ML20199J743
| ML20199J743 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/11/1999 |
| From: | Abbott R NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17059C486 | List: |
| References | |
| NMP1L-1401, TAC-MA1945, NUDOCS 9901260240 | |
| Download: ML20199J743 (33) | |
Text
NiagarahMohawk' Richard B. Abbott -
Phone: 315.349.1812 l Vice President Fax: 315.349 4417 ;
NuclearEngineering }
- i. January 11,1999 NMPIL 1401 l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk l Washington, DC 20555 )
i RE: Nine Mile Point Unit 1 Docket No. 50-220 DPR-63
Subject:
Supplemental Requestfor Additional Infonnation Reganting Increased Spent Fuel Pool Stomge Capacity at Nine Mile Point Nuclear Station Unit 1 (TAC No. MA1945)
Gentlemen: :
t By letter dated May 15,1998, Niagara Mohawk Power Corporation (NMPC) submitted an application to amend Nine Mile Point Unit 1 (NMPI) Technical Specification 5.5, Storage o' ;
Unitradiated and Spent Fuel. The changes reflect proposed modifications to increase the storage capacity of the NMP1 spent fuel pool from 2776 to 4086 fuel assemblies. The NRC's L letters dated August 11,1998, August 24,1998, and October 27,1998 requested additional information regarding our application. Our submittals of September 25,1998, October 13, 1998, and December 9,1998 provided our responses.
In your letter dated December 9,1998, the NRC provided another request for additional information. The attachments to this letter provide this information, i
Attachments 6, 7 and 8 are considered by its preparer, Holtec International, to contain j proprietary information exempt from disclosure pursuant to 10CFR2.790. Therefore, on '
behalf of Holtec International, NMPC hereby makes application to withhold these documents from public disclosure in accordance with 10CFR2.790 (b)(1). An affidavit executed by '
Holtec International detailing the reasons for the request to withhold the proprietary information has been included as Attachment 2. A non-proprietary version of these documents l
has not been included due to the nature of the documents (drawings and calculations), which j makes separation of proprietary and non-proprietary information impossible. A list of these / i documents is provided as Attachment 9.
9901260240 990111" PDR ADOCK 05000220 P PDR' 1 p Y? L
- 70k \ ' pYorf13093 0063 + wwwnimo.com Nine Mile Point Nuclear Station P0. Box 63, Lycoming N kg bo 9 4W
}l Page 2 l During a telephone conference held with the Staff on January 8,1999, it was noted that l corrections needed to be made to Table 2.2 and Figure 2.1 of our May 15,1998 submittal.
Table 2.2 and Figure 2.1 have been revised and are included as Attachment 11. (It should be noted that Figure 2.1 is considered by its preparer to contain proprietary information as
- discussed in our May 15,1998 submittal.)
Sincerely, h546 Y Richard B. Abbott Vice President Nuclear Engineering RBA/JMT/ kap Attachments xc: Mr. H. J. Miller, Regional Administrator, Region I l Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR l Mr. G. K. Hunegs, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR !
Mr. John P. Spath NYSERDA 286 Washington Avenue Ext.
Albany, NY 12203-6399 Records Management l 1 l
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l ATTACHMENT 1 1
SUPPIFMENTAL RFOUEST FOR ADDITIONAL INFORMATION REGARDING SPENT FUFI POOL MODIFICATIONS !
NIAGARA MOHAWK POWER CORPORATION l NINE MIII POINT NUCI F AR STATION. UNIT NO.1 DQfKET NO. 50-220 l
4 V. CIVIL ENGINEERLNG l IMainn 12-1 Provide additional irlfonnation including drawings or sketches describing the design of the following items:
- a. The pool cask area and the cask drop protection .tystem. Identify any physical barriers beturen this area and the remaining pool. Explain why the cask drop protection system was analyzed as afuel rack.
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- b. Details ofcell-to-cell welds, cell-to-baseplate uvids, and pedestal-to-baseplate nelds.
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- c. Details ofimpact protection hant points at top corners of the racks.
- d. Dimensions of the bearing pads which transfer the rack loads to the poolfloor.
