ML21228A262

Revised Response to Request for Additional Information - Holtec Spent Fuel Pool Heat Up Calculation Methodology Topical Report

ML21228A262
Person / Time
Site:	99902086
Issue date:	08/16/2021
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21229A072	List: ML21228A262
References
Download: ML21228A262 (37)

Text

HOLTEC INTERNATIONAL August 16, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Holtec Technology Campus, One Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Docket No. 99902086 - HDI Spent Fuel Pool Heatup Calculation Methodology

References:

Revised Response to Request for Additional Information - Holtec Spent Fuel Pool Heat Up Calculation Methodology Topical Report

1.

Letter from Holtec International to US NRC, "Holtec Spent Fuel Pool Heat Up Calculation Methodology Topical Report," September 29, 2020 (ML20280A524)

2.

US NRC Electronic Mail Request to Andrea Sterdis (HDI) "Formal Transmittal of the US NRC Requests for Additional Information for Holtec Topical Report Hl-2200750 Revision 0, "Holtec Spent Fuel Pool Heat Up Calculation Methodology," March 31, 2021 (ML21077A102)

3. Letter from Holtec International to US NRC, "Response to Request for Additional lnformation-Holtec Spent Fuel Pool Heat Up Calculation Methodology Topical Report," May 28, 2021.

Dear Sir or Madam:

In Reference 1, Holtec submitted a Topical Report providing a methodology for calculating Spent Fuel Pool heat up for NRC review and approval. Holtec believes the methodology will be a large benefit in reducing zirconium fire risks in the spent fuel pool.

In Reference 2, the NRC transmitted a request for additional information (RAI) concerning the Topical Report.

The following Enclosures to this letter provide a response to the NRC RAI.

Reference 3 provided the Holtec response to the RAI that were made in Reference 2.

This letter provides a revised set of responses to the RAI that provides additional clarification and supporting information. Although the revisions are limited to the responses to RAI 02, 03, 05 and 08, for ease of review and tracking, HDI is providing complete revisions of the Reference 3 Enclosure 1 and 2. NRC should use Enclosures 1 and 2 in lieu of the Reference 3 Enclosures 1 and 2. provides the proprietary version of the revised RAI response. This enclosure contains information Page I of 2

HOLTEC INTERNATIONAL Holtec Technology Campus, One Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 proprietary to Holtec and is therefore supported by an affidavit signed by Holtec which is provided in Enclosure

3. provides a non-proprietary, redacted version of the revised RAI response.

If you have any questions, please contact me at 856-797-0900 ext. 3813.

Sincerely, And rea D191tally signed by Andrea Sterd1s ON. cn=Andrea Sterd1s, c=US, o=Hottec Decomm1ss1onmg S

d,

International, ou=HDI, te r IS ema1l=a sterd1s@holtec com Date 2021 08 16 20 09 32 -04'00' Andrea L. Sterdis VP, Regulatory and Environmental Affairs Holtec Decommissioning International

Enclosures:

Holtec Response to Request for Additional Information concerning Spent Fuel Pool Heat Up Calculation Methodology Topical Report (Holtec Proprietary Withhold Information from Public Disclosure pursuant to 10 CFR 2.390) Holtec Response to Request for Additional Information concerning Spent Fuel Pool Heat Up Calculation Methodology Topical Report-Redacted (Non-Proprietary) Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure cc:

Robert Lucas, NRC, NRR/DORL/LLPB Dennis Morey, NRC, NRR/DORL/LLPB Ekaterina Lenning, NRC, NRR/DORL/LLPB Christopher Regan, NRC, NMSS/DFM Page 2 of2

l=lOLTeC PROPRleTARY INFORMATION Holtec Response to Request for Additional Information concerning Spent Fuel Pool Heat Up Calculation Methodology Topical Report Proprietary Version Withhold Information From Pl:lblic Disclosl:lre Under 10 CFR 2.390 Submitted Separately (27 Pages not including this Cover Page)

