ML18155A413
| ML18155A413 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 05/25/2018 |
| From: | Tomlinson J Holtec |
| To: | Cuadrado J Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML18155A413 (12) | |
Text
HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 INTERNATIONAL May 25, 2017 Mr. Jose Cuadrado, Project Manager Division of Spent Fuel Management Office ofNuclear Material Safety and Safeguards Docket Number: 72-1051
Subject:
Reference:
Mr. Cuadrado:
Holtec International HI-STORE CIS (Consolidated Interim Storage Facility)
License Application Responses to Requests for Supplemental Information
[1]
NRC Letter, "Holtec International's Application for Specific Independent Spent Fuel Storage Installation License for the HI-STORE Consolidated Interim Storage Facility for Spent Nuclear Fuel-First Request for Additional Information, Part 1"," from J. Cuadrado (NRC) to J. Tomlinson (Holtec) dated March 28, 2017
[2]
Holtec Letter 5025024, "Holtec International HI-STORE CIS (Consolidated Interim Storage Facility) License Application Responses to Requests for Supplemental Information," from J.Tomlinson (Holtec) to J.
Cuadrado (NRC), dated May 24, 2018 Holtec is pleased to submit responses to the staff s requests for additional information (RAis)
[Reference 1] on the HI-STORE Consolidated Storage Application. This letter provides Attachments 2 and 3, which are the revised proprietary and nonproprietary versions ofthe HI-STORE SAR in response to the RAis. The previous submittal letter contained an attachment with only the changed pages ofthe HI-STORE SAR. contains the responses to the RAis. Attachment 2 and 3 contain the proprietary and nonproprietary version ofthe HI-STORE SAR, with all changes shown in red text.
Attachments 4 contains the supporting report for the RAI response. Since Attachments 2 and 4 are considered proprietary, an affidavit pursuant to 1 OCFR2.390 is included as Attachment 5, requesting that this information be withheld from public disclosure.
If you have any questions, please contact me atj.tomlinson@holtec.com or (856) 797-0900 ext.
3765.
Sincerely, Document 1D 5025025 Page 1 of2
HOLTEC INTERNATIONAL J oyce T omlinson Adjunct Licensing Manager Holtec Intemational Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Cc:
(letter only, not attachments, via email)
John McKirgan (NRC)
Jose Cuadrado (NRC)
Attachments: : Responses to Requests for Additional lnformation - Non-Proprietary : HI-2167374 HI-STORE CIS SAR Rev OC-Proprietary : HI-2167374 HI-STORE CIS SAR Rev OC-Non-proprietary : HI-2188143, HI-STORE Bearing Capacity and Settlement Calculations-Proprietary : Affidavit Pursuant to 10CFR2.390 Document 1D 5025025 Page 2 of2
Document ID 5025025 Safety Analysis Report (SAR), Chapter 2- "Site Characteristics" RAI 2 Provide an assessment of the annual hazard to the proposed CIS Facility from any flight-related activities at nearby airports and aircraft flying through the nearby airways (e.g.,
IR 192/194, IR 128/180, V291, and V102), as given in SAR Rev. OB Section 2.2.3 Air Transportation.
The assessment should consider, at a minimum, the following flight-related information:
a) Any holding pattern close to the proposed site associated with nearby airports; b) The distance of the proposed site of the CIS Facility from each nearby airway (e.g., centerline or edge of the airway) based on a reliable source (e.g., Federal Aviation Administration);
c) The width of each airway near the proposed CIS Facility; d) The annual number of transits by each type of civilian and commercial aircraft through each of the nearby airway; e) The types of military aircraft traversing the nearby airways and their flight-related activities while in the vicinity of the proposed site (e.g., normal and special flight mode-related activities);
f) Any ordnance carried onboard any military aircraft while traversing these airways, including hung ordnance; g) The effective area for each of the important to safety structures at the proposed facility, taking into account the footprint area of the structures, the shadow area, and the skid area of the structures for each type of aircraft with specific crash-related characteristics, and; h) The historical crash rate for each type of aircraft in a particular flight phase and in a particular enroute flight mode (i.e., normal or special) for a military aircraft.
The assessment should provide the cumulative annual number of aircraft crashes at the proposed facility from all flight-related activities, and the potential consequences from onboard ordnance, if any, to the proposed facility, after considering the above information.
Alternatively, the applicant may use alternative approaches to assess the flight-related activities near the proposed CIS Facility and estimate the annual aircraft crash hazard with the associated justifications.
This information is necessary to determine compliance with 10 CFR 72.24(a), 72.90(a) through (d), 72.94, and 72.98.
Document ID 5025025 Holtec Response:
Holtec evaluated the annual aircraft hazard using a probabilistic assessment of flight related activities near the proposed CIS Facility. NUREG-0800 Section 3.5.1.6, Aircraft Hazards, was used as guidance for the basis of the probabilistic assessment. All nearby air traffic infrastructure has been identified including airports, holding and approach patterns, federal airways, Military Training Routes (MTRs), and Military Operation Areas (MOAs) as well as their relevant attributes. The Acceptance Criteria listed in NUREG-0800 Section 3.5.1.6 state that all requirements are met if the probability of an aircraft crash is less than an order of magnitude of 10-7 per year. It also provides criteria, which if met, specify that the probability can be considered less than an order of magnitude of 10-7 by inspection. These criteria will hereby be referred to as screening criteria.