Response
- a. The pool cask area is located in the northwest corner of the spent fuel pool, where the cask drop protection system (CDPS) is installed. The CDPS is a stainless steel cylindrical shell, which measures approximately 118 inches in diameter. The shell i
stands over 39 feet high, and it is anchored to the spent fuel pool liner at two elevations on the north and west walls. There are no physical barriers between the CDPS and the remaining pool. Attachment 3 contains drawings of the CDPS at Nine Mile Point Unit 1 (NMP1).
The CDPS was included in the whole pool multi-rack (WPMR) model as an additional blunt prismatic structure so that the analysis could capture the fluid coupling effect between the CDPS and the adjacent fuel racks. Unlike the other racks in the WPMR model (which are free-standing), the CDPS structure was fastened to the north and west 1 pool walls by six springs in the model, which represented the CDPS anchor points.
This modeling approach enabled the program to predict potential impacts between the free-standing spent fuel racks and the anchored CDPS structure during the postulated seismic events.
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- b. Please refer to drawings in Attachment 6 for details of cell-to-cell welds, cel!-to-baseplate welds, and pedestal-to-baseplate welds.
- c. Please refer to drawings in Attachment 6 for details of impact protection hard points at top corners of the racks.
- d. Please refer to drawings in Attachment 6 for the dimensions of the bearing pads.
Duo don 13:
Demonstrate that the artylcial seismic time histories used in the analyses satisfy the power spectral density (PSD) requirement ofStandard Review Plan (SRP) 3. 7.1.
Response
The PSD functions of the artificial seismic time-histories are plotted in Figures 1 through 6 of Attachment 4 against the corresponding target function. It is clear from these graphs that the energy content of the seismic input is essentially confined to the low frequency range (below 10Hz). In this significant frequency range of the postulated earthquake for NMP1 (IHz to 10Hz), which is also the response range of the spent fuel racks (as indicated by Figures 6.8.1 and 6.8.2 of the May 15,1998 submittal), the PSD functions that correspond with the generated time-histories conservatively bound the target functions. Therefore, the artificial seismic time-histories meet the intent of the PSD requirement of SRP 3.7.1.
Durann 14:
Erplain how in-phasefluid coupling coeficients are calculatedfor single rack model analysis.
Response
Under the assumption ofin-phase motion, the entire array of fuel racks moves in unison. As a result, all gaps between adjacent fuel racks remain constant. The only gaps that fluctuate, due to in-phase motion, are the gaps between peripheral racks and the spent fuel pool walls.
Therefore, in the single rack model, the fluid coupling coefficients for in-phase motion are based on the peripheral rack-to-wall gaps, not the inter-rack gaps.
As an example, for rack J2, which is separated by 0.375 inches from racks L,31, and H4 to the West, North, and East, respectively, the proper fluid gap dimensions for an in-phase model of the rack are 2.5 inches,2.525 inches,1.5 inches, and 1.59 inches. These dimensions represent the outermost gaps between a fuel rack and the pool wall in the west, south, east, and north directions, respectively. This example is illustrated in Figure 7 of Attachment 4.
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Duntion 15:
Fuel-to-cellfluid coupling coeficients were calculated based on channeledfuel. Fluid couplingfor unchanneledfuel may be sigm*ficantly lower due to the largerflow area through thefuel. This may increase the rack responses. Please address this potential concern.
Racnonse:
The observation is correct that the fluid coupling between the channeled spent nuclear fuel (SNF) and the cell wall is greater than that between unchanneled fuel and its storage cell. To establish the governing case, a series of parametric runs with both channeled SNF and unchanneled SNF were carried out in the last Enrico Fermi Unit 2 high-density rack project (Docket No. 50-341). The results showed that the rack response (viz., pedestal load, rigid body displacement, etc.) were slightly greater for the channeled SNF case. This result was not unexpected in light of the following considerations:
- The channeled SNF is heavier than the unchanneled SNF by 80% of the weight of the rack attributable to one storage cell.
- The presence of the channel reduces the size of the gap between the fuel and the cell wall, increases the fluid coupling between the fuel assembly and the cell wall and alters the rattling frequency as well as reducing the rattling impact loads.