MOLTEC PROPRIETARY INFORM.'\\Tlml Holtec Response to Request for Additional Information concerning Spent Fuel Pool Heat Up Calculation Methodology Topical Report Proprietary Version Submitted Separately Non-Proprietary Version (Redacted)

Wit!:i!:iold Information Frorn Pualic Disclosure Under 1Q CFR 2.390 (27 Pages not including this Cover Page)

[

Regulatory Justification Associated Section Level of Concern Overall Significance Holtec Response Page I 1 MOLTEC PROPRIETARY INFORMATION RAl-01 Treatment of near-wall locations

.] 4.a, 4.b SRP Section 15.0.2, Subsection 111.3c 3.1.4 Initial and Boundary Conditions 2

I Level of Impact I 5 I Level of Effort I 3 Medium

[

.] 4,a, 4,b Therefore, the methodology proposed by Holtec does improve the safety of the spent fuel storage.

~OLHC PROPRIETARY INFORMATION RAl-02 Lumped Analysis vs. Pin by Pin Analysis

[

] 4.a, 4.b Regu latory SRP Section 15.0.2, Subsection 11 1.3b Justification Associated 3.3.1.4 Level of Detail in the Model Section Level of Concern 1

I Level of Impact 13 I Level of Effort I 1 Overall High Sign ifica nee Holtec Response

[

] 4.a, 4.b For that, the methodology is expanded as follows:

[

Page I 2

MOLHC PROPRIETARY INF

.] 4.a, 4.b Page I 3

MOLTEC PROPRIET/\\RY INFORM/\\TION 0

. ] 4.a, 4.b The approach is considered conservative due to the following reasons:

[

Page I 4

HOLTEC PROPRIETARY INrnRM/\\TION Page I 5

MOLH:C PROPRIET/\\RY INFORM/\\TION

] 4.a, 4.b 0.7 SQ I

p/d =

i 1.5 0.6 ~

1.4

~ I u 0.5r 1.3 E I l.2

-~0.4 IE 1.1 8

u 0.3 l.01

4)

-~0.2

-0

<IS 01::

0.1 0

0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 Rod emissivity, r Figure 2-1: Radiative coefficient for a square array, Figure 3.6-5 in [2.2]

Page I 6

Page I 7 MOLTEC PROPRIET/1.RY INFORMATION References for Response to RAl-02

[2.1]

Manteufel, R.D. and N.E. Todreas, "Effective Thermal Conductivity and Edge Configuration Model for Spent Fuel Assembly," Nuclear Technology, Vol. 105, pp. 421-440, March 1994.

[2.2]

Manteufel, R.D., "Heat Transfer in an Enclosed Rod Array",

Submitted to the Department of Mechanical Engineering in partial fulfillment of the requirements for the degree of Doctor of Philosophy, Massachusetts Institute of Technology, May 1991

Regulatory Justification Associated Section Level of Concern Overall Significance Holtec

Response

Page I 8 MOLTEC PROPRIETARY INFORMATION RAl-03 Radial and Axial Peaking

] 4.a, 4.b SRP Section 15.0.2, Subsection 111.3b 3.3.1.4 Level of Detail in the Model 2

I Level of Impact I 2 I Level of Effort High

[

] 4.a, 4-b (see for example the HI-STAR 100 Storage SAR [3.1), Table 2.1.8, and the SER on the initial submittal of this SAR [3.2), Section 4.3). [

Page I 9 HOLTEC PROPRIETARY INFORM.'\\TION

] 4.a, 4.b For PWR fuel, axial burnups were also extensively analyzed in support of Burnup Credit for spent fuel transportation casks, as documented in NUREG/CR-6801 [3.3], with results documented in Table 5 of that document.

