ML19092A189
| ML19092A189 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 03/20/2019 |
| From: | Tomlinson J Holtec |
| To: | John Mckirgan Division of Spent Fuel Management |
| Shared Package | |
| ML19092A192 | List: |
| References | |
| 5014867 | |
| Download: ML19092A189 (9) | |
Text
Holtec Technology Campus, 1 Holtec Blvd, Camden, N~ 08104 HOLTEC INTERNATIONAL March 20, 2019 Mr. John McKirgan Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 72-1014, Certificate of Compliance (CoC) No. 1014 Telephone (856) 797-0900 Fax (856) 797-0909
Subject:
HI-STORM 100 Multipurpose Canister Storage System Amendment 15 Request
Dear Mr. McKirgan:
We request DSFM's review of LAR#15 for our HI-STORM 100 system which makes much needed changes to the CoC to serve existing users of the HI-STORM system. These changes include the addition of an advanced HI-STORM overpack model, revised HI-TRAC design, MPC-32M fuel canister, three additional fuel types, and addition of an optional ancillary cooling system.
The enhanced overpack, termed Version E, gives the HI-STORM 100 system the same extreme resilience against the so-called "smart" flood that is built into the previously licensed HI-STORM FW (Flood & Wind) overpack. The flood handling capability of the HI-STORM FW system has been a prized feature for sites located adjacent to rivers or in flood zones because it significantly reduces the emergency preparedness burden on flood-vulnerable sites. Previously limited to the HI-STORM FW, NRC's approval of this LAR will make the extreme flood resistance feature available to users of the HI-STORM 100 system as well. The improved HI-TRAC provides flexibility in the lead shielding thickness and increases heat load storage capability. The MPC-32M canister is the PWR counterpart to the previously approved MPC-68M and is expected to be used to defuel the twin PWRs at the Indian Point Energy Center in support of a planned expedited decommissioning of the site. We have also taken this opportunity to incorporate technical material to reflect the Staffs previously stated preferences, such as including another restriction on acceptable stored nuclear fuel based on the correlation for enrichment - burnup -cooling time.
Document ID 5014867 Page I of 4
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104
='-'------'------T-e-le_p_h_on_e_(_8_5_6)_7_9_7_-0_9_0_0 H Q L T E C Fax (856) 797-0909 INTERNATIONAL To facilitate the Staff's review, the safety analysis material supporting this FSAR consists of a supplement II appended to each chapter; thus Supplement I.II provides new information that adds to or supersedes the information in Chapter 1 along with its existing appendices and supplements.
The FSAR material submitted herewith contains all the new supplements along with certain pages in the main report that contain clarifications.
As part of these changes, this license amendment seeks to update the safety analysis methods and models to bring them in alignment with those documented through the state-of -the-art anaiyses in our HI-STORM FW docket. Harmonizing the analysis models between the two dockets will enable the methodology for future site-specific and 10 CFR 72.48 change evaluations to be unified for the two dockets. This will eliminate the disconnects between the HI-STORM 100 (Docket# 72-1014) and HI-STORM FW (Docket# 72-1032) dockets which exists at this time.
We have also used this opportunity to include a new Material Suitability Evaluation Supplement, Supplement 14.II, which brings this FSAR in alignment with the latest NRC guideline. This supplement mirrors the HI-STORM FW FSAR Chapter 8, "Material Evaluation", which was previously reviewed by the NRC. to this letter provides a summary of the proposed changes in this amendment. through 6 to this letter provides the changed pages of the Certificate of Compliance and its appendices. Appendices C and D are introduced in this LAR. Attachments 7 and 8 contain the changed FSAR pages to address the proposed changes in proprietary and non-proprietary versions. Attachment 9 contains the proposed drawings to support the proposed changes. 0 contains the responses to the RAis received for the original LAR-13 submittal pertaining to the proposed change which is incorporated into LAR-15 as proposed change# 10.
Attachments 11-16 contain the thermal calculation packages and supporting files. Attachments 17-20 contain the structural calculation packages and supporting files. Attachments 21-26 contain the criticality and shielding calculation packages and supporting files. Attachment 27 is an affidavit prepared in accordance with 10 CFR 2.390 requesting that Attachments marked proprietary be withheld from public disclosure due to their proprietary nature.
We request a SER by October 2020 to support rulemaking for an effective date of April 1, 2021 to support the expedited decommissioning of the Indian Point site.
If you have any questions, please contact me at 856-797-0900 ext. 3765.