- The net effect of fluid coupling is to transfer energy from one body to another; it does not dissipate the total system kinetic energy. Therefore, a greater extent of fluid coupling in the channeled SNF case does not entail reduction in the system kinetic energy. The sole paths for dissipation of the rack kinetic energy are through Coulomb friction and structural damping modeled in the dynamic simulation.
The above considerations and results from the historical Fermi 2 runs led Holtec International to standardize the channeled SNF as the reference fuel configuration for 3-D dynamic analysis.
It is, however, recognized that the difference in the rack response with channeled SNF versus unchanneled SNF condition is only slightly different. In fact, the effect of pedestal-to-liner friction coefficient or extent and pattern of fuel loading (which of the storage locations are occupied) have a much more pronounced effect on the peak response of the fuel rack. .
For this reason, a number of parametric runs with varied parameters (e.g., coefficient of friction, extent of SNF loading, etc.) were performed to obtain a reasonable approximation of the upper bound on the rack structural response in the face of, theoretically, an infinite number of combination of variables which can exist in a loaded fuel rack in wet storage.
Question 16:
Provide the structural damping values used in the analysis and explain how damping was included in the equations ofmotion.
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l Raamass:
Structural damping is provided by applying'a damper element in parallel with every linear stiffness element in the model. The damping coefficient is pK, where K .= the spring constant, p -
(%D/100)/ nr,
%D =
percent critical damping specified, and f = predominant response of the structure.
For NMPl: 4% damping at 10 Hzis used for SSE 2% damping at 10 Hzis used for OBE
- Ihe reference frequency of 10 Hz exceeds the predominant excitation frequency of the seismic event, and it is in the response range of the rack.
In the governing equations of motion, which appear in matrix form on page 6-22 of the May 15, ,
1998 submittal, the structural damping is lumped into the generalized force terms, therefore, it _ l does not appear explicitly, Qwndon 17:
1 Provide a sketch of a typical singpliped 8 DOF mck model used in the whole pool multi-rock (WPMR) analyses. What percentage of the totalfuel mass was assumed to rattle and how ms . ,
this and other singplifying assumptions validated? l 4
Ramoner- !
A sketch of a typical 8 degree of freedom (DOF) rack model, which is used in the WPMR )
analyses, is shown in Figure 8 of Attachment 4. The first six DOFs are assigned to the spent i fuel rack, and are located on the rack geometric centerline at the mid-height of the storage cells. Degrees of freedom 7 and 8 are assigned to the rattling fuel mass at the top of the storage rack.
. The fraction of the total SNF mass assigned to the rattling lumped mass is set to ensure bounding rack displacements with respect to the 22 DOF single rack model. This is validated by performing a series of 8 DOF single rack analyses with different rattling mass percentages.
The rattling mass percentage that produces rack displacements that closely bound the corresponding 22 DOF results is selected for use in all subsequent WPMR simulations.
j For NMP1, eight different rattling mass percentages, which ranged from 30% to 50% of the )
total stored fuel mass, were investigated. Of these eight cases, the closest match occurred when the rattling mass was set equal to 50% of the stored fuel mass. This percentage was then used for all subsequent WPMR analyses.
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l Ourcrinn 18:
A number ofnewfuel racks (e.g., racks E and M) shown in your submittal ofMay 15,1998, have irregular configurations with additional cells in corners. These racks are sigm'ficantly diferentfrom the simple rectangular cmss-section racks assumed in the models. These diferences may afect the seismic motion and stress distribution. Erplain how these diferences are accountedfor in the analyses.
Recnonce:
The planar center-of-gravity of the rack cross section defines the location of the Rack Geometric Centerline (shown in Figure 8 of Attachment 4) with respect to the support pedestals. If all locations are occupied by the fuel assemblies, then the location of the effective spent fuel mass will coincide with the rack geometric centerline (i.e., Dx = Dy = 0 in Figure 8). Otherwise, non-zero values of Dx and Dy will need to be input into the dynamic model to recognize the eccentricity between the rack C.G. axis and the C.G. of the assemblage of fuel bundles stored in the rack. In DYNARACK simulations, irregular rack shapes are accounted for by first calculating the centroid of the irregularly shaped rack and then carefully locating the support legs with respect to the centroid. Attachment 5 summarizes the support leg calculations for Rack M as an example. The rnass distribution (i.e., the position of the lumped masses) must be correct to accurately predict the seismic motion and envelope all possible configurations of spent fuel storage. The stress factors, in the 8-DOF WPMR analysis, are derived from the forces on the support legs.
