ML14052A053

Project Units 1 & 2, Submittal of Casa Grande Code & Analyses for Risk-Informed GSI-191 Licensing Application

ML14052A053
Person / Time
Site:	South Texas
Issue date:	02/13/2014
From:	Powell G T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14052A110	List: ML14052A053 NOC-AE-14003081, STP-Specific Casa Grande Inputs CASA01 JT4, CASA09 JT4, CASA22 JT4, CASA26 JT4, & CASA43 JT4
References
NOC-AE-14003081, TAC MF2400, TAC MF2401, TAC MF2402, TAC MF2403, TAC MF2404, TAC MF2405, TAC MF2406, TAC MF2407, TAC MF2409
Download: ML14052A053 (7)

Text

Contents of Attachments 2 -6 and 12 should be withheld from public disclosure in accordance withlOCFR2.390 Nuclear Operating Company South TeCAs Pro/ect Electric Generating Station P.O. Bx 282 Mdsavrth, 77483 -February 13, 2014 NOC-AE-14003081 D43.02 10 CFR 2.390 Attention:

Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and 50-499 Submittal of CASA Grande Code and Analyses for STP's Risk-Informed GSI- 191 Licensing Application (TAC NOS. MF2400, MF2401, MF2402, MF2403, MF2404. MF2405, MF2406. MF2407, MF2408, AND MF2409)

References:

1. Letter, G. T. Powell, STPNOC, to NRC Document Control Desk, "Supplement 1 to Revised STP Pilot Submittal and Requests for Exemptions and License Amendment for a Risk-Informed Approach to Resolving Generic Safety Issue (GSI)-191", November 13, 2013, NOC-AE-13003043, ML13323A183

2. Los Alamos National Laboratory (LANL) inter-agency transfers of CASA Grande to NRC and Southwest Research (SWRI): NRC -License Tracking Number 14-N03329, SWRI (Center for Nuclear Waste Regulatory Analyses)

-License Tracking Number 14-N03333 This submittal documents the transmittal to the NRC of the CASA Grande computer code and input used in Reference 1.The CASA Grande code and non-proprietary input and setup files were transmitted separately by Los Alamos National Laboratory (LANL) in Reference 2 via an interagency transfer.The attachments to this submittal provide the South Texas Project (STP) -specific input files for the staff s review and use. Certain information in attachments 2 -6 and 12 is proprietary to Alion and should be withheld from public disclosure in accordance with I OCFR2.390.

The Alion affidavit for withholding is included with the attachments.

Non-proprietary versions of attachments 2 -6 are also provided as attachments 7 -11.STI: 33816285 NOC-AE-14003081 Page 2 of 3 Attachment 12 is a proprietary CD containing the input described in attachments 2 -6 that can be run in CASA Grande so that the input would not require manual entry. The contents of the CD should be withheld from public disclosure.

There is no need for a non-proprietary version of the CD since attachments 7 -11 provide the redacted version.Alion identified that in the debris properties table for the attached cases, the diameters of SiO2 and TiO2 are improperly reversed.

This typographical error in the input was evaluated and it was determined that the effect is very small and causes the analysis result to be slightly more conservative.

Correcting the error would cause the analysis result to be slightly less conservative, so STP elected not to change the input file at this time. Its resolution is being tracked in the Corrective Action Program.There are no commitments in this submittal.

If there are any questions regarding this request, please contact Wayne Harrison at (361) 972-4745 or me at (361) 972-7566.I declare under penalty of perjury that the foregoing is true and correct.Executed on: Fr,,,.,2i 13 ZO04 G. T. Powell Site Vice President awh Attachments

1. Alion Affidavit for Withholding

2. STP-specific CASA Grande Input CASA01 JT4 -Proprietary Version 3. STP-specific CASA Grande Input CASA09 JT4 -Proprietary Version 4. STP-specific CASA Grande Input CASA22 JT4 -Proprietary Version 5. STP-specific CASA Grande Input CASA26 JT4 -Proprietary Version 6. STP-specific CASA Grande Input CASA43 JT4 -Proprietary Version 7. STP-specific CASA Grande Input CASAO1 JT4 -Non-Proprietary Version 8. STP-specific CASA Grande Input CASA09 JT4 -Non-Proprietary Version 9. STP-specific CASA Grande Input CASA22 JT4 -Non-Proprietary Version 10. STP-specific CASA Grande Input CASA26 JT4 -Non-Proprietary Version 11. STP-specific CASA Grande Input CASA43 JT4 -Non-Proprietary Version 12. Proprietary CD with Attachments 2 -6 NOC-AE-14003081 Page 3 of 3 cc: (paper copy)(electronic copy)** Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 8 B 1)11555 Rockville Pike Rockville, MD 20852** NRC Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77483* Jim Collins City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 A. H. Guttennan, Esquire Morgan, Lewis & Bockius LLP Balwant K. Singal Michael Markley John Stang U. S. Nuclear Regulatory Commission

• John Ragan* Chuis O'Hara* Jim von Suskil NRG South Texas LP* Kevin Pollo* Richard Pena* L.D. Blaylock City Public Service Peter Nemeth Crain Caton & James, P.C.* C. Mele City of Austin* Richard A. Ratliff Texas Department of State Health Services* Robert Free Texas Department of State Health Services* Without proprietary Attachments 2 -6, 12** Without proprietary CD Attachment 12 Attaclunent 1 NOC-AE- 14003081 Attachment 1 Alion Application for Withholding AI I 0 N ALION Science & Technology SCIENCE AND TECH1NOL.OGY AFFIDAVIT I, Megan A. Stachowiak, state as follows: (1) I am Division Manager, Nuclear Services, ALION Science & Technology

("Alion")

and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in ALION Science & Technology report "Insulation Debris Size Distribution for use in GSI-191 Resolution," ALION-REP-ALION-2806-01, dated May 20., 2009. Information from this report was used to support the South Texas Project licensing submittal, and it appears in CASA Grande input files that are being submitted to the NRC for review. A portioned version of the input files denoting the proprietary information is being provided.

Additionally, redacted versions of the input files are being provided.(3) In making this application for withholding of proprietary information of which it is the owner, Alion 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 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought 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 Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).(4) Some examples of categories of information which fit into the definition of proprietary information are: a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Alion's competitors without license from Alion 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 aspects of past, present, or future Alion customer-funded development plans and programs, resulting in potential products to Alion;d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

Pagel1 of 3 AMASAf~fidavit A LION O SCIENCE AND TECHNOLOGY The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4) a, and (4) b., above.(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence.

The information is of a sort customarily held in confidence by Alion, 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 Alion, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.

Access to such documents within Alion 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 their delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside Alion 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 document identified in paragraph (2), above, is classified as proprietary because it contains "know-how" and "unique data" developed by Alion within our research and development programs.

The development of this document, supporting methods and data constitutes a major Alion asset in this current market.(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Alion's competitive position and foreclose or reduce the availability of profit-making opportunities.

The information is part of Alion's comprehensive BWR/PWR GSI-191 analysis base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and experimental methodology and includes development of the expertise to determine and apply the appropriate evaluation process.The research, development, engineering, analytical and experimental costs comprise a substantial investment of time and money by Alion.Page 2 of 3 MAS Affidavit ALION SCIENCE AND TECHNOLOGY 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.

Alion's competitive advantage will be lost if its competitors are able to use the results of the Alion 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 Alion 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 Alion of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.Executed on this 10th day of February 2014.Megan A. Stachowiak Division Manager, Nuclear Services ALION Science & Technology Page 3 of 3 PA'L4S Affidavit