ML20217B345
| ML20217B345 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/23/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20013F918 | List: |
| References | |
| W3F1-98-0040, W3F1-98-40, NUDOCS 9803260042 | |
| Download: ML20217B345 (76) | |
Text
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y Entergy Operiti:ns,Inc.
Kdona. LA 700640751 Te! 504 739 6660 Charles M. Dugger we res nt. Opmatms W3F1-98-0040 A4.05 PR ATTACHMENTS 1, 3, 4, 5, 6, 7, 8, 9,10,12 and 13 CONTAIN PROPRIETARY INFORMATION March 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 Request for Additional information (RAI) Regarding Technical Specification Change Request NPF-38-193 Gentlemen:
By letter dated March 27,1997, Waterford 3 proposed to amend Operating License NPF-38 to increase the Spent Fuel Pool storage capacity and increase the maximum fuel enrichment. The NRC review staff requested additional information in their letter dated February 11,1998 regarding the proposed changes. This information is included in Enclosure 1 to this submittal.
This submittal also includes, as Enclosure 2, additional information requested at the NRC/Entergy meeting on February 19,1998; and, as Enclosure 3, additional information requested in an NRC/Entergy telecon on March 9,1998.
/
The information in this submittal has no effect on the previously provided f
determination of no significant hazards.
Please note that Attachments 1,3,4,5,6,7,8,9,10,12 and 13 contain information dfD[
that is considered proprietary pursuant to 10CFR2.790. In this regard, Entergy requests that these attachments be withheld from public viewing. Please note that the respective Holtec international affidavits, pursuant to 10CFR2.790, precede the material in these attachments.
9003260042 980323 PDR ADOCK 05000382 P
PDR k il ti U U 1 (Ok
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T Request for Additional information (RAl) Regarding Technical Specification Change Request NPF-38-193 W3F1-98-0040 Page 2 March 23,1998 Should you have any questions or comments concerning this request, please contact Roy Prados at (504) 739-6632.
Very truly yours, M
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r C.M. Dugger Vice President, Operations Waterford 3 CMD/RWP/tmm
Enclosures:
Affidavit Attachments (w/ Enclosures & Attachments) cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR (w/o Enclosures & Attachments) cc:
J. Smith N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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)
Entergy Operations, Incorporated
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' Docket No. 50-382 Waterford 3 Steam Electric Station
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'. 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 Additional Information Regarding Technical Specification Change Request NPF-38-193; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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W Charles Marshall Dugger Vice President Operations - Waterford 3 STATE OF LOUISIANA
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) ss PARISH OF ST. CHARLES
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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this > c :. I day of ht./
,1998.
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/L Notary Public
' My Commission expires SAM.
ENCLOSUR'i 1 4
ADDITIONAL INFORMATION REGARDING TECHNIC AL SPECIFICATION CHANGE REQUEST NPF-38-193 lte'm 1 HOLTEC INTERNATIONAL performed an analysis using a computer code,
" Computational Fluid Dynamics, (CFD)" to demonstrate that adequate cooling is provided by natural circulation in the cask pit area. Although the detailed mathematical modeling in CFD has not been provided, it is apparent that the analytical solution is developed by considering the conservation equations of mass, momentum and energy, and the equation of state, together with the control volume (nodalization) technique for simulating spatial variation. Provide the following information:
a.
Provide schematic drawing showing the nodalization (number of control volumes) used in the analysis. The nodal volume, initial temperature, heat source and interconnecting flow path areas for each node should also be indicated on the drawing.
b.
Describe the nodalization sensitivity studies performed to determine the minimum number of nodes required to predict the water flow: from the refueling canal into the fuel cask pit; and from the fuel cask pit to the spent fuel pool (SFP).
The nodalization sensitivity studies should include consideration of spatial temperature variation; i.e. temperature variations circumferentially, axially and radially within each node.
c.
Provide and justify preferably by comparison with experimental data the equation or correlation used to calculate the temperature and flow between two volumes, d.
Describe in detail how the velocity vectors and temperature gradients in the gateways between the refueling canal and the fuel cask pit, and between the fuel cask pit and the SFP will be verified.
Response 1 The detailed mathematical modeling of the Waterford 3 thermal-hydraulic analysic for reracking was carried out on the FLUENT Computational Fluid Dynamics (CFD) analysis code. FLUENT is a general purpose CFD code with over two decades of extensive application. Attachment 1 to this response provides Holtec Intemational Position Paper WS-121, which is a summary of benchmarking work on FLUENT by others and by Holtec International. The Navier-Stokes equations of fluid motion along with mass and energy balance equations solved by this code are fully described in the user's manual. Attachment 2 provides a copy of the Theory section of this manual.
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a.
The figure included herein as Attachment 3 provides a schematic of the original nodalization scheme developed for the Waterford 3 CFD analysis. Due to the large number of computational cells in the original nodalization scheme (a total of 4100 cells used to model the Waterford 3 pool system), it is not possible to indicate all of the requested nodalinformation in Attachment 3. Attachment 3 does not provide a scaled size of the computation cells. ' Rather, it provides a visual confirmation of the number of cells used to model a particular region in the physical space being analyzed. It is seen from Attachment 3 that in the x-direction (horizontal), there are eighty-two subdivisions (I = 1,2.. 82) of the space. The y-direction (vertical) has fifty subdivisions (J = 1,2.. 50). The relatively narrow bottom plenum (space below the rack baseplate) is modeled by five vertical subdivisions in each of the three spaces. While Attachment 3 provides information on the degree of discretization in each space, the figure included as Attachment 4
. provides the cell sizes to " scale". In summary, Attachment 3 provides the interconnections between the computational cells in the horizontal and vertical extent of the physical model. The physical mesh mapped by this scheme is shown in Attachment 4. The physical region mapped by the nodalization scheme represents a vertical planar cross-section of the Waterford 3 Refueling Canal (1-cell count from 2 to 15), Cask Storage Pit (I-cell count from 20 to 48) and Spent Fuel Pool (1-cell count from 52 to 81). The three regions are separated by wall boundary cells labeled W1 (1-cell count 16-19 and 49-51). These cells are mapped as shown in Attachment 4 to represent the physical isolation of the three bodies of water below the bottom level of the interconnecting gates between the Refueling Canal and the Cask Storage Pit and between the Cask Storage Pit and the Spent Fuel Pool. The fluid cells (above the racks, downcomer and bottom plenum areas) in each of the three regions are depicted as empty (unmarked) cells. The heat generating fuel rack cells are depicted in light blue as porous media cells (labels *1, *3 & *4). The porous media region cells labeled *2 depict the cells which model pressure drop due to flow constriction in the interconnecting gate regions. The dark blue cells in the Spent Fuel Pool region represent water inlet and outlet boundaries.
b.
In the figure given in Attachment 5, a volumetric heat source contour plot is provided to depict the distributed heat sources in the pool racks. The maximum 5
heat source in the Cask Storage Pit racks (-3.98*10 W/m ) corresponds to freshly discharged fuel from the reactor. The initial water temperature in the cells at the start of CFD solver iterations is selected to be uniform for the Spent Fuel Pool, Cask Storage Pit, and Refueling Canal. The temperature field is iteratively refined to the final converged results provided in Technical Specification Change Request NPF-38-193 submitted to the NRC on March 27,1997.
Solutions presented in the March 27,1997 submittal are numerically converged.
' To respond to the concern with respect to the ability of the computational cell size depicted in Attachment 3 to provide an accurate portrayal of the temperature and 2 of 10
I velocity fields in the Waterford 3 pool system, a refined nodalization scheme is developed as shown in the figure provided in Attachment 6. The number of computational cells is increased considerably (from 4,100 to 15,876 cells). The figures provided in Attachments 7 and 8 present the temperature field solutions corresponding to the 4,100 cell and 15,876 cell (refined grid) cases, respectively.