The calculations shown in Attachment 5 were carried out for all irregular rack shapes at NMPl.
Questinn 19:
The WPMR analysis predicted rack-to-rack impacts which were not predicted by the single rack analysis. Since the structural evaluation ofthe racks nas based upon the single rack analysis, these impact loads may not have been considered in the overall structural evaluation. Please provide a summary of the impact loads and explain how they were accountedfor in the rack stress evaluation.
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Recnnnce:
The rack-to-rack impacts that involve new Holtec racks are summarized in the table below for each of the six WPMR simulations.
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Case 1 (8 new racks, Case 2 (16 new Case 3 (16 new racks; 8 existing racks; all racks; all fully 12 racks fully loaded fully loaded loaded w/ channeled w/ channeled fuel,4 w/ channeled fuel) fuel) empty racks)
SSE OBE SSE OBE SSE OBE Rack-to-Rack Impact 5,573 lb 2,527 lb 5,927 lb 2,677 lb 5,019 lb 2,359 lb l at Top Corner Rack-to-Rack Impact 2,943 lb 0 lb 3,099 lb 1,290 lb 1,244 lb 0 lb at Baseplate These forces are accounted for in the rack stress evaluation. The rack baseplate and the impact protection hard points at the rack top corners are appropriately sized to diffuse these impact I loads. The rack baseplates are manufactured from % inch thick stainless steel plate (SA240- !
304L). For stress calculations, we assume that the baseplate impact is localized over one l characteristic cell dimension. The computed compressive stress in the baseplate is only 689 psi [= )
3,099 lb / (6 in x % in)). Since the calculated stress is far less than the yield stress of the material, l it is concluded that the Holtec racks can sustain the baseplate impacts that are predicted by WPMR analysis. The calculation of the local stresses in the rack cells due to rack-to-rack impact loads is provided in the response to Question # 20b.
Duntion 20:
Provide sample calculationsfor thefollowing:
- a. Emluation of welds summarized in Table 6. 7.27 ofyour submittal ofMay 15,1998. l
- b. Emluation oflocal stresses in rack cells due to rack-to-rack impact loads and due to fluid coupling hydrodynamic pressures.
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- c. Evaluation ofdroppedfuel, stuckfuel and dropped rack accidents.
- d. Evaluation of the pool linerforpotential tearing, rupture andfatiguefailure.
Response
The requested sample calculations are provided in Attachment 7.
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Question 21:
Provide an explanation ofthe infonnation in Table 6.7.28, " Summary ofAnalysis Results,'of yoursubmittal ofMay 15,1998. There is no discussion ofthis table in the report.
Recnonce:
In the previous rerack of the NMP1 fuel pool (1983), two rack modules, licensed for installation, were not installed in the pool. In lieu of the southwest corner (SWC) rack, a work platform was installed in the pool. I2ter, during 1993-94, the previously licensed SWC rack was placed in its designated position with one rack pedestal (which interfered with a liner bulge) relocated. The SWC rack was structurally qualified with the revised support pedestal geometry and an overhead platform. A series of single rack 3-D analyses on the SWC rack (with and without the platform) were performed to support the 10CFR50.59 safety evaluation that was prepared for the pedestal relocation and overhead platform installation.
The information in Table 6.7.28 is a summary of the results from the earlier analyses performed in support of the 50.59 effort. The run identifiers that are shown in the first row of the table represent the following loading scenarios:
FL8: The platform is installed on the rack. The rack is fully loaded with fuel. The coefficient of friction between the rack pedestal and the pool liner is set equal to 0.8.
FL2: The platform is installed on the rack. The rack is fully loaded with fuel. The coefficient of friction between the rack pedestal and the pool liner is set equal to 0.2.
