ML22083A191

Request for Exemption from an Allowable Contents Requirement Contained in the Certificate of Compliance No. 1014 for the HI-STORM 100S Version E Cask

ML22083A191
Person / Time
Site:	Indian Point, Holtec
Issue date:	03/24/2022
From:	Fleming J Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML22084A087	List: ML22083A191
References
HDI-IPEC-22-030
Download: ML22083A191 (15)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E C -------------------T-e-le_p_h-on_e_(_85_6_)_7-97---09_0_0 DE OMM I SS I N I NG 1 NT RNAT 1 0NAL Fax(856) 797-0909 HDI-IPEC-22-030 10 CFR 72.7 March 24, 2022 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , DC 20555-0001 Indian Point Energy Center Renewed Facility License No. DPR-26 and DPR-64 NRC Docket Nos. 50-247, 50-286 and 72-051

Subject:

Request for Exemption from an Allowable Contents Requirement Contained in the Certificate of Compliance No. 1014 for the HI-STORM 100S Version E Cask In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 72. 7, "Specific exemptions," Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Indian Point 2, LLC (IP2) and Holtec Indian Point 3, LLC (IP3) is requesting NRC approval of an exemption from an allowable contents requirement contained in the Certificate of Compliance (CoC) No. 1014 for the HI-STORM 100S Version E Cask. Specifically, CoC No. 1014, Appendix D, Table 2.1-1,Section V, "MPC MODEL: MPC-32M," Item Conly permits a single Neutron Source Assembly (NSA) to be loaded into the Multipurpose Canister (MPC). HDI, on behalf of IP2 and IP3, is requesting the ability to load up to five (5) primary Plutonium-Beryllium (Pu-Be) NSAs or up to thirty-two (32) NSAs with sufficient decay time into an MPC-32M.

HDI has evaluated the proposed exemption and concluded that loading and storing five (5) primary Pu-Be NSAs or thirty-two (32) NSAs with sufficient decay time into an MPC-32M does not impact the criticality control, shielding, structural, confinement, or thermal design functions of a loaded cask.

The proposed exemption will enable HDI to load fuel assemblies where the NSA cannot be removed from its fuel assembly. Under such conditions, the current requirements prevent some fuel assemblies from being loaded into dry storage systems, therefore preventing the full unloading of all assemblies from the IP2 and IP3 spent fuel pools.

The proposed exemption will not endanger life or property, or the common defense and security, and is otherwise in the public interest. Therefore, the exemption is authorized by law. to this letter describes the need and justification for the issuance of an exemption , as well as a safety analysis and environmental assessment of the proposed action. to this letter provides a proprietary version of Holtec International (Holtec) calculation Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems, that supports this exemption request. It contains information proprietary to Holtec and is therefore supported by an affidavit signed by Holtec which is provided in Enclosure 4.

The calculation provided in Enclosure 2 includes appropriate markings identifying those

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E C -------------------T-e-le_p_h-on_e_(_85_6_)_7-97---09_0_0 DE OMM I SS I N I NG 1 NT R NAT 10NA L Fax(856) 797-0909 portions that are proprietary. Enclosure 3 provides a non-proprietary, redacted version of the calculation.

HDI requests NRC review and approval of the requested exemption by October 1, 2022, to support loading of fuel assemblies and the NSAs in the fourth quarter of 2022.

This letter contains one new regulatory commitment to ensure the site-specific shielding analysis remains a bounding analysis when considering the gamma source from the activated portions of the NSAs.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 24, 2022.

If you have any questions or need further information, please contact Mr. Walter Wittich, IPEC Licensing at 914-254-7212, or me at (856) 797-0900, ext. 3578.

