 3 RCCA RCCA RC 3 RC 3 See Definition I Pattern "C" RCS4 RC 4 RC 4 RC 4 RCCA See Definition 2 Pattern "D" RCe RC5 RC 5 RC 5 See Definition 3 DEFINITIONS

1. Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 3, 4, or 5 in each of the 2x2 array locations combined with two RCCAs placed in any two locations within the 2x2 array. Requirements for all RC are defined in Table 5.6-1. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

2.

Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 4 or 5 in each of the 2x2 array locations with one RCCA placed anywhere in the 2x2 array. Requirements for all RC are defined in Table 5.6-1.

Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

3.

Allowable pattern is Reactivity Class (RC) 5 in each of the 2x2 array locations. Minimum burnup for RC 5 is defined in Table 5.6-1 as a function of nominal initial central zone enrichment and cooling time. Replacement of any fuel assembly by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable.

Diagram is for illustration only.

NOTES

1. The storage arrangements of fuel within a rack module may contain more than one pattern. There are no interface limitations within Region 2 between rack modules or within racks. Each cell is a part of up to four 2x2 arrays, and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

2.

All permanent and transient configurations for fuel placed within Region 2 must meet the requirements of Figure 5.6-2 and Table 5.6-I.

Figure 5.6-2 SEABROOK -UNIT 1 5-15 Amendment No.