From Attachments 7 and 8, a comparison of the converged temperature fields obtained with original mesh and refined mesh respectively can be performed by direct inspection. The two temperature solutions are virtually identical.
Quantitatively, the local peak temperature prediction in the original case (i.e.,
361.6'K) is only half a degree apart from the refined mesh solution (i.e.,362.1 K).
It should be noted that the temperature and velocity fields are tightly coupled in pool natural convection cooling scenarios. Therefore, the mesh size converged temperature field implies that the velocity fields are likewise converged. Thus, it is concluded that the original nodalization scheme provides an accurate characterization of the Waterford 3 thermal analysis.
c.
Benchmarking of FLUENT against experimental data is presented in Holtec International Position Paper WS-121 (Attachment 1).
Evidence directly pointing to enthalpy exchange between two bodies of water separated by a gated opening is also provided by the Millstone Unit 3 (MP3) pool evaporation experiments jointly carried out by Holtec International and Northeast Utilities in 1990. The central purpose of the MP3 experiments was to benchmark the pool evaporation correlation. These tests also provide conclusive evidence that the thermal-gradient driven fluid exchange between a Spent Fuel I
Pool and an adjoining Cask Storage Pit is sufficient to homogenize the temperature field despite a physical situation which is most adverse. The MP3 composite pool layout is shown in the figure provided in Attachment 9. In this figure, the fuel storage racks containing spent fuel were located in the Spent Fuel Pool which contains the cooling water intake and discharge lines. The Cask Storage Pit area, which contains no cooling connections, is connected to the Spent Fuel Pool via an interconnecting channel. Temperature probes at locations P1, P2 and P3, indicated in this figure, were used to monitor the temperature in the heated Spent Fuel Pool and adjoining (no decay heat input) Cask Storage Fit areas. Initially, with a uniform pool temperature of approximately 87 F, the forced cooling was stopped. The transient temperature rise in the Spent Fuel Pool and Cask Storage Pit areas were monitored via the tempeiature probes. Plots of the temperature transients are provided in the figure given in Attachment 10 which show that there was virtually no temperature difference between the two connected bodies of water. From the experimental data it is clear that there was a rapid homogenization of the Spent Fuel Pool and Cask Storage Pit temperatures during the transient heating period. This homogenization is impossible without the exchange of water between the Spent Fuel Pool and Cask Storage Pit areas through the interconnecting channel.
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m The MP3 experiment leads to the following conclusions:
1.
- The temperature of the water in the Spent Fuel Pool away from the region where the spent fuel is stored is essentially uniform.
~ ii.
The temperature of water in the Cask Storage Pit closely approximates the temperature of water in the Spent Fuel Pool even though the Cask Storage Pit has no forced water ingress or exit, and does not contain any heat producing fuel, iii.
Despite the condition of thermal transience, the homogenization of the
. Spent Fuel Pool and Cask Storage Pit water temperatures is nearly complete.
In summary, the MP3 experimental observations confirm the numerical results obtained from FLUENT for the Waterford 3 storage system.
d.
The CFD solution of the Waterford 3 thermal analysis presented in the March 27,1997 submittal corresponds to heat loads which are extremely conservative. The total number of spent fuel assemblies in storage will never actually be more than 2,104. The bounding decay heat load used in the thermal hydraulic analysis is based on 2,485 assemblies which is greater than the proposed cell capacity of 2,398 assemblies. The spent fuel burnup and cooling times are also taken as bounding values to maximize the computed heat loads.
In the actual storage conditions, the heat loads and cooling water temperatures will be much lower, resulting in lower SFP and Cask Storage Pit temperatures, and a correspondingly reduced rate of inter-body water exchange. Therefore, the predicted velocity vectors and temperature gradients are beyond those anticipated for real conditions and may never be experienced. Therefore, physical verification of the computed flow rates will not be possible. However, as stated above, the prediction of rapid pool homogenization has been confirmed by virtue of the comparison with the similar situation in the Millstone experiment.
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Item 2 Please provide the average exchange flow rate across the area of the opening between the cask storage pit and the SFP. Also, provide the average exchange flow rate across the area of the opening between the Cask Storage Pit and the Refueling Canal.
Describe in detail how these exchange flow rates were derived and how these flow rates will be verified.
Response 2 The average flow over the area of the opening between the Cask Storage Pit and the SFP provides an estimated fluid exchange rate of about 13,000 gpm. The average flow over the area of the opening between the Cask Storage Pit and the Refueling Canal provides an estimated fluid exchange rate of about 8,000 gpm. The exchange flow rates were determined by post-processing the converged velocity field results from the
' FLUENT based CFD analysis model of the Waterford 3 SFP, Cask Storage Pit, and Refueling Canal areas (see Figure 5.8.10 of Holtec International Report HI-9717628 provided in the March 27,1997 submittal). The water mass flows entering the CFD model cells representing the two interconnecting channels were integrated by the FLUENT post-processor commands. The integrated mass flow rate, reported by FLUENT is provided in volumetric flow units, as reported above.
As discussed in response to item 1(d), physical verification of the computed flow rates across the openings in question is not possible, since the conditions assumed for the extreme cases analyzed shall never be realized.
Item 3 In your December 12,1997 submittal, EOl indicated that the decay heat generated from 294 previously discharged spent fuel assemblies (SFAs) proposed to be stored in the 8
refueling canalis approximately 1.8x10 Btu /hr. How long are these 294 SFAs required to be stored in SFP prior to being transferred to the refueling canal? Will this time requirement be included in the TS? If not, describe how this requirement will be assured.
Response 3 8
The heat load used for the Refueling Canal was 1.72x10 Btu /hr based on 294 assemblies with average cooling time for the background fuel. This is slightly less than 8
three and one-half percent (3.41 %) of the maximum decay heat load (50.4x10 Btu /hr; see Response 7 below) to be removed by the cooling system. Installation of storage racks in the Refueling Canal would be performed after the final fuel cycle assembly is discharged. The design basis and licensing basis will be revised, after approval of this 8
amendment, to ensure that the heat load does not exceed 1.72x10 Btu /hr in the
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Refueling Canal. Also, prior to installation of the Refueling Canal racks, fuel movement procedures will be revised to include the limitation of heat load to be placed in the Refueling Canal.
The heat load limitation will be used instead of a cooling time requirement because this will allow more flexibility in determining which assemblies may be placed in the Refueling Canal racks (i.e., a cooling time requirement would have to be based on a worst case assembly burnup and enrichment, which would be overly conservative).
Item 4 Since 294 previously discharged SFAs would be stored in the refueling canal, discuss how the SFAs from the last fuel cycle would be discharged to the SFP.
Response 4 The storage rack modules proposed for the Refueling Canal would not be installed until after the final fuel assembly is removed from the reactor initially, only the SFP racks (1,849 spaces) and the Cask Storage Pit racks (255 spaces) will be installed. This will give a total capacity of 2,104 installed spaces.
After permanent plant shutdown, the 217 assemblies in the reactor vessel will be removed and placed in the Cask Storage Pit (assuming that the Spent Fuel Pool is filled to capacity). The fuel transfer carriage mechanisms located at the bottom of the Refueling Canal will be removed subsequent to removal of the last fuel assembly from the reactor and before installation of any racks in the Refueling Canal. After the upender and transfer carriages are removed the Refueling Canal racks will be installed.
