ML20207A799
| ML20207A799 | |
| Person / Time | |
|---|---|
| Site: | 07109268, 07201023 |
| Issue date: | 02/25/1999 |
| From: | Fuller E External (Affiliation Not Assigned) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20136H802 | List: |
| References | |
| BFS-NRC-99-020, BFS-NRC-99-20, TAC-L22307, NUDOCS 9903050244 | |
| Download: ML20207A799 (14) | |
Text
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1 Victor Square Fuel Solutions Corporation yg4gejgA Sc 6444 Fax: (408) 438-5206 Febmary 25,1999 BFS/NRC 99-020 Docket Nos. 72-1023,71-9268 File Nos. SNC-109, SNC-209 Director, Office of Nuclear Material Safety and Safeguards 1
US Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Completion ofTranStor Part 72 Open Issues (TAC L22307)
Reference:
- 1) BFS Letter dated January 21,1999, Schedule to Complete TranStor Part 72 Storage Issues, BFS/NRC 99-005.
i
- 2) BFS Letter dated February 12,1999, Responses to NRC Requests for Additional Information Regarding the TranStorm Shipping Cask System, BFS/NRC 99-019.
- 3) BFS letter dated November 27,1998, Responses to NRC Request fer Additional Information (RAI-2) Regarding the TranStor Storage Cask System, BFS/NRC 98-022.
Dear Sir,
As documented in Reference 1, BNFL Fuel Solutions (BFS) committed to resolve four remaining TranStor Storage Cask open issues, by February 26,1999. Adoitionally,in Reference 2, BFS committed to provide by February 26,1999, a list that identifies the changes in the Part 72 application resulting from the enclosed Part 71 submittal. The enclos;ses to this letter provide the committed information and comple te the TranStorm Part 72 open issues.
The following is a discussion of each enclosure. - Oath /AfIirmation and Proorietary Affidavits I
1 to this letter provides an Oath and Affirmation and the Proprietary Affidavits for the design information contained within this response.
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Page 2 - Hvoothetical Non-Mechanistic Cask Tinover and Coatines As Enclosure 2 to this letter, find the evaluation of the consequences of the hypothetical non-mechanistic cask tipover event for the generic TranStor" Storage Cask System.
This evaluation includes two design calculation revisions, each issued in proprietary and redacted versions. Additionally, revised responses to the TranStorm Part 72 Request for Additional Information (RAI) questions 3-9,3-13,11-1, and Il-3 are provided. These RAI responses supersede those originally submitted with Reference 3. The TranStor Part 72 Safety Analysis Report (SAR) Section 11.2.10 has been updated to summarize the analysis and conclusions for this tipover evaluation. Revision D of the TranStorm Part 72 SAR is provided as Enclosure 2.
BFS has developed nowproprietary coating design parameters, which define the bounding characteristics for the TranStor basket internal and external coatings. New SAR Table 3.4-11, entitled " Design Parameters of Coatings", is included with SAR Revision D (Enclosure 2). - Material Testing BFS has completed the material testing for the A-500 and A-570 materials used in the TranStor fuel debris and failed fuel cans. Enclosure 3 contains the test reports documenting the material properties within the design temperature range for these materials. Initial RAI 2 response 3-12 did not require subsequent revision, since it committed only to demonstrating the adequacy of the materials by testing, which is completed by the enclosed test reports. The revised SAR table 3.3-5, Mechanical Properties of A-500, Grade C Ferritic Carbon Steel, reflects the results of this material testing (see Enclosure 2). - Bolt Testina BFS has successfully completed the requested load testing for the structural lid eye bolts.
The test report is provided as Enclosure 4. No changes to the initial RAI responses or Part 72 SAR are required for this issue. - Differences Between Part 71 and Part 72 Annlications A list tlat identifies the changes between the Part 71 and 72 applications is provided in to this letter. The changes primarily involve drawing and calculation revisions necessary to demonstrate component qualification at the higher acceleration limits of the Part 71 application. Specifically, the Boiling Water Reactor (BWR) and l
Pressurized Water Reactor (PWR) baskets were qualified to a 44g horizontal acceleration limit in the Part 72 storage application. The Part 71 shipping application impact limiter design necessitated the qualification of BWR and PWR baskets to 47g horizontal. The PWR baskets were re-qualified to the higher acceleration limit without design modification. Consequently, revisions to the original PWR basket design calculations are o
US Nuclear Regulatory Commission l
BFS/NRC 99-020 Page 3 noted, but are not re-submitted to the staff for review with the Part 72 application. On the l
other hand, the BWR baskets required minor design modification to qualify to the higher horizontal accelerations. The material of the spacers and sleeves was revised to accommodate the increased g loads. For the BWR basket therefore, revised design drawings and calculations are submitted herein for NRC review with the Part 72 application. Note that the previous information provided with the original Part 72 application (Reference 3), was not incoiTect, but has been updated to maintain consistency with the BWR basket design in Part 71.
