ML20044F601

ISFSI Renewal Proprietary Determination Letter for RAI Clarification Submittal 7-12-19

ML20044F601
Person / Time
Site:	07200011
Issue date:	02/24/2020
From:	Kristina Banovac Storage and Transportation Licensing Branch
To:	Tallman D Rancho Seco Assets Power Generation
KLBanovac NMSS/DFM/STL 415.7116
References
CAC 000993, CAC 001028, EPID L-2018-LNE-0004, EPID L-2018-RNW-0005
Download: ML20044F601 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 24, 2020 Mr. Dan Tallman Manager, Rancho Seco Assets Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, CA 95638-9799

SUBJECT:

APPROVAL OF SACRAMENTO MUNICIPAL UTILITY DISTRICT REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE FOR RANCHO SECO INDEPENDENT SPENT FUEL STORAGE INSTALLATION (CAC/EPID NOS. 001028/L-2018-RNW-0005; 000993/L-2018-LNE-0004)

Dear Mr. Tallman:

By letter dated July 12, 2019, Sacramento Municipal Utility District submitted an affidavit dated July 10, 2019, and executed by Prakash Narayanan, Chief Technical Officer of TN Americas LLC (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19204A239). You requested that the following documents be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

• - RAI Clarifications and Responses

• - Rancho Seco ISFSI License Renewal Application, Revision 3

• - Design Drawings and Quality Category Assessment Associated with the Response to RAI 2-1 Clarification

• - Calculation 67009-TLAA25, Revision 0, Gamma Radiation for Potential Radiolysis of Water at DSC Outer Surface, Associated with the Response to RAI 3-2 The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:

1) The information sought to be withheld from public disclosure involves operating experience with spent fuel storage system aging and details of spent fuel storage system aging management studies associated with the renewal of a system using the NUHOMS technology. The NUHOMS technology is owned and has 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 information customarily held in confidence by it.

D. Tallman 2

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 operating experience with the aging degradation of systems using the NUHOMS technology and details of spent fuel storage system aging management studies and planned aging management strategies associated with the renewal of systems using the NUHOMS technology, 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 America LLC' s product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of your statement, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the above listed documents marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended. Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents.

If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the U.S. Nuclear Regulatory Commission (NRC). You also should understand that the NRC may have cause to review this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of the date of public disclosure, which will be a reasonable time thereafter.

If you have any questions regarding this matter, please contact me at (301) 415-7116 or Kristina.Banovac@nrc.gov.

Sincerely,

/RA/

Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 72-11 License No. SNM-2510 CAC/EPID Nos. 001028/L-2018-RNW-0005 000993/L-2018-LNE-0004 cc: Rancho Seco Service List Prakash Narayanan, TN Americas LLC

Rancho Seco Service List cc:

Arlen Orchard, Chief Executive Officer Sacramento Municipal Utility District 6201 S Street P.O. Box 15830 Sacramento, CA 95817-1899 Laura Lewis, Chief Legal Officer Sacramento Municipal Utility District 6201 S Street P.O. Box 15830 Sacramento, CA 95817-1899 Steve Lins, Deputy General

Counsel, Sacramento Municipal Utility District 6201 S Street P.O. Box 15830 Sacramento, CA 95817-1899 Site Document Control Supervisor Rancho Seco 14440 Twin Cities Road Herald, CA 95638-9799 Commissioners' Office California Energy Commission 1516 Ninth Street (MS 34)

Sacramento, CA 95814-5512 Radiation Program Director California Radiologic Health Branch P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414 Sacramento County Board of Supervisors 700 H Street, Suite 2450 Sacramento, CA 95814

ML20044F601 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME KBanovac WWheatley DDoyle DATE 2/14/2020 2/14/2020 2/24/2020