Old fuel from the spent fuel pool, which meets the Refueling Canal heat load limitations, will then be transferred into the Refueling Canal racks. The fuel assemblies stored in the Cask Storage Pit will then be moved into the open spaces in the Spent Fuel Pool.
The Cask Storage Pit racks will then be removed to allow a spent fuel cask to be placed into the Cask Storage Pit and loaded with spent fuel.
The storing of fuel in the Refueling Canal will only be implemented if sufficient storage does not remain in the SFP and Cask Storage Pit to allow loading of spent fuel casks at the end of plant life. The 294 storage locations in the Refueling Canal are intended to provide additional temporary storage capacity to move sufficient fuel and racks from the Cask Storage Pit to allow submergence and loading of a spent fuel cask. As stated above there will never be a total of more than 2,104 assemblies stored in the three storage regions (SFP, Cask Storage Pit and Refueling Canal).
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1 I
Item 5 A backup fuel pool heat exchanger with a low design heat removal capacity (15.4x10' Btu /hr) is used when the SFP heat exchanger is out of service. Discuss what provisions have been established in the plant operating procedures to ensure that the SFP heat exchanger will not be taken out of service whenever the SFP heat load is higher than the backup heat exchanger design heat removal capacity of 15.4x10' Btu /hr.
Response 5 System Operating Procedure OP-002-006, " Fuel Pool Cooling and Purification" currently contains a Limitation (Section 3.2.9) and three Cautions (Sections 6.1,6.2 and 6.3) that establish administrative limits concerning capacity of the Back-Up Spent Fuel Pool Heat Exchanger.
These limitations and cautions are for the presently licensed Spent Fuel Pool capacity of 1088 spent fuel assemblies. Following approval of Technical Specification Change Request NPF-38-193, the limitations and cautions in OP-002-006 will be revised to reflect the administrative limits that correspond to the increased spent fuel storage
- capacity, item 6 Table 9.1-3 of the UFSAR indicates that the SFP cooling system would be able to maintain the SFP temperature at 155 F with a SFP heat load of 47.0x10' Btu /hr. Since
. the previously calculated SFP heat load for a full core off-load is 55.7x10' Btu /hr, what is the corresponding calculated SFP temperature for this previously calculated SFP heat load? Does it exceed the design basis of 155 F as stated in the UFSAR?
Response 6
. This question pertains to the conditions currently analyzed (prior to reracking) for Waterford 3. The steady state bulk pool temperature of 155*F represents the current Waterford 3, self imposed, design basis (NUREG 0800 allows for a higher 8
temperature). This temperature results from a pool heat load of 47.0 x 10 Btu /hr cooled through the Spent Fuel Pool Cooling System Heat Exchanger with a Component Cooling Water (CCW) inlet temperature of 100*F. Maintaining the bulk pool temperature at 155*F under a heat load of 55.7 x 10' Btu /hr requires a CCW inlet
- temperature of 89*F. The variation of heat load is determined by time after shutdown.
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The 47 0 x 10 Btu /hr and 55.7 x 10 Btu /hr values correspond to the heat load of the entire core instantaneously placed into the SFP five and three days after shutdown, respectively.' These heat loads are conservative, since some finite time would be 7 of.10
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required to transfer the entire core from the Reactor (the Waterford 3 Technical Specifications do not allow any fuel movement until three days after reactor shutdown).
The relationship between cooling time, heat load, and the CCW inlet temperature is provided in UFSAR Figure 9.1-21, which is included as Attachment 11. As may be seen in the notes for this figure, the pool bulk temperature is maintained at the current design basis temperature of 155 F.
Item 7 in your March 27,1997 submittal, EOl stated that the SFP cooling system heat load for 8
a full core off-load is 50.4x10 Btu /hr, however, Figure 5.8.4 of the submittal and Attachments 8A and 8C of December 12,1997 submittalindicate that the SFP cooling 8
system heat load for a full core off-load is 52.65x10 Btu /hr. Discuss the differences in these values.
Response 7 8
The March 27,1997 submittal contains the heat load value of 50.4x10 Btu /hr in the Safety Assessment discussion. This value is consistent with the value under the column labeled " Coincident Exchanger Heat Removal"in Table 5.8.1 of Holtec International Report HI-971628 (submitted as part of Technical Specification Change Request NPF-38-193). The adjacent column labeled " Coincident Evaporation Heat 8
Removal"in Table 5.8.1 provides a value of 1.08x10 Btu /hr. This second value is the portion of the total fuel decay heat load (at the instant of maximum bulk pool temperature) which is being dissipated to the environment (through ambient heat losses). The total fuel decay heat load is determined by adding the two values to obtain 8
51.48x10 Btu /hr. This value is slightly less than the maximum fuel decay heat load, which occurs earlier. The two values occur at different times due to thermal inertia. The maximum fuel decay heat load occurs at the instant when the last fuel assembly enters the storage pool from reactor discharge.
The maximum fuel decay heat load value may be obtained from Attachments 8A and 8
8C of the December 12,1997 submittal by adding the values 42.05x10 Btu /hr from 8
e A and 10.06x10 Btu /hr to obtain a value of 52.11x10 Btu /hr. This is the proper peak value of the curve shown in Figure 5.8.4 of Holtec International Report HI-971628.
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At the point in time when the maximum fuel decay heat load (52.11x10 Btu /hr) occurs, the pool bulk temperature is still rising. Some of this heat load is lost to ambient and 8
some is taken to raise the bulk pool temperature. Therefore, the 50.4x10 Btu /hr value coinciding with the maximum bulk pool temperature does represent the maximum heat load required to be removed by the SFP cooling system.
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Item 8
. In your March 27,1997 submittal, EOl stated that the maximum SFP cooling system heat load for a full core off-load is 50.4x10' Btu /hr which is lower than the previously 8
calculated value of 55.7x10 Btu /hr as indicated in Table 9.1-3 of the UFSAR. The difference is because in the previous analysis the entire core is discharged instantaneously 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after reactor shutdown. However, for the routine refueling it is not clear why the maximum SFP cooling system heat load is much higher (33.7x10 8
Btu /hr vs. 22.2x10 Btu /hr) than the previously calculated value. Discuss these differences.
Response 8 For most discharge scenarios the majority of the SFP heat load is due to the fuel assemblies that are currently being discharged (the background heat load from the fuel already in storage is much less than the decay heat from the currently discharged 4
assemblies). The 22.2x10 Btu /hr decay heat load is based on a partial core discharge of 96 assemblies five days after reactor shutdown plus 992 background fuel assemblies (total of 1088 spent fuel assemblies). The new, routine refueling, heat load is higher because it is based on a cooling time of only three days for the partial core discharge of 116 assemblies plus 2,369 background fuel assemblies filling the remainder of the pools (total of 2485 spent fuel assemblies). This is conservative because, as stated in responses 1(d) and 4 above, there will never be more than a total of 2,104 assemblies in storage. The governing design basis values (enrichment and burnup) that were used in the new analysis are also much more conservative (higher) than the values that were used for the current analysis. These factors (more assemblies discharged at higher burnups and initial enrichments with a shorter in reactor cooling time; and with more background fuel) are all in the direction to increase the decay heat load and when combined result in a higher routine refueling heat load for the new analysis. It should also be noted that the 116 fuel assembly discharge number used for this partial core discharge scenario was chosen as a bounding value and is based on a two (2) year fuel cycle. The previous analysis (96 fuel assembly discharge) did not envision a two year fuel cycle and was based on an eighteen month fuel cycle.
