ML20198H357

Forwards non-proprietary Versions of Proprietary Documents Previously Included in Licensee Ltrs to NRC in Response to RAIs Re Spent Fuel Reracking License Amend.Holtec Affidavit, Reaffirming Proprietary Nature of Original Submittals,Encl

ML20198H357
Person / Time
Site:	Waterford
Issue date:	12/23/1998
From:	Dugger C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198H363	List: ML20198H357 ML20198H371 ML20198H391 ML20198H406 ML20198H412 ML20198H437 ML20198H442 ML20198H464 ML20198H468
References
W3F1-98-0190, W3F1-98-190, NUDOCS 9812290324
Download: ML20198H357 (14)

Text

Entergy OperOtions,Inc.

Ki oi a 70066-0751 Tel 504 739 6600 Charles M. Dugger eP sont. Operations W3F1-98-0190 A4.05 PR December 23,1998 -

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Non-Proprietary Version of Proprietary Documents  !

Associated with Amendment 144 Gentlemen: .

l Please find enclosed non-proprietary portions of the proprietary attachments that  !

were previously included under Entergy's letters to the NRC in response to requests for additional information associated with the Waterford 3 Spent Fuel Pool reracking l license amendment (Amendment 144). These non-proprietary portions of the I documents were not previously provided. The list of the non-proprietary enclosures is provided in the attached table (Attachment 1). .

l Also, enclosed is a Holtec affidavit (Attachment 2) re-affirming the proprietary nature )

of the original proprietary submittals.

If you have any questions concerning this information, please contact Roy Prados at (504) 739-6632.

Very truly ours, C.M. Dugger V

Vice President, Operations Waterford 3 y CMD/RWP/ssf Attachments & Enclosures

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9812290324 981223 PDR P

ADOCK 05000382 PDR j

. _ . . . . . . . . _ _ ~ . _ . - . _- - .-

, Non-Proprietary Version of Proprietary Documents Associated with Amendment 144 W3F1-98-0190 Page 2.

December 23,1998 I

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(w/ Attachments & Enclosures) i cc: E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR

-l J. Smith N.S. Reynolds NRC Resident inspectors Office '

Administrator Radiation Protection Division ,

-(State of Louisiana) j American Nuclear Insurers  !

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of )

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. Entergy Operations, incorporated ) Docket No. 50-382

- Waterford 3 Steam Electric Station )

AFFIDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Non-Proprietary Version _of Proprietary Documents Associated with Amendment 144; that he is familiar with the content thereof; and that the matters set forth therein are true and i corrf4t to the best of his knowledge, information and belief. )

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.j g(. k - <

<1r Charles Marshall Dugger Tl' Vice President Operations - Waterford 3 STATE OF LOUISIANA ) .

i ) ss PARISH OF ST. CHARLES )

l Subscribed and sworn to before me,9J4 otary Public in and for the Parish and State l above named this > e day of V L . ,. 4 <

,1998.

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, , j QL Notary Public My Commission expires s%~M .

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Attachment 1 to I W3F1-98-0190

Attachment 1 to W3F1-98-0190 Page 1 of 2 PROPRIETARY SUBMITTAL LISTING

SUMMARY

TABLE Entergy Submittal Letter No. Proprietary Document Title New Non-Proprietary and Date Attachment No. Enclosure Number W3F1-97-0246 1 Holtec Report HI-91700, "Dynarack Validation 1 10/23/97 Manual 19 Holtec Drawing No.1850, Revision 4 2 W3F1-97-0288 Only Hoitec Report HI-961586, " Thermal-Hydraulic 3 1/21/98 Attachment Analysis" of Waterford 3 Spent Fuel Pool" W3F1-98-0016 1 Holtec Position Paper WS-115. "3-D Single Rack 4 1/29/98 Analysis of Fuel Racks" 3 Holtec Report Hi-87113, " Evaluation of Fluid Flow 5 for in-Phase and Out-of-Phase Rack Motions" 4 Holtec Report Hi-87114, " Estimated Effects of 6 Vertical Flow Between Racks and Between Fuel Cell Assemblies" 5 Holtec Report Hi-87102, " Study of Non-Linear 7 Coupling Effects" 6 Holtec Report Hi-87112, " Fluid Flow in Narrow 8 Channels Surround Moving Rigid Bodies" 7 Holtec Report HI-91700, "DYNARACK Validation 9 Manual" 12 Flow chart for Whole Pool Multi Rack Analysis 10 13 Holtec Report HI-971606, Tables 5.1, 5.2, and 5.3 11 W3F1-98-0040 1 Holtec Position Paper WS-121, " Benchmarking 12 3/23/98 Computer Code Fluent" 3 Figure labeled " Attachment 3: Schematic of 13 Original Nodalization scheme for Waterford 3 CFD Analysis"