[

.] 4.a, 4.b Note that for lower burnup, the NUREG reports slightly higher values, up to about 1.215 (for burnups between 14 and 18 GWd/mtU). [

] 4.a, 4.b For BWR fuel, similar studies were performed and are documented in NUREG/CR-7224 [3.4]. For high burnup assemblies, results are shown in that NUREG in Figure 6.3, with maximum values generally no more than 1.2. [

MOLTEC PROPRIET/\\RY l~lFORMATION Page I 10

MOLTEC PROPRIETARY INFORM/\\TION Page I 11

l=lOLTEC PROPRIETARY l~lFORMATION Page I 12

l=IOLTEC PROPRIETARY INFORMATION Page I 13

Page I 14 FlOLTEC PROPRIH/\\RY l~JFORMATION

] 4.a, 4.b References for Response to RAl-03

[3.1]

HI-STAR 100 Final Safety Analysis Report, Holtec Report Hl-2012610, Rev. 0, March 2001

[3.2]

NRC Safety Evaluation Report and CoC, Holtec HI-STAR 100 Cask System, April 1999

Page I 15 MOLTEC PROPRIETARY l~JWRM.'\\TION

[3.3]

"Recommendations for Addressing Axial Burn up in PWR Burn up Credit Analyses", NUREG/CR-6801, ORNL/TM-2001/273, Oak Ridge National Laboratory, March 2003.

[3.4]

"Axial Moderator Density Distributions, Control Blade Usage, and Axial Burnup Distributions for Extended BWR Burnup Credit", NUREG/CR-7224, ORNL/TM-2015/544, Oak Ridge National Laboratory, August 2016.

[3.5]

Not used.

[3.6]

Westinghouse Technology Systems Manual, Section 2.2, Power Distribution Limits, USNRC HRTD, Rev. 0508, ML11223A208

[3. 7]

Safety Analysis Report on the HI-STAR 190 Package, Holtec Report H 1-2146214, Rev. 3, November 2018, USN RC Docket 71-9378

HOLTeC PROPRl~T.'\\RY INFORMATION RAl-04 Time Step Sensitivity

[

] 4.a, 4.b Regulatory SRP Section 15.0.2, Subsection 111.3d, Appendix K to 10 CFR 50, and TM/

Justification

{Three Mile Island] action items for PWR Associated 3.3.2.1 Numerical Solutions & 3.3.5.4 Sensitivity Studies Section Level of Concern 3

I Level of Impact I 3 I Level of Effort 4

Overall Low Significance Holtec Response

[

.] 4.a, 4.b 4.a, 4.b Page I 16

Regulatory Justification Associated Section Level of Concern Overall Significance Holtec

Response

Page I 17 HOLTE( PROPRIETARY INFORMATION RAl-05 Planar Surface Area

] 4.a, 4.b SRP Section 15.0.2, Subsection lll.3e 3.3.5.1 Important Sources of Uncertainty 3

I Level of Impact 13 I Level of Effort Low

] 4.a, 4.b

[5.1] "Handbook of Heat Transfer", W.M. Rohsenow, J.P. Hartnett, Y.I. Cho, 3rd Edition, McGraw Hill Book Co.

Extract from (5.1] on following page

Page I 18 l=IOLTEC PROPRIETARY INFORMATION

3. Infinite plane to row of parallel cylinders, or n rows of inline cylinders

References:

Hottel (290]; Kuroda and Munakata [296I Definition: D = dlb Governing equations:

For n = 1: F1_2 = 1 - (1 - D2) 112 + D tan-* ( 1 ~~

2

)

112 For n > 1: Fi-*,.,... = 1 - (1-F,_2)"

RADIATION 7.81 0

Regulatory Justification Associated Section Level of Concern Overall Significance Holtec Response Page I 19 HOLTEC PROPRleTARY INFORMATION RAl-06 Uncertainty due to emissivity

]4.a, 4.b SRP Section 15.0.2, Subsection lll.3e 3.3.5.1 Important sources of Uncertainty 3

I Level of Impact I 3 I Level of Effort I 3 Low Surface emissivities are significantly affected by surface layers on the cladding (crud usually increases emissivity); therefore, the assumed oxidation layer and any exposed zircaloy surfaces are assumed to have the emissivity resulting from MATPRO Equation 4.1-8 [2] (equal to 0.8 or higher) using the oxidation thicknesses from [1]. Furthermore, Table B-3.11 of [2] also shows an emissivity of fuel cladding with crud well over 0.8.