For the full core off-load the number of asse'mblies discharged in both cases is identical (217). For the new analysis the higher burnup and enrichment values would again result in a higher heat load (everything else being equal) but the longer, in reactor, cooling time used for the new analysis outweighs these factors (and the increased heat load from the increased number of background fuel assemblies) and results in a slight decrease in heat load. The decay heat load decreases exponentially with time after reactor shutdown. For the previous analysis the 217 fuel assemblies were assumed to be instantaneously discharged to the SFP three days after reactor shutdown. In the new analysis the 217 fuel assemblies are discharged at a rate of four assemblies per 9 of 10
hour starting at three days after reactor shutdown. This is a more realistic, although still very conservative, discharge scenario. In this full core off-load case, the longer, in reactor, cooling time is governing and results in an overall heat load reduction.
Item 9 Discuss how spent fuel will be loaded into casks when the cask storage pit is filled with spent fuels.
Response 9 Prior to loading a spent fuel cask, fuel assemblies and storage rack modules will be removed from the Cask Storage Pit. As described in the response to item 4, the 294 storage locations in the Refueling Canal provide additional temporary storage capacity
' to remove sufficient fuel and racks from the Cask Storage Pit to allow loading of a spent fuel shipping cask.
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ENCLOSURE 2 ADDITIONAL ITEMS POSED AT THE FEBRUARY 19,1998 MEETING ltem 1 in the event of complete loss of cooling in the Cask Storage Pit and the Refueling Canal, how long will it take the water to boil. Discuss the means for providing make-up water to these areas.
In the response Entergy indicated that in the unlikely event that there is a complete loss of SFP cooling capability, the evaluation of time-to-boilin the SFP, Cask Storage Pit and Refueling Canal is presented in Section 5.8 of Holtec International report HI-971628. However, Section 5.8 of Holtec International report Hi-971628 only addressed the timn-to-boil for the SFP and not the Cask Storage Pit and Refueling Canal. In addition, boil-off rates, sources of makeup and the methods / systems used to provide the makeup water have not been discussed.
Response 1 The CFD analysis has demonstrated an adequate exchange of water between the three bodies of water, namely the SFP, the Cask Storage Pit and the Refueling Canal. This exchange of water is driven by buoyancy forces generated from temperature differences in the bodies of water. During loss of forced cooling scenarios, this exchange of water continues without interruption, thereby homogenizing the water temperatures in the Cask Storage Pit, Refueling Canal and the Spent Fuel Pool.
During post loss of cooling scenarios, the temperature of water in the three bodies will simultaneously rise with time. Consequently, the aggregate thermal inertia of water in the three areas (i.e. SFP, Cask Storage pit, and Refueling Canal) directly participate in the post loss of cooling heat up. The post loss of cooling time to boil curves provided in Section 5.8 of Holtec International Report HI-971628 are developed for a bounding decay heat load coincident with peak bulk temperature and conservatively crediting the thermal inertia of water in the SFP only. In other words, the thermal inertia of water in the Cask Storage Pit and Refueling Canal is not credited to the bulk pool time to boil computations. The heat up curves are therefore valid and conservative portrayals of bulk pool transient temperature responses.
As stated in Response 1 of the December 12,1997 submittal"It is not possible to produce bulk boiling (with regions connected and administrative controls in place) in any one region while maintaining a sub-boiling condition in others, because of extensive gravity induced heat and mass transfer fluxes." The times to boil for the SFP, the Cask Storage Pit, and the Refueling Canal are thus all identical and are given in Figures 5.8.5 through 5.8.8 of Holtec International Report HI-971628.
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The total decay heat load for the case iv (full core offload initiated 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after reactor shutdown at a rate of 4 assemblies per hour) scenario coincident with peak bulk pool 8
temperature is 51.48x10 Btu /hr. The boil off rate corresponding to this decay heat load a short time after pool heat up to boiling condition during loss of forced cooling is 53,066 lbs/hr (i.e.,96.48 gpm.) The time to boiling for this scenario is 2.89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> after loss of forced cooling.
Makeup to the SFP, the Cask Storage Pit and the Refueling Canal can be provided from either the Refueling Water Storage Pool (via the Refueling Water Storage Pool Purification Pump at 150 gpm, the Condensate Storage Pool (via the Component Cooling Water Makeup Pumps at 600 gpm) or the Fire Water System (at approximately 100 gpm). The Refueling Water Storage Pool and the Condensate Storage Pool are the normal makeup water sources for the Spent Fuel Pool.
Item 2 in the December 12,1997 submittal, Entergy stated that the high SFP temperature alarm is set at 135*F and that there are three barriers for ensuring that SFP heat load and water temperature limits are not exceeded. The first barrier is an engineering review of the "Groundrules". The second barrier is system operating procedure OP-002-006, " Fuel Pool Cooling and Purification," which directs the operators to maintain the SFP temperature to less than 130*F. The third barrier is in the event of high SFP temperature alarm, plant procedure OP-901-513 and site directive W2.501 have provisions to ensure that appropriate corrective actions are taken. Please provide the following information:
a.
Discuss what the above cited "Groundrules" are. Under what circumstance and how often these groundrules will be reviewed, is the requirement of this groundrule review a part of the plant operating procedures?
b.
Operating procedure OP-002-006 directs the operators to maintain the SFP temperature to less than 130 F which is 5 F below the high SFP temperature alarm set-point. Discuss how often the SFP temperature is monitored and what actions the operators will have to perform in order to maintain the SFP temperature to less than 130 F.
c.
Discuss what are the appropriate corrective actions (i.e. prohibit fuel handling, aligning other systems to provide SFP cooling, etc.) to be taken in the event of high SFP temperature alarm.
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Response 2 The following provides responses to the above.
a.-
The "Groundrules" document is an official Waterford 3 Design Engineering.
calculation (prepared in accordance with Design Engineering Procedures NOECP-011, " Engineering Calculations" and NOECP-702, " Processing and Approval of Groundrules and Reload Analysis Reports"). It gives the values of the design parameters that the reload fuel fabricator then uses in the performance of the Safety Analysis for each batch of reload fuel. The key parameters that apply to the calculation of the decay heat load are fuel assembly burnup and initial enrichment. The proposed design uses values of 70,000 MWD /MT and 5.0 w/o U235 for these two parameters respectively. As long as the actual values used in the "Groundrules" are less than those values, the decay heat load used for the thermal-hydraulic analysis will not be exceeded. The "Groundrules" document
-(calculation) is prepared by Waterford 3 as part of the design process for each batch of reload fuel and is then provided, as design input, to the fuel fabricator some months prior to the actual fabrication of each batch of reload fuel. Site Directive W4.904, " Core Reload Selection and Review Process" ensures that this review occurs for each batch of reload fuel.
b.
Auxiliary operators log the local SFP temperature (in the Fuel Handling Building) once per shift (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). The Control Room operators also log the temperature once per shift. Monitoring of the SFP temperature is available to the Control Room operators via the Plant Monitoring Computer. Operating Procedure OP-002-006 directs the operators to start the second Fuel Pool Pump, if required, to maintain the Spent Fuel Pool Temperature less than 130 F. Operating Procedure OP-901-513 provides instructions for responding to a Spent Fuel Pool Cooling System malfunction such as reestablishing component cooling water flow to the heat exchanger, adding makeup water to the SFP (SFP cooling pumps trip on low level), checking for SFP leaks, checking for proper operation of the Fuel Pool Temperature Control valve and checking for heat exchanger leakage.
c.
In the event of a high Spent Fuel Pool Temperature Alarm, Operating Procedure OP-901-513 directs the Operators to check for and correct any system lineup or equipment malfunctions that may be the cause of the high pool temperature. This procedure also directs the operator to start the second Spent Fuel Pool Pump, if required, to maintain SFP temperature less than 130 F.
