ML17065A250

& Independent Spent Fuel Storage Installation (ISFSI) - Submittal of Response to Request for Referenced Information Related to RAIs 2-2, 3-5, and 3-8

ML17065A250
Person / Time
Site:	North Anna
Issue date:	02/28/2017
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML17065A248	List: ML17065A250 ML17065A251
References
Download: ML17065A250 (36)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 PROPRIETARY INFORMATION-WITHHOLD UNDER 10 CFR 2.390 February 28, 2017 U. S. Nuclear Regulatory Commission

• Serial No.17-059 Attention: Document Control Desk

• NRA/DEA RO Washington, DC 20555-0001 Docket No.: 72-16 License No.: SNM-2507 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION RESPONSE TO REQUEST FOR REFERENCED INFORMATION In a May 25, 2016 letter (Serial No.16-031), Virginia Electric and Power Company (Dominion) on behalf of itself and Old Dominion Electric Cooperative (ODEC) submitted an application for renewal of the North Anna Power Station (NAPS) site-specific Independent Spent Fuel Storage Installation (ISFSI) license SNM-2507 (Agency Documents Access and Management System (ADAMS) Accession No. ML16153A140).

The Nuclear Regulatory Commission (NRC) acknowledged acceptance of the license renewal application on July 21, 2016 (ADAMS Accession No. ML16207A104).

A Request for Additional Information (RAI) (ADAMS Accession No. ML16330A715) related to the application for renewal of the NAPS* site-specific ISFSI license was subsequently received on November 23, 2016 and the response submitted on January 20, 2017 (ADAMS Accession No. ML17025A128).

In an email dated February 2, 2017, the Nuclear Regulatory Commission (NRC) transmitted a request for Dominion to provide information that was referenced in the response to RAls 2-2, 3-5 and 3-8 related to the application for renewal of the NAPS site-specific ISFSI license dated January 20, 2017.

On February 15, 2017, a telecon was held between the NRC and Dominion to discuss the details of the requested reference information being provided. Based on the results of the telecon, Dominion is providing the following Attachments to this letter, as well as the three compact discs included as Enclosure 1, to the NRC with the requested information:

- Attachment 1 provides Dominion calculation NE-1311, Technical Report, "Evaluation of the TN-32 Cask with Increased Enrichment and Burnup Fuel for use at the North Anna Power Station Independent Spent Fuel Storage Installation," Rev. O tJf'./1551 l,,,.

Attachments 3 and 4 contain information that is being withheld from public disclosure.

under 10 CFR 2.390. Upon separation from Attachments 3 and 4 this letter is decontrolled.

Serial No.17-059 Docket No.: 72-16 Response to Request for Referenced Information Page 2 of 4

- Attachment 2 provides Dominion calculation PA-0181, "North Anna ISFSI Cask Surface, Perimeter Fence, Site Boundary, and Nearest Permanent Resident Dose Rates Based on the TN-32 Dry Storage Cask," Rev. 0 [NOTE: Dominion calculations only required a Preparer and Reviewer signature in 2001]

- Attachment 3 provides AREVA calculation 503065-0501, 'TN-32 Cask Combustible Gas Generation in Neutron Shield Resin," Rev. 0 (proprietary)

- Attachment 4 provides AREVA calculation 503065-0500, "Neutron Fluence, Gamma Exposure and Dose Rate Calculation for North Anna Power Station TLAA Phase 2," Rev. 0 (proprietary)

- Attachment 5 provides Dominion calculation CE-1399, "Evaluation of NAPS As-Built ISFSI Concrete Storage Pad," Rev. 0

- Attachment 6 provides Dominion calculation CE-1399, Rev. 0, Addendum #OOA, "Evaluation of Ageing Effects of Concrete Cask Drop & Tipover Events," Rev. 0

- Attachment 7 contains the Affidavit of AREVA TN Americas LLC for withholding proprietary Information from public disclosure.

- Enclosure 1 contains three compact discs which contents include the output files from calculation PA-0181, Rev. 0.

Since Attachments 3 and 4 contain information proprietary to AREVA TN Americas LLC, they are supported by an affidavit signed by the owner of the information. The affidavit 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 2.390.

Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.

Because of the amount of proprietary information included in the documents in Attachments 3 and 4, a non-proprietary version of the documents would be of no value to the public and has not been prepared.

Should you have any questions in regard to this submittal, please contact Ms. Diane E.

Aitken at (804) 273-2694.

Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None

Serial No.17-059 Docket No.: 72-16 Response to Request for Referenced Information Page 3 of 4 Attachments:

1. Dominion calculation NE-1311, Technical Report, "Evaluation of the TN-32 Cask with Increased Enrichment and Burnup Fuel for use at the North Anna Power Station Independent Spent Fuel Storage Installation," Rev. 0

2. Dominion calculation PA-0181, "North Anna ISFSI Cask Surface, Perimeter Fence, Site Boundary, and Nearest Permanent Resident Dose Rates Based on the TN-32 Dry Storage Cask," Rev. 0

3. AREVA calculation 503065-0501, "TN-32 Cask Combustible Gas Generation in Neutron Shield Resin," Rev. 0 (proprietary)

4. AREVA calculation 503065-0500, "Neutron Fluence, Gamma Exposure and Dose Rate Calculation for North Anna Power Station TLAA Phase 2," Rev. 0 (proprietary)