Therefore, use of an emissivity of 0.8 for zircaloy cladding is conservative.

Emissivity of stainless-steel plates that are used for the rack cell walls is 0.587 per ORNL studies [3] and [4]. The variation in emissivity of stainless-steel with temperature is extremely small(~ 0.05) in large temperature range as shown in reference [5].

Moreover, it must be noted that the emissivity values of 0.8 and 0.587 for zircaloy cladding and stainless-steel plates, respectively, have been approved by USNRC in multiple Holtec's dry storage applications (USNRC Docket Nos. 72-1014, 72-1032, 72-1040, 71-9325, 71-9367, 71-9373, 71-9374, etc.). NRC staff further mentions in their SERs (Section 3.2 on Docket Nos. 71-9367, 71-9374) that the material properties and surface emissivities used in these applications are acceptable.

Page I 20 HOLHC PROPRIET/\\RY INFORM/\\TION The variances in emissivity can alter the radiation heat transfer characteristics of the surfaces and therefore change the peak cladding temperatures. However, as noted in Section 4.2.7 of [1], the impact of emissivity variations on the peak cladding temperature (PCT) is extremely small. As a defense-in-depth, Holtec also performed sensitivity evaluations [

] 4.a, 4.b

Reference:

[1] "Spent Nuclear Fuel Effective Thermal Conductivity Report," US DOE Report BBA000000-01717-5705-00010 REV 0, (July 11, 1996).

[2] Hagrman, Reymann and Mason, "MATPRO-Version 11 (Revision 2) A Handbook of Materials Properties for Use in the Analysis of Light Water Reactor Fuel Rod Behavior," NUREG/CR-0497, Tree 1280, Rev. 2, EG&G Idaho, August 1981.

[3] "Nuclear Systems Materials Handbook, Vol. 1, Design Data", ORNL TID 26666.

[4] "Scoping Design Analyses for Optimized Shipping Casks Containing 1-,

2-, 3-, 5-, 7-, or 10-Year-Old PWR Spent Fuel", ORNL/CSD/TM-149 TTC-0316, (1983).

[5] "Process Heat Transfer", D.Q. Kern.

l=IOLTEC PROPRleT/\\RY l~JFORM/\\TION RAl-07 Quality Assurance Program In the topical report, Holtec did not discuss the quality assurance program which controlled this analysis. Holtec should confirm that this [

] 4.a, 4.b analysis is kept under a quality assurance program consistent with 10 CFR Part 50 Appendix B that this program contains adequate documentation for design control, document control, software configuration control and testing, and corrective actions, and that the analysis has been independently peer reviewed. Additionally, Holtec should confirm that the important references which the analysis method rely upon have been incorporated into Holtec's quality assurance program.

Regulatory Justification Associated Section Level of Concern Overall Sign ifica nee Holtec Response Page I 21 SRP Section 15.0.2, Subsection lll.3f 3.3.6.1 Appendix B Quality Assurance Program 3

I Level of Impact I 3 I Level of Effort I 2 Low The analysis developed for this topical report was developed, reviewed and approved under the Holtec Quality Assurance (QA) Program. The Holtec QA Assurance Program addresses the 10 CFR 50, Appendix B requirements and provides for appropriate design control, document control, software configuration control and testing, and corrective actions. The topical report and the supporting analysis as well as applicable references are maintained under the Holtec QA Program.

When the methodology is approved and then is applied to a plant specific spent fuel pool, the site specific calculations will be performed in accordance with the site's Quality Assurance Program.