Attachment 1 to W3F1-98-0190 Page 2 of 2 PROPRIETARY SUBMITTAL LISTING

SUMMARY

TABLE Entergy Submittal Letter No. Prc prietary Document Title New Non-Proprietary and Date Attachment No. Enclosure Number 4 Figure labeled " Attachment 4: Physica! Mesh 14 Mapped by the Original Scheme 5 Figure labeled " Attachment 5: Volumetric Heat 15 Source Contours Plot" 6 Figure labeled " Attachment 6: Refined Nodalization 16 Scheme to Determine Mesh Size Convergence" 7 Figure labeled " Attachment 7: Temperature 17 Contours Plot with Original Mesh Temperature (K)

[Waterforri 3 CFD Analysis]" ,

8 F.:gure leoeled " Attachment 8: Temperature 18 Contours Plot with Refined Mesh Temperature (K)

"Waterford 3 CFD Analysis]"

9 Figure labeled " Attachment 9: MP3 Spent Fuel Pool 19 Test Layout" 10 Figure labeled " Attachment 10: Millstone Unit 3 Pool 20 Transient Heating Profiles" 12 Figure labeled " Attachment i2: Base Case 21 Waterferd 3 Temperature Contours" 13 Figure labeled " Attachment 13: Perturbed Base 22 Watej 1 Temperature Contours" W3F1-98-0100 2 D"NARN .( User's Instructions 23 5/19/98 3 Three Diskettes Containing Proprietary Files- No 24 Non-Proprietary information is available W3F1-98-0096 Only Holtec Report Hi-981942, " Independent Review of 25 5/28/98 Attachment Waterford Unit 3 Spent Fuel Pool CFD Model"

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Attachment 2 to W3F1-98-0190 i l

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AFFIDAVIT PURSUAN'I' TO 10CFR2.790 l l

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I, Scott H. Pellet, being duly sworn, depose and state as follows:

(1) I am the Project Manager for Holtec International and have been delegated the l function of reviewing the information described in paiagaph (2) which is sought l to be withheld, and have been authorized to apply for its withholding.  ;

l (2) A number of items prevmusly submitted to the USNRC, in response to Requests for Additional Information, were accompanied by affidavits stating that the entire contents were proprietary. A listing is provided as Attachment A to this document.

However, certain portions, such as cover sheets, tables of contents, and titles may be considered as non-proprietary. Therefore, additional non-proprietary versions l of these items have been prepared and are being transmitted under separate cover.

(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 ofInfonnation 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),

2.790(a)(4), and 2.790(b)(1) for " trade secrets and commercial or financial j information obtained from a person and privileged or confidential" (Exemption 4). I The material for which exemption from disclosure is here sought is all " confidential l

commercial information", and some portions also qualify under the narrower defmition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy ProjecLy.

Nuclear Regulatory Commission,975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v. FDA,704F2d1280 (DC Cir.1983).

(4) Some examples of categories of informatiott which fit into the definition of proprietary information are:

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a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtee's competitors without license from Holtec International constitutes a competitive economic advantage over other companies; I

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l-AFFIDAVIT PURSUANT TO 10CFR2.790 l ,

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l l l b. Information v hich, if used by a competitor, would reduce his expenditure  ;

of resources or improve his competitive position in the design, manufacture, l shipment, installation, assurance of quality, or licensing of a similar product.

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c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its 1 customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec l International customer-funded development plars and programs of potential

! commercial value to Holtec International; l

e. Information which discloses patentable subject matter for which it may be l desirable to obtam patent protection.  !

l l The information sought to be withheld is considered to be proprietary for the l reasons set forth in paragraphs 4.a,4.b,4.d, and 4.e, above.

l (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, i 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 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.

l -(6) Initial approval of preprietary treatment of a document is made by the manager of l the originating component, the person most likely to be acquainted with the value i and sensitivity of the information in relation to industry knowledge. Access to such I documents within Holtec International is limited on a "need to know" basis.