5. Dominion calculation CE-1399, "Evaluation of NAPS As-Built ISFSI Concrete Storage Pad," Rev. 0

6. Dominion calculation CE-1399, Addendum #OOA, "Evaluation of Ageing Effects of Concrete Cask Drop & Tipover Events," Rev. 0

7. Affidavit of AREVA TN Americas LLC for withholding proprietary Information from public disclosure

Enclosure:

1. Three compact discs which contents include the output files from calculation PA-0181, Rev. 0 cc: (without Attachments or Enclosure)

U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Ms. Kristina Banovac Project Manager: NAPS ISFSI LRA U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop 4 B72 11545 Rockville Pike Rockville, Maryland 20852-2738 Mr. John N. Nguyen Senior Project Manager: NAPS ISFSI U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop T4834 11545 Rockville Pike Rockville, Maryland 20852-2738

Serial No.17-059 Docket No.: 72-16 Response to Request for Referenced Information Page 4 of 4 cc: Mr. J. E. Reasor, Jr Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, VA 23060 Mr. R. McWhorter Vice President of Operations & Asset Management Old Dominion Electric Cooperative 4201 Dominion Blvd Glen Allen, Virginia 23060 State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 NRC Senior Resident Inspector North Anna Power Station

Serial No.17-059 Docket No.: 72-16 Response to Request for Referenced Information ATTACHMENT 7 AFFIDAVIT OF AREVA TN AMERICAS LLC FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Virginia Electric and Power Company (Dominion)

North Anna Power Station Independent Spent Fuel Storage Installation

A AREVA TN Americas LLC Feb. 10,2017 E-47624 Rev. 0 Jason Mantzouranis, PM Suite 300 7135 Minstrel Way Columbia, MD 21045

Subject:

Release of TN Documents for License Renewal Amendment to License SNMM2507, Docket No. 72M16 *

Dear Jason:

This correspondence is written to provide select design documents in support of the subject License Renewal Amendment (LRA). These documents are in support of an extension of the 10 CFR Part 72 license for the storage of spent nuclear fuel at the North Anna Power Station. The documents requested are being transmitted to Dominion Power under proprietary agreement and will, subsequently, be forwarded to the NRC via affidavit pursuant to 10 CFR 2.390.

The specific AREVA TN Americas documents to be transmitted are identified as follows:

• Calculation 503065-0500 Rev. O

• Calculation 503065-0501 Rev. O Please forward controlled copies of these documents to Dominion Power under proprietary agreement and request return correspondence signifying receipt of said documents.

If you or anyone at Dominion Power has questions on information contained herein, please contact me and I will strive to resolve the issue as soon as possible.

Sincerely, Tom Edwards Design Project Engineer Attachments: (1) -Affidavit Page 1 of 2 TN AMERICAS LLC 71 35 Minstrel Way, Suite 300, Columbia, Maryland 21 045 Tel.: 410 910 6900- Fax: 410 910 6902 - www.us.areva.com/AREVATN

A

.AREVA TN Americas LLC cc: Phil Lozmack (PM) Rod Gooch (PM)

Ajay Verma (QAS) John McEntire (PM)

Dennis Williford (Licensing) Jim Williams (Dominion Power)

Lauren Naggs (DCA) Project File 593065 - Outgoing Correspondence Page2 of2 TN AMERICAS LLC 71 36 Minstrel Way, Suite 300, Columbia, Maryland 21045 Tel.: 410 910 6900- Fax: 410 910 6902 -www.us,areva.com/AREVATN

Attachment to Letter E-47624 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State of Maryland ) SS.

County of Howard )

I, Jayant Bondre, depose and say that I am Chief Technology Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is listed below:

• Calculation No. 503065-0500 Revision 0

• Calculation No. 503065-0501 Revision 0 This information has been appropriately designated as proprieta.iy.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged, or as confidential commercial or fina.ncial information.

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, included in the above referenced documents, should be withheld.

1) The information sought to be withheld from public disclosure involves time-limited aging analyses (neutron fluence, gamma exposure and dose rates, a.i.1d combustible gas generation in the neutron shield) associated with the TN-32 dry spent :ti.rel storage cask, which are owned and have been held in confidence by TN Americas LLC.

2) The information is of a type customarily held in confidence by TN Americas LLC and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of infonnation customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC because the information consists of descriptions of the methodology and time-limited aging analyses for components of the TN-32 dry spent fuel storage cask, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN Americas LLC's product, and avoid developing sinlilar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

~

J ayant Bondre Chief Technology Officer, TN Americas LLC Subscribed and sworn before me this 13th day ofFebruary, 2017.

IL--~*

RONDA JONES

~OTARV PUBLIC STATE OF MARVLANP 1>,1y Commission Expires October 16, 2019 Not~Public My Commission Expires ___10~~

Page 1of1

Serial No.17-059 Docket No.: 72-16 Response to Request for Referenced Information ENCLOSURE 1 THREE COMPACT DISCS WHICH CONTENTS INCLUDE THE OUTPUT FILES FROM CALCULATION PA-0181, REV. 0 Virginia Electric and Power Company (Dominion)

North Anna Power Station Independent Spent Fuel Storage Installation