In the interest of Fuel Handling Building habitability and personnel safety (in case of inadvertent immersion in the SFP), Entergy intends to maintain the SFP temperature as low as possible. Due to the conservatisms built into the decay heat load used for the thermal-hydraulic analysis, in Entergy's judgment, it is prudent to leave the high temperature alarm set at 135'F in the belief that the 1
3 of 6
o actual spent fuel temperature will not reach 135 F for non faulted (two pump) operation. However, in the event that this temperature is reached, corrective action, such as, halting fuel movement or running the two SFP heat exchangers in parallel will be implemented to maintain the spent fuel pool temperature at an acceptable level. For faulted (one pump) operation, it is expected that the SFP temperature may reach or exceed 135 F. For this case, fuel movement will also be halted and the inoperable pump would be placed back into service as soon as possible. The frequency of monitoring the SFP temperature will be increased; and, depending on the estimated time to repair the faulted pump it may also be prudent to temporarily reset the high temperature alarm to slightly above the actual
. pool temperature. This would alert the operators to any additional increase in pool temperature.
Item 3 Will there be full core off-loads during routine refueling outages?
Response 3 At this time, Waterford 3 does not routinely conduct full core off-loads during routine refueling outages. The current design basis for a partial core off-load is in conformance with the SRP, which indicates that SFP temperature should be less than or equal to 140*F for the faulted condition (with one SFP cooling pump out-of-service). For full core off-load with two SFP cooling pumps in operation, the Waterford 3 design basis is 155*F, which is also in conformance with the SRP criterion to be less than boiling (during full core off-load and two pumps operating).
An analysis was conducted to determine the bulk temperature of the combined three regions (SFP, Cask Storage Pit and Refueling Canal) for a full core off-load with one SFP cooling pump out-of-service. The bulk region temperature for this condition was calculated to be 163.49'F. This condition considers the discharge of 217 assemblies into the Cask Storage Pit at the rate of four per hour starting at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after reactor shutdown and with a single active failure of the most efficient of the two pumps. For this analysis, the remainder of the Spent Fuel Pool and Cask Storage Pit storage cells were considered to be filled with average cooled background fuel. The total heat load used for this analysis is 51.48x10 Blu/hr (50.4x10' Btu /hr is rejected by the heat 8
exchanger and 1.08x10' Blu/hr is lost through evaporation).
The three considerations for a higher bulk combined region temperature are hot subchannel temperature increase, SFP Purification System resin degradation and the effect on the structural strength of the pool concrete. The predicted temperature of 163.49*F under the most extreme conditions has been determined to be acceptable for the following reasons:
4 of 6
o.
The hot subchannel result is acceptable in complying with the local subcooled e
criteria for storage rack cells.' The local maximum temperature is expected to increase from 192.2'F to 204.1*F, which is substantially below the water boiling temperature at the local (elevated) pressure. The pressure in the local hot subchannel is elevated due to the height of the water cv.umn above the
~
hot subchannel. The saturation temperature on top of the racks is 236*F. No nucleate boiling will therefore occur anywhere within the three regions.
The pool temperature alarm is currently set below 140 F, which provides sufficient margin to preclude damage to the purification system resins. The SFP purification system will be isolated prior to reaching temperatures at which damage to the resins will occur.
The elevated temperature will only occur for a short duration, as may be seen from a comparison of plots of the bulk region transient temperature for similar conditions, provided in Figures 5.8.1 through 5.8.4 of Holtec International Report HI-971628. Despite differences in the assumed conditions for these four figures. the profile of the reduction in bulk region temperatures after the peak is very similar. The profile of the curve for the case of full core discharge with single active failure is also expected to be similar. The temperature in excess of the 150 F maximum suggested by the American Concrete institute (ACl) code (ACl-349) is of short duration and is common practice. In addition, as described in Section 8.4 of Holtec Intemational Report HI-971628 the Fuel Handling Building has been successfully reanalyzed for an accident condition bulk temperature of 212*F. Therefore, there will be no reduction of concrete structural strength due to the higher, short time period, bulk temperature of 163.49 F.
Since the bulk region temperature of 163.49*F (occurs with full core off-load and one SCP cooling pump out-of-service) exceeds the SRP temperature criterion (140*F for this condition), Wa;erford 3 is not presently proposing to change the design basis.
However, it is anticipated that such a design basis change will be proposed in the future.
Item 4 Will both SFP pumps be available during refueling and full core off-load?
Response 4 Yes, both pumps will be available prior to commencement of fuel movement. However, to maintain consistency.with the intent of Standard Review Plan Section 9.1.3, the full
' 5 of 6
I core off-load scenario with a single active failure has been evaluated for Waterford 3.
Details of the conditions considered and the calculated results are stated in response to item 3 abovm item 5 The modeled location for the SFP cooling piping (intake and discharge) appears to be non-conservative for predicting temperatures in the Cask Storage Pit and Refueling Canal. Discuss the sensitivity, of the predicted local temperatures, to relocating the piping closer to the far (East) side of the SFP.
Response 5 The results of the base case, which considered the cooling piping located properly for the projection onto the 2D model was provided in Figure 5.8.9 of Holtec International Report HI-971628 and is replicated herein as Attachment 12. An additional analysis was performed considering that the inlet and discharge piping was located in the extreme North-East corner of the SFP. Modeling the piping at this location in the 2D model places the incoming coolant as far as possible from the Cask Storage Pit gate.
This additional model was prepared to establish the sensitivity of the location of the cooling pipe. The location previously modeled was correct for the projection of the piping onto the 2D model surface, but did not reflect the additional out of plane distance from the Cask Storage Pit gate opening. This additional distance is due to the cooling piping being located on the North wall of the SFP. Neglecting this additional distance between the cooling piping and the Cask Storage Pit gate opening is demonstrated to result in a negligible change in the local maximum temperature response.
The results of the local field temperatures for the revised model are shown in the figure given in Attachment 13. The revised model predicted a reduction of about 1*C of the maximum local temperature, which is located in a rack cell within the Cask Storage Pit.
This change represents very little difference from the original model results. Therefore, the model is not sensitive to the location of the cooling piping and the temperature and velocity fields remain stable under relatively large perturbations.
6 of 6
o ENCLOSURE 3
. ADDITIONAL ITEM FROM THE MARCH 9,1998 TELECON ltem 1 How will uniform concentration of soluble boron in the three regions (SFP, Cask Storage Pit and Refueling Canal) be ensured?
Response 1 Administrative controls currently require that a minimum boron concentration of 1720 ppm be maintained in the SFP. Uniform soluble boron is currently ensured in the three regions (SFP, Cask Storage Pit, Refueling Canal) by the exchange of fluid (due to natural convection) between the regions. The proposed change does not represent any change to this mechanism of boron homogenization in the three regions. However, the introduction of new heat sources, by the proposed change, serves to increase inter-region mixing from the mixing experienced (currently occurring) prior to the proposed change. The subject of fluid exchange is discussed more fully in items 1(c),1(d) and 2 of Enclosure 1; but just as there is no thermal segregstion similarly there can be no boron concentration segregation in the three regions as long as the gates remain removed. Natural convection currents ensure that there is always complete mixing.
It should be noted that the criticality safety evaluations did not take credit for soluble boron, except for the accident condition, which is a misloaded/ misplaced fuel assembly.