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l AFFIDAVIT PURSUANT TO 10CFR2.790 (7) The procedure for approval of external relesse of such a document typically i 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 provisions or proprietary agreements.

1 (8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is j classified as proprietary because it contains detailed historical data and analytical -

results not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed using codes developed by Holtec l International. Release of this information would improve a competitor's position i without the competitor having to expend similar resources f- die development of the database. A substantial effort has been expended by Holtec International to develop this information.

(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 j

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 f

appropriate evaluation process.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

l 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.

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AFFIDAVIT PURSUANT TO 10CFR2.790 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 i adequate return on its large investment in developing these very valuable analytical tools.

STATE OF NEW JERSEY )

) ss:

COUNTY OF BURLINGTON )

l Scott H. Pellet, being duly sworn, deposes and says:

l That he has read the foregoing affidavit and the matters stated therein are true and correct i to the best of his knowledge, information, and belief.

Executed at Marlton, New Jersey, this 9th day of December 1998.

l Scon H. Pellet Holtec International Subscribed and sworn before me this day of  % 1998.

TF)& 0lp hMRM C. PEPE NOTARY PUBLIO OF NEW JERSEY My Commialor) Expires April 25,2000 i 4 l

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Attachment A PROPRIETARY SUBMITTAL LISTING

SUMMARY

TABLE Entergy Submittal Ixtter No. Attachment No. Document Title and Date W3F1-97-0246 i Holtec Report 111-91700, "Dynarack Validation Manual" 10/23/97 19 Ilottec Drawing No.1850, Revision 4 W3F1-97-0288 Only Attachment IIoltec Report 111-961586, " Thermal-llydraulic Analysis" of 1/21/98 Waterford-3 Spent Fuel Pool" W3F1-98-0016 1 lloltec Position Paper WS415, "3-D Single Rack Analysis of ,

1/29/98 Fuel Racks" 3 Holtec Report HI-87113, " Evaluation of Fluid Flow for In-Phase ,

and Out-of-Phase Rack Motions" 4 Holtec Report HI-87114, " Estimated Effects of Vertical Flow Between Racks and Between Fuel Cell Assemblies" 5 Holtec Report Hi-87102, " Study of Non-Linear Coupling Effects" ,

6 Holtec Report Hi-87112, " Fluid Flow in Narrow Channels Surrounding Moving Rigid Bodies" 7 Holtec Report HI-91700, "DYNARACK Validation Mant a!"

12 Flow Chart for Whole Pool Multi Rack Analysis 13 Holtec Report Hl-971606, Tables 5.1,5.2, and 5.3 W3F1-98-0040 1 Holtec Position Paper WS-121, " Benchmarking Computer Code 3/23/98 Fluent" 3 Figure labelled " Attachment 3: Schematic of Original Nodalization scheme for Waterford 3 CFD Analysis"

Attachment A PROPRIETARY SUBMITTAL LISTING

SUMMARY

TABLE W3F1-98-0040 4 Figure labelled " Attachment 4: Physical Mesh Mapped by the 3/23/98 Original Sheme" 5 Figure labe' led " Attachment 5: Volumetric Ileat Source Contours Plot" 6 Figure labelled " Attachment 6: Refined Nodalization Scheme to Determine Mesh Size Consergence" 7 Figure labelled " Attachment 7: Temperature Contours Plot with Original Mesh Temperature (K) [Waterford 3 CFD Analysis]"

8 Figure labelled " Attachment 8: Temperature Contours Plot with Refined Mesh Temperature (K) [Waterford 3 CFD Analysis]"

9 Figure labelled " Attachment 9: MP3 Spent Fuel Pool Test

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L.ayout" 10 Figure labelled " Attachment 10: Millstone Unit 3 Pool Transient Heating Profiles" 12 Figure labelled " Attachment 12: Base Case Waterford 3 Temperature Contours" 13 Figure labelled " Attachment 13: Perturbed Case Waterford 3 Temperature Contours" W3F1-98-0100 2 DYNARACK User's Instructions ,

5/19/98  :

3 Three Diskettes Contrining Proprietary Files - No Non-Proprietary Information is available W3F1-97-0096 Only IIoltec Report 111-981942, " Independent Review of Waterford 5/28/98 Attachment Unit 3 Spent Fuel Pool CFD Model"

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ENCLOSURE 1 i

(Non-Proprietary Version of Attachment 1 to W3F1-97-0246, dated 10/23/97) iI i

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