If any questions exist relative to this submittal, please contact me at (831) 438-6444.
Sincerely, 4
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. uller President & CEO cc)
Mr. L. G. Dusek Ms. Marilyn Meigs Portland General Electric BNFL Inc.
th 71760 Columbia River Hwy, 90017 Street NW, Suite 1050 Rainier, OR 97048 Washington, DC 20006-2501 Mr. Dan Gildow Mr. Max DeLong Portland General Electric Project Engineer
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71760 Columbia River Hwy.
Private Fuel Storage, LLC Rainier, OR 97048 c/o NSP,512 Nicollet Mall Minneapolis, MN 55401 F
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US Nuclear Regulatory Commission BFS/NRC 99-020 Page1 STATE OF CALIFORNIA COUNTY OF SANTA CRUZ Edward D. Fuller states that he is the President and Chief Executive Officer of BNFL Fuel Solutions; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
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Edw'ard D. Fuller President & CEO BNFL Fuel Solutions Corporation i
Sworn to and subscribed before me this day or Fdrot4,v, 1999,by 1
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US Nuclear Regulatory Commission BFS/NRC 99-020 Page 2 TranStor Part 72 Storage Cask System l
AFFIDAV!T IN SUPPORT OF PROPRIETARY INFORMATION CONTAINED IN BNFL FUEL SOLUTIONS DESIGN DRAWINGS State of Califomia, County of Santa Cmz I, Edward D. Fuller, being ddy sworn, depose and state as follows:
(1) I am the President and Chief Executive Officer of BNFL Fuel Solutions ("BFS") 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 design drawings listed below. The proprietary material in these documents is delineated by proprietary designation on specific pages or within specific sections of the pages.
TSB-001, Sheet 2/6, Rev. 4 TSB-001, Sheet 3/6, Rev. 4 TSB-001, Sheet 4/6, Rev. 4 TSB-001, Sheet 5/6, Rev. 4 TSB-002, Sheet 1/2, Rev. 4 TSB-002, Sheet 2/2, Rev. 4 TSB-005, Sheet I/1, Rev. 4 TSB-006, Sheet 1/1, Rev. 4 TSB-007, Sheet 1/l, Rev. 4 TSB-008, Sheet 1/1, Rev. 4 TSB-009, Sheet 1/l, Rev. 4 TSB-010, Sheet 1/1, Rev. 4
)
i (3) In making this application for withholding of proprietary information of which it is the owner, BFS relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 U.S.C. @ 552(b)(4), and the Trade Secrets Act,18 U.S.C.
1905, and NRC regulations 10 C.F.R. s 9.17(a)(4),2.790(a)(4), and 2.790(d)(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 assigned to those terms for purposes of FOIA Exemption
- 4. S_ce Critical Mass Enercy Pro _iect v. NRC,975 F.2d 871 (D.C. Cir.1992), cert.
c denied,507 U.S. 984 (1993); Public Citizen Health Research Group v. FDA,704 F.2d 1280 (D.C. Cir,1983).
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US Nuclear Regulatory Commission BFS/NRC 99-020 Page 3 (4) Information that is held in confidence, meaning if the information is released, it might result in the loss of an existing or potential competitive advantage, falls into one or more of the following categcry types:
(a) The information reveals the distinguishing aspects of components, and the prevention ofits use by BFS's competitors, without license from BFS, gives BFS a competitive economic advantage.
(b) The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
(c) The information reveals aspects of past, present, or future BFS or customer funded development plans and programs of potential commercial value to BFS.
(d) The infomiation contains patentable ideas, for which patent protection may be desirable.
(5) The information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by BFS, 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 BFS, no public disclosure has been made, and it is not avail..ble in public sources. All disclosures to third parties including any required trans nittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the infonnation in confidence.
i (6) The procedure for approval of external release of such a document typically requires review by the project manager, lead technical and management personnel, and by the licensing director, for technical content, competitive effect, and determination of the i
accuracy of the proprietary designation. Disclosures outside BFS 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.