However, this accident scenario is not plausible for the flux trap style racks proposed for
. the Cask Storage Pit, since these racks are designed to accept fuel of the highest effective enrichment (new-unburned fuel at an enrichment of 5.0 w/o U235 with no bumable poison). The accident scenario of new fuelinadvertently being loaded into a Refueling Canal storage cell is also not possible, since these racks will only be installed subsequent to the final fuel offload of the reactor at the end of plant life (there will be no new fuel assemblies on site). In fact, as discussed in Section 4.7.4 of Holtec International Report HI-971628 and the Description of the Proposed Change preceding the Significant Hazards Consideration submitted on March 27,1997, for the most severe accident condition a soluble boron concentration of 700 ppm would be adequate to maintain k n below 0.95. Thus, far less than complete uniformity in soluble boron j
o concentration is required although, as discussed above, uniform boron concentration is achieved in all three regions.
)
1 of 1
ATTACHMENT 2
?
- - - - - - - - - ~
FLUENT User's Guide Volume 4 Version 4.3 March 1995 1
%2
Chapter 19.
Theory This chapter describes the governing fluid flow equations, the bound.
ary conditions, and the numerical procedure used in FLUENT. The continuous phase is addressed first, followed by the dispersed phase and interactions between the two-phases. While FLUENT solves all equations in general curvilinear coordinates, all equations are intro-duced in Cartesian tensor forms for simplicity. Information in the chapter is organized into the following sections:
e Section 19.1: Basic Conservation Equations for Laminar Flows e Section 19.2: Fluid Properties and the Equation of State e Section 19.3: Models for Turbulent Flows e Section 19.4: Chemically Reacting Flow Models e Section 19.5: Phase Change Model e Section 19.6: Lumped Parameter Models e Section 19.7: Sliding Mesh Model t
e Section 19.8: Deforming Mesh Model e Section 19.9: Eulerian Multiphase Model i
e Section 19.10: Volume of Fluid Multiphase Model e Section 19.11: Boundary Conditions 1
e Section 19.12: Solution of the Continuous Phase Equations e Section 19.13: Equations for the Dispersed Second Phase e Section 19.14: Radiation Modeling
I*
19-2 Chapter 19 - Theory 19.1 Basic Conservation Equations for Laminar Flows The basic equations describing the laminar flow of continuous fluid are:
- Conservation of mass, e Conservation of momentum,
. Conservation of energy, and e Conservation of species.
These equations are detailed below and their extension to turbulent flow are described in Section 19.3.
Cartesian vs. FLU ENT normally solves the governing conservation equations using Cylindrical Cartesian spatial coordinates and velocity components. Optionally, Formulation this formulation can be replaced by one in which cylindrical-polar spatial coordinates and velocity components are employed. The later formulation leads to improved predictions, with reduced nu-merical errors, in rotationally symmetric problems and/or problems involving swirling or rotating flow. See Section 19.1.5.
19.1.1 The Mass Conservation Equation The conservation of mass, or continuity equation, used in FLUENT is:
op 6
- + -(put) = S.
(19.1-1) at exs Equation 19.1-1 is the general form of the mass conservation equa-tion and is valid for incompressible as well as compressible flows.
The source S.,, is the mass added to the continuous phase from the dispersed second phase (e.g. due ta vaporization of liquid droplets).
19.1.2 Momentum Conservation Equations Conservation of momentum in the ith direction in an inertial (non-accelerating) reference frame, is described by: [5]
og(pug) + o (pu6uj) = - op + or- + pg, + F4 (19.1 2) where p is the static pressure, rgj is the stress tensor (described below), and y, and F are gravitational acceleration and external 4
l
19.13asic Conservation Equations for Laminar Flows 19-3 body forces (e.g. that arising from interaction with the dispersed phase) in the i direction, respectively.
The stress rij is given by:
! Oui + OuQ 2 out 3 g,;6ii P
rij =
P g,,
where p is the molecular viscosity and the second term on the right hand side is the effect of volume dilation.
Momentum FLUENT also allows computation of flows in a rotating reference Equations for frame such as flows in rotating turbomachinery passages. Since a Rotating Reference rotating coordinate system is a non-inertial accelerating reference Erames frame, additional body force terms arise in the momentum equa-tions, where the acceleration of the fluid is augmented by the an-gular acceleration of the reference frame. The total acceleration of the fluid in the rotating frame is thus: [5]:
Dv d+ f *I Dt where v is the velocity of the fluid in the rotating frame, O is the i
angular velocity of the reference frame, and y is the position vector in the reference frame.
If the axis of rotation is assumed to be the z-axis and D is assumed to be constant in time, O = wis (19.1-5) where w is the magnitude of rotation (radians /sec). When f1 is defined as above, the additional acceleration terms arising due to rotation can be written in Cartesian tensor notation as:
- 3) + 1 (-u'z ))
(19.1-6) 2 2(i (-wu ) + i (wui)) + (i (-w :
2 a
i s
2 i
The first and second terms in Equation 19.1-6 are referred to as the coriolis and centrifugal acceleration terms, respectively.
FLUENT alternately can treat the axis of rotation as the x-axis (for axisymmetric problems or when the cylindrical formulation is employed) and can include time varying rotational speed, w(t).
i
i
+
19-4 Chapter 19 - Theory 19.1.3 Species Conservation Equations The conservation of species i' is described by the following equation:
8 8
8
-(pmf) + ox,(pugmf) = Oz, (J,,) + S 8t f
f (19.1-7) where my is the mass fraction of species i', J,, is the diffusive mass f
flux of species i' in the ith direction and Sp is the net rate of pro-duction of species i* per unit volume due to chemical reaction or contribution from the dispersed phase. The summation of conser-vation equations for all the species present in the continuous phase results in the overall mass conservation equation described earlier.
In general, the diffusive mass flux J,, is composed of diffusion due f
' to thermal efects (Soret diffusion), difusion due to concentration gradient, pressure diffusion, and diffusion due to external forces l74). In FLUENT, the diffusion due to concentration gradients and thermal effects are included. Hence, J,4 = -pD,,om, - @ 1 BT f
f g,
t where D,, is the difusion coefficient for species i' in the mixture f
and D[ is the thermal diffusion coefficient.
Multi-Component Species 'IYansport FLUENT optionally provides a full multi-component species trans-4 port model which can be important when details of the molecular transport processes are significant (e.g., in diffusion dominated lam-inar flows).
Definition of the The general expression for the diffusion mass flux vector of species Multi-Component i' in full multicomponent diffusion is given by [46):
Diffusion Flux J,, = C'P j,.f Mg,M,,D,,j.dj, - D[VT (19.1-9)
T nype r
l
.mm m
19.1 Basic Conservation Equations for Laminar Flows 19-5 where:
C molar concentration of the mixture
=
M,,
molecular weight of species i'
=
Af,,
molecular weight of species j'
=
D,j, multicomponent diffusion coefficient for species pair i'-j'
=
dj, mechanical diffusion vector for species j
=
VXj, for ideal gases
=
Xj, mole fraction of species j' in the mixture.
=
D,?
thermal mass diffusion coefficient for species i' in the
=
mixture.
The first term in Equation 19.1-9 is the contribution of concentra-tion gradients to the diffusional mass flux vector and the secor..I term represents the Soret effect, that is mass transfer due to tery perature gradients. This general form of the diffusion flux appears l
as a modeling optior in FLUENT. The dilute approximation (Equa-tion 19.1-8) is used by default.
Ideal Gas Law When the fluid mixtureis assumed to be an ideal gas, Equation 19.1-9 Form of the can be expressed in terms of mass fractions and, with some mathe-Diffusion Flux matical manipulations, be reduced to yield:
Mi.
VT J, = pp '={s.j*t,'Dg,j, (Vmj, + mj, VM - DJ7 (19.1 10 4
i The species equation thus becomes:
- Opmi, M,.