DL8: The platform is installed on the rack. The rack is (diagonally) halfloaded with fuel.
The coefficient of friction between the rack pedestal and the pool liner is set equal to 0.8.
DL2: The platform is installed on the rack. The rack is (diagonally) half loaded with fuel.
The coefficient of friction between the rack pedestal and the pool liner is set equal to 0.2.
AP-FL8: The conditions of this run are the same as FL8, except the seismic input is amplified by 15 %. This run serves as a stability check, and its results are not used to determine stresses.
AP-DL2: The conditions of this run are the same as DL2, except the seismic input is amplified by 15%. This run serves as a stability check, and its results are not used to determine stresses.
It is important to note that the current Licensing Amendment application, dated May 15, 1998, does not seek the NRC's approval to install any overhead platforms on the new Holtec racks, and no such installation is contemplated.
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Qurctinn 22:
Provide the basisfor selection ofthe third WPMR analysis load case on page 6-28 ofyour submittal ofMay 15,1998. In this case,four racks in the southnest corner of the pool are empty. It appears inappropriate that one ofthe empty racks,12, is the heaviest rack that was analyzed as one ofthe two bounding racks in the single rack analyses.
Resnonse:
The third load case was selected for WPMR analysis to investigate the effect of a non-uniform fuelloading on the pool slab.
Question 23:
Thefirst WPMR analysis load case includes the old racks in the south halfofthe pool.
Although they are laterally restrained, they appear to be analyzed asfree-standing racks and have comparable seismic displacements to those of the new racks. Please clarify the design, lateral restraint and analysis of the old racks.
Resnonse:
The following description of the existing rack structure, excerpted from Nine Mile Point Specification No. FSE-1, Rev. O, provides a clear exposition of the rack configuration after the 1983 (Phase II) rerack of the NMP1 pool:
"The south half Phase II modification provided 1710 spent fuel cells (eight racks) using Boraflex as a neutron absorber. Each rack is supported by four floor-bearing pedestals. The racks are not interconnected at the base or top and are free to slide and tip within the confines of the lateral restraints. There is a one-fourth inch thermal gap between walls and seismic bearing pads in the east, west and south directions. Lateral loads in the east, west, and south directions are transmitted through individual rack bottom plates to the bearing pads on the east, west and south pool walls. Lateral loads in the north direction are transmitted to existing swing bolt brackets through a support beam located under each rack. Design and installation requirements provide for direct contact with seismic restraints in this direction. Two additional lugs are welded to the pool liner for lateral support in the north direction under the racks located on the east edge of the pool. These lugs are required since swing bolt lugs that support adjacent racks did not exist at these locations."
The WPMR model of the existing racks includes the lateral restraints in the east, west, and south directions and the swing bolt connections in the north direction. The lateral restraints are modeled as nonlinear (compression-only) springs with the appropriate gap. The base of each existing rack is also connected to a fixed point on the spent fuel pool liner by a unidirectional spring, which is aligned in the north direction. The displacement results from WPMR analysis are consistent with the applied fixity conditions on the existing racks. For example, the maximum top corner displacements of the new freestanding racks are on average more than two times greater than the maximum top corner displacements of the existing racks.
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l Quentan 24:
ne maximum WPMR analysis displacement of1.366 inches presented in Table 6.8.13 ofyour submittal ofMay 15,1998, does not agree with the value of 2.04 inchespresented in Table 6.8.lfor the same rack. Bis is much larger than the single rack analysis displacement of
- 0. 726 inches. This should be corrected and the consequences of this dference should be evaluated.
Response
The observation is correct. The niaximum WPMR displacement for rack G is 2.04 inches, as listed in Table 6.8.1. Table 6.8.13 has been revised and is included as Attachment 10. The error in the table has no effect on the result.
Quctinn 25:
Erplain the basisfor the marimum shear stress equation given in Section 7.4 ofyour submittal ofMay 15,1998.
Response
The derivation of the shear stress equation given in Section 7.4 is provided as Attachment 8.
Quentan 26:
Provide additionalirlfonnation to demonstrate that the increased mass due to the expansion of the spentfuel storage capacity will not afect the seismic response ofthe reactor building.