MOLTEC PROPRleTARY INFORMATION RAl-08 Comparison to Office of Research (RES) Data

[

.] 4.a, 4.b Please provide a plot similar to that given in Figure 7.3 with these comparisons Regulatory Justification Associated Section Level of Concern Overall Sign ifica nee Holtec Response Page I 22 SRP Section 15.0.2, Subsection 111.3d 3.3.3.2 Validation of the Evaluation Model 3

I Level of Impact I 5 I Level of Effort I 3 Low Figure 7.3 in the TR has been expanded to show data up to 6 months for BWR fuel assemblies. The revised figure compares data from the method proposed in the TR to data from calculations done by the Office of Research {RES) starting from 6 months of cooling time. The conclusions made in the TR still remain applicable that the proposed method shows conservative results under all configurations for BWR fuel assemblies [

] 4.a, 4.b A similar figure has been added below for PWR fuel assemblies.

MOLTEC PROPRIETARY INFORM/\\TION Response to RAl-08 Revised Figure 7.3 and added Figure 7.3(b) 4.a, 4.b Page I 23

MOLHC PROPRIETARY l~JFORMATION RAl-09 Variation in Heat Capacity

[

] 4.a, 4.b Regulatory SRP Section 15.0.2, Subsection 111.3b Justification Associated 3.3.1.4 Level of Detail in the Model Section Level of Concern 3

I Level of Impact I 3 I Level of Effort 14 Overall Low Significance Holtec Response Heat capacity of fuel assemblies is an input to the calcu lations. [

] 4.a, 4.b Page I 24

MOLHC PROPRl~TARY INFORMATlmJ Revised Appendix B (see Response to RAl-02)

EXAMPLE CALCULATION [

_]4a., 4 b AT EXAMPLE PLANT A (Page Bl of 3) 4.a, 4.b Page I 25

MOLH:C PROPRleT/\\RY INFORMATION Revised Appendix B (see Response to RAl-02) (Page B2 of 3) 4.a, 4.b Page I 26

MOLH:C PROPRlf:T/\\RY l~Ji;QRM/\\TION Revised Appendix B (see Response to RAl-02) (Page B3 of 3) 4.a,4.b Page I 27 August 16, 2021 Letter, Holtec International to US NRC Affidavit for Withholding (5 Pages Attached)

U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure 3 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Andrea L. Sterdis, being duly sworn, depose and state as follows:

1) I have reviewed the information provided in the RAI responses provided in which is sought to be withheld, and am authorized to apply for its withholding.

2) The information sought to be withheld is in Enclosure 1 to the August 16, 2021 letter to NRC providing "Revised Responses to Request for Additional Information - Holtec Spent Fuel Pool Heat Up Calculation Methodology Topical Report." The Enclosure 1 responses contain information that is proprietary to Holtec International.

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 oflnformation Act ("FOIA"), 5 USC Sec. 552(b )( 4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) 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, 704F2d1 280 (DC Cir. 1983).

Page 1 of 5

U.S. Nuclear Regulatory Commission ATTN : Document Control Clerk Non-Proprietary Enclosure 3 AFFIDAVIT PURSUANT TO 10 CFR 2.390

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;

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 and 4.b 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 Page2of5

U.S. Nuclear Regulatory Comm ission ATTN: Document Control Clerk Non-Proprietary Enclosure 3 AFFIDAVIT PURSUANT TO 10 CFR 2.390 initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs ( 6) and (7) following.

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

7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function ( or his designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the 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 descriptions of analytical approaches and methodologies 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 by Holtec International.

A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.

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 Page 3 of 5

U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure 3 AFFIDAVIT PURSUANT TO 10 CFR 2.390 Holtec International's comprehensive decommissioning and 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.

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 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.

Page 4 of 5

U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure 3 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATEOFNEWJERSEY)

)

ss:

COUNTY OF CAMDEN

)

Andrea L. Sterdis, being duly sworn, deposes and says:

That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.

Executed at Camden, New Jersey, this / fo-Hday of August 2021.

~d)~

Andrea L. Sterdis Holtec Decommissioning International Holtec International VP, Regulatory & Environmental Affairs Subscribed and sworn before me this lbfh day of lk~w:,t 2021 2021 Page 5 of 5