Document ID 5014867 Page 2 of 4
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Telephone (856) 797-0900 HQ LT EC Fax (856) 797-0909 INTERNATIONAL Sincerely, Joyce Tomlinson Licensing Manager, Holtec International cc:
(via email)
Ms. Yen Chen, USNRC Mr. Mike Layton, USNRC Attachments: : HI-STORM 100 Amendment 15 Summary of Proposed Changes(non-proprietary) : HI-STORM 100 Amendment 15 Certificate of Compliance (non-proprietary) : HI-STORM 100 Amendment 15 Certificate of Compliance, Appendix A (non-proprietary) : HI-STORM 100 Amendment 15 Certificate of Compliance, Appendix B (non-proprietary) : HI-STORM 100 Amendment 15 Certificate of Compliance, Appendix C (non-proprietary) : HI-STORM 100 Amendment 15 Certificate of Compliance, Appendix D (non-proprietary) : HI-STORM 100 FSAR Proposed Revision 17 revised pages (proprietary) : HI-STORM 100 FSAR Proposed Revision 17 revised pages (non-proprietary) : Proposed Licensing Drawings (proprietary) 0: Amendment 13 RSI Response (non-proprietary) 1: HI-2188386RO, Critical Dimension Report for HI-STORM 100 Version E, HI-TRAC MS, and MPC-32M (proprietary) 2: HI-971788R14, Effective Property Evaluations of HI-STAR 100 and HI-STORM Dry Cask System Multi-Purpose Canisters (proprietary) 3: HI-971789Rl 6, Effective Thermal Conductivity Evaluation of L WR Fuel Assemblies in Dry Storage Casks (proprietary) 4: HI-2177974Rl, Effective Properties of PWR and BWR Fuel Assemblies (proprietary) 5: HI-2043317R33, HI-STORM Thermal-Hydraulic Analyses Supporting Up to 36.9kW High Heat Load Amendment, Appendix N, R, S, T (proprietary) 6: Thermal Calculation Input/ Output Files (proprietary) 7: HI-2188390RO, Tornado Missile Analysis for the HI-STORM lOOS Version E Document ID 5014867 Page 3 of4
HOLTEC INTERNATIONAL Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 System (proprietary) 8: HI-2188402RO, Structural Calculation Package for HI-STORM 100 S Version E System (proprietary) 9: HI-2188448RO, Analysis of the Non-Mechanistic Tipover Event of the Loaded HI-STORM lOOS Version E Storage Cask (proprietary) 0: Structural Calculation Input/ Output Files (proprietary) 1: HI-2012771R26 App AE, AF, AG, AH, HI-STAR 100 and HI-STORM 100 Additional Criticality Calculations (proprietary) 2: Criticality Calculation Input/ Output Files (proprietary) 3: HI-951322R27, App 47, HI-STAR 100 Shielding Design Analysis for Transport and Storage (proprietary) 4: HI-2167524R2, HI-STAR 190 Source Terms and Loading Patterns Using SCALE 6.2.1 (proprietary) 5: HI-2188253RO, HI-STORM lOOS Version E Shielding Analysis (proprietary) 6: Shielding Calculation Input I Output Files (proprietary) 7: Affidavit in Accordance with 10 CFR 2.390 Document ID 5014867 Page4 of4
U.S. Nuclear Regulatory Commission Document ID 5014867 Non-Proprietary Attachment 27 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:
(1)
I 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 in Attachments 7, 9, 11 and Attachments 12 through 26 to Holtec Letter 5014867. These enclosures contain Holtec Proprietary information.
(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, andNRC 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).
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U.S. Nuclear Regulatory Commission Document ID 5014867 Non-Proprietary Attachment 27 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 paragraphs 4.a, 4.b, and 4.e 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 2 of5
U.S. Nuclear Regulatory Commission Document ID 5014867 Non-Proprietary Attachment 27 AFFIDAVIT 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 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 pr~>Visions 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 de.scriptions 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 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.
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U.S. Nuclear Regulatory Commission Document ID 5014867 Non-Proprietary Attachment 27
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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.
I 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.
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U.S. Nuclear Regulatory Commission Document ID 5014867 Non-Proprietary Attachment 27 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY COUNTY OF CAMDEN
)
)
)
ss:
Kimberly Manzione, being duly sworn, deposes and says:
That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.
Executed at Camden, New Jersey, this 20th day of March, 2019.
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Subscribed and sworn before me this 20th day of 5 of5 Kimberly Manzione Licensing Manager Holtec International Erika Grandrimo NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES January 17. 2022
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