(7) The information identified in paragraph (2) is classified as proprietary because:
1 (i)
It contains detailed results of analytical models, computer codes, methods and processes, in which BFS has a proprietary interest and has applied to evaluations of the TranStor Part 72 Storage cask system for which BFS is seeking NRC approval.
US Nuclear Regulatory Commission BFS/NRC 99-020 Page 4 (ii)
The development and eventual approval of the designs represented in these documents was achieved at a significant cost to BFS.
(iii)
The interpretation and application of analytical results is derived from the extensve experience database that constitutes a major BFS asset.
(iv)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to BFS's competitive position and foreclose or reduce the availability of profit-making opportunities. The infomiation is part of BFS's technology base and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the analytical methodology and includes development of the expertise to determine and apply appropriate evaluation process. In addition, the technology base includes the value derived from NRC's eventual approval of the specific cask design.
(v)
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by BFS.
(vi)
BFS's competitive advantage will be lost ifits competitors are able to use the results of the BFS 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.
(vii)
The value of this information to BFS would be lost if the information were disclosed to the public. Making such infom1ation available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive BFS of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.
Y Edward D. Fuller BNFL Fuel Solutions Sworn to before me this/25 day ofW hropu 1999.
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US Nuclear Regulatory Commission BFS/NRC 99-020 Page 5 TranStor Part 72 Storage Cask System AFFIDAVIT IN SUPPORT OF PROPRIETARY INFORMATION CONTAINED IN BNFL FUEL SOLUTIONS CALCULATIONS State of California, County of Santa Cruz I, Edward D. Fuller, being duly sworn, depose and state as follows:
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(1) I am President and Chief Executive Officer of BNFL Fuel Solutions ("BFS") and have been delegated the function of reviewing the informatio. xscribed in paragraph (2), which is sought to be withheld, and have been authorized to apply for its i
withholding.
1 (2) The information sought to be withheld is contained in the calculations listed below.
The proprietary material in these documents is delineated by proprietary designation on specific pages or within specific sections of the pages.
BNFL1.10.06.07, Rev. 6 TSLO1.10.06.69, Rev. 2 l
TSLGl.10.06.70, Rev.1 (3)In making this application for withholding of proprietary information of which it is 4
the owner, BFS relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 U.S.C. G 552(b)(4), and the Trade Secrets Act,18 U.S.C.
1905, and NRC regulations 10 C.F.R. %$ 9.17(a)(4),2.790(a)(4), and 2.790(d)(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 assigned to those terms for purposes of FOIA Exemption
- 4. S_ee Critical Mass Enerav Proiect v. NRC,975 F.2d 871 (D.C. Cir.1992), cert.
denied,507 U.S. 984 (1993); Public Citizen Health Research Group v. FDA,704 F.2d 1280 (D.C. Cir.1983).
4
- (4) Infonnation that is held in confidence, meaning if the infonnation is released, it might result in the loss of an existing or potential competitive advantage, falls into one or more of the following category types:
(a) The information reveals the distinguishing aspects of components, and the prevention ofits use by BFS's competitors, without license from BFS, gives BFS a competitive economic advantage.
US Nuclear Regulatory Commission BFS/NRC 99-020 Enclostre 1 Page 6 (b) The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or heensing of a similar product.
(c) The information reveals aspects of past, present, or future BFS or customer funded development plans and programs of potential commercial value to BFS.
(d) The information contains patentable ideas, for which patent protection may be j
desirable.
(5) The information sought to be withheld is being submitted to NRC in confidence. The information is of a son customarily held in confidence by BFS, 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 BFS, no public disclosure has been made, and i
it is not available in public sources. All disclosures to third panies including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the information in confidence.
(6) The procedure for approval of extemal release of such a document typically requires review by the project manager, lead technical and management personnel, and by the licensing director, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside BFS 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.
(7) The informe. tion identified in paragraph (2) is classified as proprietary because:
(i)
It contains detailed resul s of analytical models, computer codes, methods and processes, in which BFS has a proprietary interest and has applied to evaluations of the TranStor Part 72 Storage cask system for which BFS is seeking NRC approval.
(ii)
The development and eventual approval of the designs represented in these documents was achieved at a significant cost to BFS.
(iii)
The interpretation and application of analytical results i; derived from the j
extensive experience database that constitutes a major BFS asset.
(iv)
Public disclosure of the infonnation sought to be withheld is likely to cause substantial harm to BFS's coni; titive position and foreclose or reduce the availability of profit-making opportunities. The information is l
US Nuclear Regulatory Commission BFS/NRC 99-020 Enclosure i Page 7 part of BFS's technology base and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the analytical methodology and includes development of the expertise to determine and apply appropriate evaluation process. In addition, the technology base includes the value derived from NRC's eventual approval of the specific cask design.