Each of the nearby airports, holding or approach patterns, federal airways and MOAs pass the screening criteria by inspection and are considered to be negligible hazards. Of the four (two sets of two) nearby MTRs, IR-192/194 meet the screening criteria and are therefore considered negligible hazards, as the probability of a crash is less than 10-7 by inspection. IR-128/180 passes directly above the proposed CIS site and does not pass by inspection.
Further evaluation of IR-128/180 was performed to determine the potential hazard of this flight path. Following the guidance of the NUREG-0800 Section 3.5.1.6 equation for airway crash probability, the flight density on IR-128/180 would have to be greater than 1011 flights per year in order for the probability to be greater than 10-7. Dyess Air Force Base, who controls this MTR has stated they do not use the portion of IR-128/180 within 5 miles of the CIS Facility and do not plan to use it in the future. Therefore, it is reasonable to assume that the flight density will remain less than 1011 flights per year and the probability of a crash will remain less than 10-7.
Since the probability of a crash will remain less than 10-7, the route is a negligible hazard.
Although this information was verbally received, the lead airspace analyst at Air Force Headquarters (AF/A3TI) in the Pentagon is gathering the data as requested in this RAI and will formally transmit it to Holtec International shortly.
By inspection and probabilistic assessment, the annual aircraft crash hazard is determined to be a negligible hazard.
Chapter 2 Section 2.2.3 of the SAR has been revised to include a probabilistic assessment of the aircraft crash hazard at the CIS Facility. Figures 2.2.6 and 2.2.7 as well as Tables 2.2.4 through 2.2.9 were added to support these descriptions.
RAI 2 Provide assessments, using site-measured geotechnical properties, to demonstrate that the soils at the subgrade and under-grade of the storage pads and the Canister Transfer Facility (CTF) would be able to withstand the loading assumed in the certification of the HI-STORM UMAX Canister Storage System. The assessments should provide, at a minimum, the following information:
- 1. Information and analyses to estimate the bearing capacity of the soils at the subgrade
Document ID 5025025 and under-grade of the storage pads and the CTF. Specifically, provide a description of the methodologies selected, the site-measured geotechnical property data used, and the effects of any spatial variation of the in-situ geotechnical properties on the estimated bearing capacity. The analyses should demonstrate that the "subgrade and under-grade soil properties at the HI-STORE CIS site are uniformly better than those assumed for the general certification of the HI-STORM UMAX system," as stated in SAR Rev. 08, Section 4.3.2.1, "Structural."
- 2. Information and analyses to estimate the immediate and the long-term settlement of the soils at the subgrade and under-grade of the storage pads and the CTF.
Specifically, provide a description of the methodologies selected, the site-measured geotechnical property data used, and the effects of any spatial variation of the in-situ geotechnical properties on the estimated immediate and long-term settlement. The analyses should demonstrate that the estimated immediate and long-term settlements at the storage pad area and the CTF, including any differential settlement, would not exceed the assumed settlements in the certification of the HI-STORM UMAX, as discussed in SAR Rev. 08, Section 4.3.2.1, "Structural."
- 3. A description of the piling design envisioned to achieve the equivalent stiffness of Space C material, as stated in SAR Rev. 08, Table 4.3.3, which specifies that Space C "[...]
Holtec Response:
- 1. Holtec Report HI-2188143, Revision 0, added to Chapter 19 as reference 4.3.5, provides the bearing capacity and settlement calculations and methodologies. The soil under the UMAX ISFSI has allowable bearing capacities of 170 ksf and 255 ksf for static and seismic loading conditions, respectively. The soil under the CTF has allowable bearing capacities of 89 ksf and 133 ksf for static and seismic loading conditions, respectively.
These allowable bearing capacities are calculated using conservative parameters and assumptions. The allowable bearing capacities are greater than the computed bearing pressures under static and seismic loading conditions.
- 2. Holtec Report HI-2188143, Revision 0, added to Chapter 19 as reference 4.3.5, provides the bearing capacity and settlement calculations and methodologies. Elastic/immediate settlement and long-term settlement will occur under the UMAX ISFSI and Canister Transfer Facility (CTF). There is no restraining value associated with elastic settlement for either system per the HI-STORE FSAR or the UMAX FSAR. The values of 3.931 inches and 0.376 inches of elastic settlement for UMAX and CTF, respectively, are reasonable considering the size of the UMAX field that will be constructed. The UMAX FSAR states the maximum long-term permissible settlement of the SFP is 0.2 inches.
The calculated long term settlement for the UMAX ISFSI is 0.074 inches, therefore the requirement is met. A The calculated long-term settlement for the CTF is 0.047 inches,
Document ID 5025025 Although there is no requirement for the CTF, the 0.047 inches of long term settlement is small and can be considered negligible for the system.