Response
The increase in the total deadload in the reactor building due to the proposed capacity expansion in the NMP1 pool is less than 0.5%. Since the natural frequency of a structural system is inversely proportional to the square root of the associated mass, the net change in the frequency spectrum is negligible. Therefore, the input seismic excitation applied to the pool slab in the previous rerack was considered to remain valid for the proposed capacity expansion project.
Questian 27:
Provide the stfness calculationsfor the racks C and E ofyour submittal ofMay 15,1998, with respect to the three directions (i.e., North-South, East-West and diagonal (45-degree) directions).
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'l Emmenas:
Racks C and E are only included in the 8 DOF WPMR models. Unlike the 22 DOF single rack analysis, where clastic stiffness is considered, the cell structure is assumed to be rigid in the 8 DOF WPMR model. The 8 DOF WPMR model is " calibrated" by adjusting the percentage of the total stored fuel mass that is assumed to rattle (see response to Question
- 17).'
@antion28:
What is the maximum bulkpool temperature at afull core of-load during a refueling outage?
f the temperature exceeds 150 *F, provide thefollowing:
a.' A description of the details of the spentfuelpool (SFP) structural analysis, including the materialproperties (i.e., modulus ofelasticity, shear modulus, poisson's ratio, yield stress and strain, ultimate stress and strain, conpressiw strength, etc.), used in the analysisfor the reinforced concrete slab and alls, and linerplate, welds and anchorages.
- b. The complete analysis results in a tabularform including: i) factors ofsqfety with respect to bending, shear and axialforcesfor SFP wils and slab and (ii) shear stress, strain, deflection and reactionforcesfor the linerplate and liner anchor.
- c. ACI Code 349 limits a concrete temperature up to 150 'Ffor normal operation or any other long tenn period. Provide technicalJustifcationfor exceeding the required temperature of150'F.
Eassanat:
l'Ihe maximum bulk pool temperature resulting from a full-core offload is 140*F, as noted in Attachment C of the May 15,' 1998 submittal (Licensing Report for Reracking Nine Mile Point Unit 1 Spent Fuel Pool, Section 5.4).
@nsgian 29:
Discuss the quality assurance and inspection programs to preclude installation of any irregular or distorted racks, and to corfnn the actualfuel rack gap corfgurations with respect to the gqps assumed in the DYNARACK analyses aper installation of the racks.
Essense:
A comprehensive and proven quality assurance and inspection program, summarized below, will be used in the NMP1 rack changeout project.
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Receipt inspection procedures are prepared prior to receipt of the new rack on site. These procedures ensure that each rack is in full compliance with the provisions of the May 15,1998 submittal and Holtec International's 10CFR50 Appendix B program. Upon receipt, the rack is first inspected for any damage potentially caused by the shipping or handling processes. The rack is also inspected for any scratches, dents, or signs of environmental exposure. Once the rack is offloaded and upended, another procedure is implemented for pre-installation dry drag testing. A selected set of candidate cells is drag tested using a dummy gage to ensure that the cells tested do not exceed a predetermined maximum dry pull force. Any cells that do not pass this test are reworked and then re-tested until the cell passes. After a rack passes receipt inspection and dry test criteria, the QC inspector removes the " HOLD", allowing the rack to be installed.
After rack installation, all cells are drag tested under water. Any cells that do not pass the acceptable drag test limit are reworked and then re-tested until the cell passes. The rack gaps are also checked at various locations along each side of the racl. at the rack top. Ieng handled measuring tools and underwater cameras are typically used for this evolution. If the gaps are within the tolerances allowed by the pool layout drawing, the rack is acceptable. If the gaps are not acceptable, the rack is re-lifted and re-positioned.
If the final inter-rack and peripheral rack-to-wall gaps are not within the tolerance specified in the rack installation procedures, then a reconciliation WPMR analysis with the as-indicated gaps is required to be performed to support a safety evaluation in accordance with 10 CFR 50.59.
Question 30:
Indicate whether or not you are planning to place an overhead platfonn on the racks pennanently orfor temporary storage during the installation of the racks.