VM g + V - (pVm,.) = V. p3...f....D,,,. (Vmja + mi, y
~
V. D[ VT' + Se, (19.1-11)
+
T i
i 19.1.4 Energy Conservation Equation FLUENT solves the conservation of energy in terms of conservation of the static enthalpy, h, defined as:
4={m,,h.
(19.1-12) g
)
e where 7
A=
c,,,, dT (19.1 13) f 1
i e
)
19-6 Chapter 19 - Theory where T,,f s a reference temperature and c,,g. is the specific heat.
i at constant pressure of species i'.
As in the species transport equations, the energy equation solved by FLUENT assumes that species diffusion due to pressure and external forces is negligible. Under this assumption, the energy equation cast in terms of h can be written [9]:
a B
B BT\\
-(ph) + Bze(push) = 8x; k 8xe, i
St 8
op ou-hj,4 + p+ u, op + r,j
+ Sr (19.1 14) where T is the temperature, r4j is the viscous stress tensor, Jj, is the flux of species j', and k is the mixture thermal conductivity. SS is a source term that includes sources of enthalpy due to chemical reaction, radiation, and exchange of heat with the dispersed second phase. Note that the viscous heating term, r,j g, must be activated as a modeling option and should be turned on when the viscous stresses are large and/or in compressible flows.
Energy Equation in in conducting solid regions, FLUENT solves a simple conduction Conducting Solids equation that includes the heat flux due to conduction and volu-metric heat sources within the solid:
0-p.h. = 8 k. BT +i (19.1 15) 6t Bzi 8xi where p.,
=
wall density h,
wall enthalpy, c.(T - Tuf)
=
k.
wall conductivity
=
T wall temperature
=
(~
volumetric heat source
=
Equation 19.1-15 is solved simultaneously with the enthalpy trans-port equation, Equation 19.114, to yield a fully coupled conduc-tion / convection heat transfer prediction.
The effects of wall motion can be included in Equatio
- 1.1-15, yielding an energy equation in the solid of the following form:
ag(p.h.) + o (p u4, h.) = a (k.BT) + 4-(19.1 16) where u,. is the wall velocity in the ith component direction. Ilere, s
i the convection of thermal mass due to the wall motion is included in the energy balance within the solid region.
.q
19-7 19.1 Basic Conservation Equations for Laminar Flows 19.1.5 Conservation Equations in Cylindrical Form FLUENT optionally solves the conservations equations for mass, mo-mentum, and all scalars using a cylindrical coordinate formulation.
The cylindrical formulation provides direct calculation of curvature related terms, yielding more accurate numerical results in problems involving high swirl or rotation. The equations, cast in cylindrical coordinates (z, r, 0), are:
Continuity:
O + I#") + 10f'#) + 10(#*) = S,.
(19.1-17) f at Sz r or r #6 Axial Direction Momentum:
g(Pu) + g(puu) + l a (rpvu) + l a (pwu) =
6 a
g i
+ g** + f g*,"+ f g***+ ps, + F, (19.1-18)
Radial Direction Momentum:
g(PU) + g(puv) + 16 (rpov) + l a (pwv) =
B B
g
_Op O(r ) 1,6(rr,,) 1d(r,,)
re, 7
9 9
er or r
ox r or r De r
Circumferential Direction Momentum:
g(PS) + g(puw) + l a (rpvw) + l a (pww) =
0 8
g a(r,,) + I a(r 7,,) + l a(ree) + ppe + F, (19.1-20) 2 IDp pvw +
y or r De
roe r
oz r
where u is the axial velocity component, v is the radial velocity
)
component, and w is the circumferential velocity component. The stress tensor in cylindrical coordinates is:
19 8 Chapter 19 - Theory Su 2
/Su 16(rv)+1Swi r 80,l (19.1-21) p l Bz + r r,, = 2 Oz 3
\\
or av 2
fou i
r,,=2#g 39 g + er16(rv) + 18w g
(19.1-22)
'Bu 16 1Sw)
/
vi 2
gr 60 + r,l 3p ! - + - (rv) + --
l (19.1 23) re, = 2 i 1 Sw gDx r or r 60, fou ovh r,, = p I -+-
l (19.1-24)
(or az j l
1 av awi g+g (19.1-25) r,a = 9 8
i flav + rg(w, )
(19.1-26) tre = p 19.2 Fluid Properties and the Equation of State
]
Closure of the conservation equations presented in the preceding sec.
]
tion requires a description of the fluid density and other fluid prop-
)
erties. FLUENT allows all fluid properties to be defined as constant or as temperature and/or composition dependent in this section the equations employed by FLUENT for calculation of temperature and/or species dependent fluid properties are outlined. Note that user subroutines may also be used to define properties in FLUENT.
t 19.2.1 Equation of State for Density FLUENT allows the mixture density to be described as a function of temperature and composition and, in ideal gases, as a function of temperature, pressure and composition.
' Mixture Density in Density may be computed via the ideal gas law as:
Ideal Gases (19.2-1) p = RTEt m where R is the universal gas constant, Eg.m,/M; provides the re-g ciprocal of the molecular weight of the local mixture (Mr is the i
9 O
r.
ATTACHMENT 11
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L
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 document entitled "Holtec Position Paper WS-121 - Benchmarking Computer Code Fluent," Revision 0:
February 17, 1998. The entire content of this document is considered to contain 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, 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 "confiden'tial 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 Proiect v.
Nuclear Regulatory Commission,975F2d871 (DC Cir.1992), and Public Citi7en 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 competitive economic advantage over other companies; 1
a 4
AFFIDAVIT PURSUANT TO 10CFR2.790 i
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,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 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.
(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.
.2
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 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 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.
(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.
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.
3 i
..,J
. 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 adequate return on its large investment in developing these very valuable analytical tools.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Febru
,1998.
1
/
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this O day of 64 %,1998.
- T T]
y MARIA C. PEPE NOTARY PUBUO OF NEW JERSEY My W Expires Apr2 25,2000 z.
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 figure entitled
" Attachment 3: Schematic for Original Nodalization Scheme for Waterford 3 CFD Analysis." The entire content of the figure is considered as 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, 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 assigned to those terms for i
purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v.
Nuclear Reguhtory Commission,975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v. FDA,704F2dl280 (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 4
competitors without license from Holtec International constitutes a competitive economic advantage over other companies; I
a.,M%.
' AFFIDAVIT PURSUANT TO 10CFR2.790 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,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 International. No public disclosure has been made,' and it is not available in public sources. Al! 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.
2
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions.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 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 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.
(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.
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.
3 J
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 adequate return on its large investment in developing these very valuable analytical tools.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Febru ry,1998.
v Dr. Alan I. Soler Holtec International Subscribed and sworn before me this #7 day of M
8.
% Vp MARIA C. PEPE i."
'.RY PUBUO OF NEW JERSEY lt/Lommiselon Expues AprJ 25,2000
)
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 Ogure entitled
" Attachment 4: Physical Mesh Mapped by the Original Scheme." The entire content of the figure is considered as 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, 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 dennition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v.
Nuclear Regnhtory Commission,975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir.1983).
(4)
Some examples of categories of information which 6t into the de6nition 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; 1
a 4
AFFIDAVIT PURSUANT TO 10CFR2.790 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,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 International. No public disclosure l
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 Hollec International is limited on a "need to know" basis, l
2
4 AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 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 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.
(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.
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.
3
s 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 adequate return on its large investment in developing these very valuable analytical tools.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
1 Dr. Alan I. Soler, 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 27th day of February,1998.
l Dr. Alan I. Soler Holtec International O
day of N64%998.