- 3. Geotechnical explorations and evaluations revealed/confirmed that the HI-STORE CIS Site Value for strain compatible effective shear wave velocity in Space C (~1,000 ft/sec minimum) is greater than the HI-STORM Generic License Value (485 ft/sec minimum).
Therefore, pilings are not needed for support of the UMAX system and the language has been removed from Table 4.3.3.
- 4. Section 2.6.6 has been added to Chapter 2 to include the following information about the excavation and construction process. During the construction of Phase 1 of the HI-STORE CISF, there will be multiple areas where excavation will be required to accommodate and install the underground facilities; specifically, the Canister Transfer Facilities (CTF) which are located in the Cask Transfer Building (CTB), and the UMAX field. In both cases, the expected total excavation depth is approximately twenty-five (25) feet.
According to the geotechnical borings, there are two layers of subsurface material that will be encountered during construction excavations. The native Caliche layer, which is approximately 12 feet in depth from top of existing grade, and the native residual soil layer, which makes up approximately 13 feet of depth for the remaining required excavation depth for site facilities. In no instance is it expected that construction excavations will encounter the native Chinle layer.
In order to accommodate construction vehicle access and maintain industry wide safety standards, it is expected that construction practices will utilize a minimum 1:1 slope around the extents of the excavation pits. This method will create ~124,000 cubic yards (CY) of caliche spoils and ~121,500 CY of residual soil spoils; some of which (~24,000 CY) will be utilized to backfill the excavation area. The residual soil spoils will be utilized for the backfill material as it meets the minimum density and shear wave velocity requirements for Space B, referenced in Figure 4.3.1.
Once the areas have been excavated, the supporting soil will be prepared to receive the reinforced concrete Support Foundation Pad (SFP). The residual soil surfaces shall be proof rolled by a heavy vibrating compactor, prior to the placement of compacted fill or foundations. Careful observation shall be made by a professional engineer licensed in New Mexico or their approved representative during proof rolling in order to identify any areas of soft, yielding soils that may require over-excavation and replacement. Once the subsurface has been prepared and compacted, the supporting residual soil fill (Space C) shall be confirmed to have reached a compaction of 95 percent (minimum) of the modified Proctor maximum dry density (in accordance with ASTM D1557). The compaction should be conducted at or close to the optimum moisture content indicated by the modified Proctor test procedure (ASTM D1557).
Upon completion of subgrade preparation/compaction, placement of the reinforced concrete Support Foundation Pad (SFP) and UMAX Cavity Enclosure Containers
Document ID 5025025 (CECs), backfilling of Spaces A and B (Figure 4.3.1) will commence. Space A will consist of a Controlled Low Strength Material (CLSM) or lean concrete that has a minimum compressive strength and density of 1,000 psi and 120 pcf, respectively, as referenced in Table 4.3.3. Since the backfilling process is iterative, as the fill materials are brought back up to finished grade, the sloped areas of the excavation pit that make up Space B of the UMAX lateral subgrade, will be composed of the aforementioned residual soil. Again, it is expected that for Phase 1 of the HI-STORE CISF, and all subsequent phases, ~24,000 CY of this residual soil will be required to fill out the Space B portion of the excavated area.
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document 1D 5025025 Non-Proprietary Attachment 5 AFFIDA VIT PURSUANT TO 10 CFR 2.390 I, Stefan Anton, being duly swom, depose and state as follows:
(1)
I have reviewed the information described in paragraph (1) which is sought to be withheld, and I am authorized to apply for its withholding.
(2)
The information sought to be withheld is provided in Attachments 2 and 4 to Holtec Letter 5025025, which contains Holtec Proprietary Information.
(3)
In making this application for withholding of proprietary information of which it is the owner, Holtec Intemational 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)(l) 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).
1 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5025025 Non-Proprietary Attachment 5 AFFIDAVIT PURSUANT TO 10 CFR 2.390 2 of 5 (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 paragraphs 4.c 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 agreements which provide for
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document 1D 5025025 Non-Proprietary Attachment 5 AFFIDA VIT PURSUANT TO 10 CFR 2.390 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 Intemational is limited on a "need to know" basis.
(7)
The procedure for approval of extemal release of such a document typically requires review by the staff manager, project manager, principa! 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 Intemational 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 Intemational at a significant cost to Holtec Intemational. 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 Intemational's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec Intemational 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 lllJUry.
3 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5025025 Non-Proprietary Attachment 5 AFFIDAVIT PURSUANT TO 10 CFR 2.390 4 of 5 (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.
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document 1D 5025025 Non-Proprietary Attachment 5 AFFIDA VIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY COUNTY OF CAMDEN
)
)
)
ss:
Stefan Anton, being duly swom, deposes and says:
That she has read the foregoing affidavit and the matters stated therein are true and correct to the best ofher knowledge, information, and belief.
Executed at Camden, New Jersey, this 25th day ofMay 2018.
~Qk-Stefan Anton Vice President Engineering Holtec Intemational Subscribed and swom before me this 25th day ofMay, 2018.
LENA ANN OLESIEWICZ NOTARY PUBUC Of NEW JEFISEY Commlsslon Explras 11 /2612019 5 of5