Responw:
There are no plans to place an overhead platform on the racks permanently or temporarily during the installation of the racks.
Question 31:
Describe the plan andprocedurefor the post-operating basis earthquake inspection offuel rack gaps and configurations.
Response
The continued compliance of the installed rack arrays with the licensing basis is an essential part of a plant's safety considerations. Since the fuel racks are free-standing structures, the inter-body spacings in the NMPI pool, after a site seismic event, may be different from the as-installed values. NMP1 procedure N1-SOP-11, "Scismic Event," will be revised to require a comprehensive survey of the inter-module and module-to-wall gaps subsequent to a seismic event. If the gaps are found to have changed, then a re-evaluation of the acceptability of the t
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!. module layout configuration (using the WPMR model described in the May 15,1998 !
submittal) would be performed. If the analysis indicates that the gaps are not acceptable, then -
i the racks would be repositioned to achieve the pre-seismic event gaps and configurations. j l
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l ATTACIIMENT 2 Affidavit Executed by Ifoltec International
l AFFIDAVIT PURSUANT TO 10CFR2.790 I, Michael P. McNamara, being duly sworn, depose and state as follows:
(1) I am the Director of Nuclear Projects for Holtec International and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the following documents:
Holtec Drawings:
- 890, Revision 3
.#891, Revision 3
- 892, Revision 2
- 893, Revision 1
- 899, Revision 2 Holtec Reports:
HI-961584, " Fuel Assembly Drop Accident for Niagra Mohawk Power Corporation" Rev. O HI-971667, " Liner Fatigue Analysis for NMPl",
Rev.0 HI-92801," Calculation Package for Single Rack Analysis, Nine Mile Point Unit 1, Niagra Mohawk Power Corporation", Rev.2, Pg.7-201 through 7-204 and 7-219.
HI-89330, " Seismic Analysis of High Density Fuel Racks, Part III: Structural Design Calculations-Theory", Rev.1, pg. 49 through 54.
(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 1
l AFFIDAVIT PURSUANT TO 10CFR2.790 l 1
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 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 l assigned to those terms for purposes of FOIA Exemption 4 in, respectively, l Critical Mass Enerev Project v. Nuclear Regulatory Commission, 975F2d871 i (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir.1983).
(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 l competitive economic advantage over other companies; )
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- b. Information which, if used by a competitor, would reduce his expenditure i of resources or improve his competitive position in the design, I manufacture, shipment, installation, assurance of quality, or licensing of a l 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 customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future Hollec International customer-funded development plans and programs of l potential commercial value to Holtec International;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
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AFFIDAVIT PURSUANT TO 10CFR2.790 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a,4.b,4.d, 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 Internation. 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.
(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 infonnation, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information classified as proprietary was developed and compiled by Holtec Intcenational at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed historical data and analytical results not available elsewhere. This information would provide other parties, 3
l r
AFFIDAVIT PURSUANT TO 10CFR2.790 i
including ' competitors, with information from Holtec International's technical f database and the results of evaluations performed using codes developed by i Holtec International. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A substantial effort has been expended by Holtec International to develop this information.
i (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 i l methodology, and includes development of the expertise to determine and apply :
l 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 i
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 l very valuable analytical tools. !
I 4 I
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AFFIDAVIT PURSUANT TO 10CFR2.790 STATE OF NEW JERSEY )
) ss:
COUNTY. OF BU'RLINGTON )
Michael P. McNamara, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at Marlton,' New Jersey, this lith day of January,1999.
1 I
L 1 1
Michael P. McNamara ;
Holtec International -l Subscribed and sworn before me this // day of w % ~ ,1999.
V
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W nr-e-I:'. :. L . CV1JcRSEY My L .. .~ :.a D.pic Apr3 25,2000 M ARIA C. PEPE NOT* *N rUBUO OF NEW JERSEY 3 Mt0:T:ntr.:.lon Expires AprS 25,2000 i l
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where c equals the center-to-center cell spacing. The coordinates of the four support legs, with j respect to the centroidal axes, are l l
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l x 2 := 6.5 c + 0.77 c y 2 := 1.5 c + 1.54 c j l
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