(v)
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by BFS.
(vi)
BFS's competitive advantage will be lost ifits competitors are able to use the results of the BFS 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.
(vii)
The value of this information to BFS would be lost if the infomiation 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 BFS of the opponunity to exercise its competitive advantage to seek an adequate re*. urn on its large investment.
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~hdward D. Fuller BNFL Fuel Solutions Sworn to before me thisy ay of buuv 1999.
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US Nuclear Regulatory Commission BFS/NRC 99-020 Enclosure i Page 8 TranStor Part 72 Storage Cask System AFFIDAVIT IN SUPPORT OF PROPRIETARY INFORMATION CONTAINED IN BNFL FUEL SOLUTIONS QUALIFICATION REPORTS State of California, County of Santa Cruz I, Edward D. Fuller, being duly swom, depose and state as follows:
(1) I am President and Chief Executive Officer of BNFL Fuel Solutions ("BFS") 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 qualification report listed below. The proprietary material in these documents is delineated by proprietary designation on specific pages or within specific sections of the pages.
ANAMET Test Report, Laboratory Number 5003.001, Rev.1 ANAMET Test Report, Laboratory Number 5003.364 ANAMET Test Report, Number 5003.364A American Drill Bushing Modified Hoist Ring Pull Test (3) In making this application for withholding of proprietary information of which it is the owner, BFS relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 U.S.C. @ 552(b)(4), and the Trade Secrets Act,18 U.S.C. Q 1905, and NRC regulations 10 C.F.R. 9.17(a)(4),2.790(a)(4), and 2.790(d)(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 assigned to those terms for purposes of FOIA Exemption
- 4. See Critical Mass Enerev Project v. NRC,975 F.2d 871 (D.C. Cir.1992), cert.
denied,507 U.S. 984 (1993); Public Citizen Health Research Group v. FDA,704 F.2d 1280 (D.C. Cir.1983).
(4) Information that is held in confidence, meaning if the information is released, it might result in the loss of an existing or potential competitive advantage, falls into one or j
more of the following category types:
(a) The information reveals the distinguishing aspets of components, and the prevention ofits use by BFS's competitors, without license from BFS, gives BFS a competitive economic advantage.
US Nuclear Regulatory Commission -
BFS/NRC 99-020 Page 9 (b) The infonnation, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
l (c) The information reveals aspects of past, present, or future BFS or customer funded development plans and programs of potential commercial value to BFS.
(d) The information contains patentable ideas, for which patent protection may be desirable.
(5) The information sought to be withheld is being submitted to NRC in confidence. The infomiation is of a sort customarily held in confidence by BFS. 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 BFS, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or naust be made, pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the information in confidence.
(6) The procedure for approval of external release of such a document typically requires review by the project manager, lead technical and management personnel, and by the licensing director, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside BFS 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.
(7) The information identified in paragraph (2) is classified as proprietary because:
l t
i (i)
It contains detailed results of analytical models, computer codes, methods and processes, in which BFS has a proprietary interest and has applied to evaluations of the TranStor Part 72 Storage cask system for which BFS is seeking NRC approval.
(ii)
The development and eventual approval of the designs represented in these documents was achieved at a significant cost to BFS.
l (iii)
The interpretation and application of analytical results is derived from the l
extensive experience database that constitutes a major BFS asset.
(iv)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to BFS's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is l
l t
US Nuclear Regulatory Commission BFS/NRC 99-020 Page 10 part of BFS's technology base and its commercial value extends beyond.
the original development cost. The value of the technology base goes beyond the analytical methodology and includes development of the expertise to determine and apply appropriate evaluation process. In addition, the technology base includes the value derived from NRC's i
eventual approval of the specific cask design.
(v)
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by BFS.
(vi)
BFS's competitive advantage will be lost ifits competitors are able to use the results of the BFS experience to normalize or verify their own process i
or if they are able to claim an equivalent understanding by demonstrating that they can anive at the same or similar conclusions.
(vii)
The value of this information to BFS 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 BFS of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.
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^- L Edward D. Fuller BNFL Fuel Solutions i
4h Sworn to before me this M - day of %crva q 1999.
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ENCLOSURE 2 I
TIPOVER AND COATINGS 1
A) Calculation BNFL1,10.06.65 B) Calculation BNFLI.10.06.70 3
C) Revised RAI Responses.
j D) TranS' orm Part 72 SAR Revision D
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