Subscribed and sworn before me this hL T
e*~Ac. reps NOTARYr*
3 C.'1:EW JERSEY My CW;a Cxpirca AprJ 25,2000 4
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 figure entitled
" Attachment 5: Volumetric Heat Source Contours Plot." The entire content of the figure is considered as 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 ofInformation 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 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).
(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; 1
AFFIDAVIT PURSUANT TO 10CFR2.790 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; Information which discloses patentable subject matter for which it may be e.
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, 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 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 i
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.
2 j
~
1 AFFIDAVIT PURSUANT TO 10CFR2.790 (7)
The procedure for approval ef 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 provisions 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 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 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.
(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.
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.
3
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 deprivo 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.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Feb y,1998.
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this 47 day of - e'l % %,1998.
u M8P!A O. PEPE NOTARY PU UO c.2 i:EW JERSEY My Comm!uka Ex;,;.a Apr;l 25,2000 4
i
-)
v AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
- I am Executive Vice President, 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 figure entitled
" Attachment 6: Refined Nodalization Scheme to Demonstrate-Mesh Size Gonvergence." The entire content of the figure is considered as 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, and NRC regulations 10CFR Part 9.17(a)(4),
'l 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 H
definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v.
Nuclear Regulatory Commission,975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v. FDA,704F2dl280 (DC Cir.1983).
(4)
Some examples of categories of information which fit into the definition of proprietary information are:
l l
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; 1
1
AFFIDAVIT PURSUANT TO 10CFR2.790 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,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 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.
(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.
~
2.
AFFIDAVIT PURSUANT TO 10CFR2.790
]
-(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 provisions or proprietary agreements.
(8)
The information classified as proprietary was developed and compiled by Holtec l
International 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, including competitors, with information from Holtec International's technical database and the results of evaluations performed using codes developed by Holtec j
International. Release of this information would improve a competitor's position
]
without the competitor having to expend similar resources for the development of 1
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 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.
The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Haltec 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.
3 1
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 adequate return on its large investment in developing these very valuable analytical tools.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Febrk,1998.
i b
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this A7 day of El 1998.
f?7 M 6 b MARIA C. PEPE NOTARY PUBUC OF tr." '~'.,0 My Commiselon Expl.=,v..
4
i AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 figure entitled
" Attachment 7: Temperatures Contours Plot with Original Mesh." The entire content of the figure is considered as 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 ofInformation 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 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 Groun 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 competitive economic advantage over other companies; 1
AFFIDAVIT PURSUANT TO 10CFR2.790 -
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 infonnation, 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, 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 Hollec 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 on 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.
2
1 AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 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 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.
(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.
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.
3
AFFIDAVIT PURSUANT TO 10CFR2.790 i
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.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINOTON
)
Dr. Alan I. Soler, 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 27th day of Febery, 6
(
( b
~
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this A7 day of NM"^t,1998.
f f" *"% C. PEPE FCT!aY i U 13 C. ICW JERSEY M/ CocrenMkn 4!rcs Apra 25,2000 4
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, Holtec International and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be viithheld, and have been authorized to apply for its withholding.
(2)
The information sought b be withheld is contained in the figure entitled
" Attachment 8: Temperature Contours Results with Refined Mesh." The entire content of the figure is considered as 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 ofInformation 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 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).
(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; I
AFFIDAVIT PURSUANT TO 10CFR2.790 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, 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 con 0dence 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.
(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.
2-
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions or proprietary agreements.
(8)
The information classified as proprietary was developed and compiled by Holtec International at a signi0 cant 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, including competitors, with information from Holtec International's technical database and the results of evaluations performed using codes developed by 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.
(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.
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.
3
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 competi' ors 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.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Februa 1998.
tb Dr. Alan I. Soler Holtec International Subscribed and sworn before me this #7 day of 998.
$rr) A T 0%
t" m.C.r"?2 gg;;W ; L _. J C71:2W JERSEY M/ omng;a D$sa@25 M C
4
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 figure entitled
" Attachment 9: MP3 Spent Fuel Pool Test Layout." The entire content of the figure is considered as 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, 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 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).
(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; I
1 u
AFFIDAVIT PURSUANT TO 10CFR2.790 b.
Information which, if used by a competitor, would reduce his expenditure l
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,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 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.
~
(6)
Initial approval of proprietary treatment of a document is made by the manager of the originating compo_nent, 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.
2
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 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 International. Release of this information would improve a competitor's position withcut 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.
(9)
Public disclosure of the information sought to be withheld is li'Kely 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.
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.
3
AFFIDAVIT PURSUANT TO 10CFR2.790 I
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 s
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 o
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.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Feb a'ry,1998.
f
}!
l
)
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this N day of 1998.
r fW
~
MARIA C. PEPE NOTARY PUSUO OF ICY / JERSEY
% Apr3 25,2000 4
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and Wate as follows:
(1)
I am Executive Vice President, 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 figure entitled
" Attachment 10: Millstone Unit 3 Pool Transient Heating Profiles." The entire content of the figure is considered as 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 ofInformation 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 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).
(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 empetitive economic advantage over other companies; 1
AFFIDAVIT PURSUANT TO 10CFR2.790 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; c.
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, 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 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.
(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.
2
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 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 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.
(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.
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.
4 4
'4 3
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 adequate return on its large investment in developing these very valuable analytical tools.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 27th day of Feb a)y,1 8.
(
Dr. Alan I. Soler Holtec International M day of,
At' 98.
Subscribed and sworn before me this J'] n MARtA C. PEPE NOTARY PUcuO OF NC';I J70EY My Comm'.asion Expkca /&.J L3. 2000 4
1 AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
i (1)
I am Executive Vice President, 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 figure entitled
" Attachment 12: Base Case Waterford 3 Temperature Contours" The entire content of the figure is considered as 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, 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 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).
(4)
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that discloses a process, iaethod, 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; 1
' AFFIDAVIT PURSUANT TO 10CFR2.790 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,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 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.
(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.
2 i
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 provisions 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 historical data and an'alytical 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 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.
(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 i
technology base goes beyond the extensive physical database and analytical I
methodology, and includes development of the expertise to determine and apply 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.
3
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 adequate return on its large investment in developing these very valuable analytical tools..
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
)
Dr. Alan I. Soler, 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 12th day of March 1998.
Dr. Alan I. Soler Holtec International Subscribed and sworn before me this day of M
,1998.
f&. 0Yf f19.".!A C. ITPfi 4
NOTARY PU;t.10 CF 1C11J2RSEY My CwTE'::'
Expiro: Apr2 25,2000
AFFIDAVIT PURSUANT TO 10CFR2.790 I, Alan I. Soler, being duly sworn, depose and state as follows:
(1)
I am Executive Vice President, 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 Ogure entitled
" Attachment 13: Perturbed Case Waterford 3 Temperature Contours" The entire content of the Ggure is considered as 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 ofInformation 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 information obtained from a person and privileged or conGdential" (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,704F2dl280 (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 competitive economic advantage over other companies; 1
AFFIDAVIT PURSUANT TO 10CFR2.790 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,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 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.
_(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.
2
AFFIDAVIT PURSUANT TO 10CFR2.790 (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 legitimcte need for the information, and then only in accordance with appropriate regulatory provisions 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 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 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 infonnation.
(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.
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.
3
b 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 I
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.
STATE OF NEW JERSEY
)
)
ss:
COUNTY OF BURLINGTON
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Dr. Alan I. Soler, 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 12th day of March,1998.
I Au, Dr. Alan I. Soler Holtec International M7
,1998.
Subscribed and sworn before me this day of V Y) c A 0 h f '
- 1'A C. PEPE 4
NOT,*.'J/ ; U 110 OF NEW JERSEY My Cumrh Empiru Apr8 26,2000 q
I