Sincerely, Jean A. Digitally signed by Jean A. Fleming FI em *Ing Date: 2022.03.24 14:02:32 -04*00*

Jean A. Fleming HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC

Enclosures:

10 CFR 72. 7 Exemption Request : Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems (Holtec Proprietary Withhold Information from Public Disclosure pursuant to 10 CFR 2.390): : Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems (Non-Proprietary): : Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure cc: NRC Senior Project Manager, NRC NMSS NRC Region I Regional Administrator NRC Senior Regional Inspector, Indian Point Energy Center New York State Liaison Officer Designee, NYSERDA New York State (NYS) Public Service Commission

Enclosure 1 to HDI-IPEC-22-030 10 CFR 72.7 Exemption Request (6 Pages)

HDI-IPEC-22-030 Page 1 of 6

1) Request for Exemption Certificate of Compliance (CoC) No. 1014 for the HI-STORM 100S Version E Cask, Appendix D, Table 2.1-1,Section V, "MPC MODEL: MPC-32M," Item C only permits a single Neutron Source Assembly (NSA) to be loaded into an MPC-32M. Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Indian Point 2, LLC (IP2) and Holtec Indian Point 3, LLC (IP3) is requesting the ability to load up to five (5) primary Plutonium-Beryllium (Pu-Be) NSAs or up to thirty-two (32) NSAs with sufficient decay time into an MPC-32M.

Therefore, in accordance with 10 CFR 72.7, "Specific exemptions," HDI is requesting NRC approval of an exemption from the following requirements:

• 10 CFR 72.212(b)(3), which states the general licensee must "[e]nsure that each cask used by the general licensee conforms to the terms, conditions, and specifications of a Coe or an amended Coe listed in§ 72.214."

• The portion of 10 CFR 72.212(b)(11) which states that "The licensee shall comply with the terms, conditions, and specifications of the Coe .... "

This exemption will enable HDI to load fuel assemblies where the NSA cannot be removed from its fuel assembly. Under such conditions, the current requirements prevent some fuel assemblies from being loaded into dry storage systems, therefore preventing the full unloading of all assemblies from the IP2 and IP3 spent fuel pools. Once approved, HDI would like this exemption to apply to up to three (3) MPC-32M canisters licensed to Amendment 15 of Coe No. 1014.

2) Basis for Approval of Exemption Request In accordance with 10 CFR 72.7, the NRC may, upon application by any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.

a) Authorized by Law This exemption would allow HDI to load and store NSAs in a configuration that is not currently permitted in the approved contents defined in CoC No. 1014, HI-STORM 100S Version E Cask.

CoC No. 1014, Appendix D, Table 2.1-1,Section V, "MPC MODEL: MPC-32M," Item C, which only permits one NSA to be loaded into the inner region of an MPC-32M.

The NRC issued 10 CFR 72. 7 under the authority granted to it under Section 133 of the Nuclear Waste Policy Act of 1982, as amended, 42 U.S.C. § 10153. 10 CFR 72.7 allows the NRC to grant exemptions from the requirements of 10 CFR 72.

Granting the proposed exemption provides adequate protection to public health and safety, and the environment. As described below, the proposed exemption will not endanger life or property, or the common defense and security, and is otherwise in the public interest. Therefore, the exemption is authorized by law.

HDI-IPEC-22-030 Page 2 of 6 b) Will not Endanger Life or Property or the Common Defense and Security HDI in Enclosure 2 has evaluated loading and storing five (5) primary Pu-Be NSAs or thirty-two (32) NSAs with sufficient decay time into an MPC-32M. This evaluation concluded that the proposed loading configuration does not impact the criticality control, shielding, structural, confinement, or thermal design functions of the loaded MPC-32M, as described in the Safety Analysis section below. Therefore, the proposed exemption does not endanger life or property or the common defense and security.

c) Otherwise in the Public Interest Approval of this exemption request is required to support the complete removal of spent fuel from the IP2 and IP3 spent fuel pools. It is in the public's interest to grant an exemption, because dry storage of the IP2 and IP3 fuel assemblies places them in an inherently safe, passive system, and the exemption would permit this storage without the unnecessary burden and impact of requesting and approving an amendment to Coe No. 1014.

The requested exemption does not create a new accident precursor or result in an increase in the probability of any postulated accident. Nor will the requested exemption result in an increase in the consequences of postulated accidents. The requested exemption does not result in any change to the types or amounts of effluents that may be released offsite. There is no significant increase in occupational or public radiation exposure. Therefore, the requested exemption does not result in undue risk to public health and safety.

3) Safety Analysis The Holtec HI-STORM 100S System (i.e., a loaded Multipurpose Canister (MPC) stored within a HI-STORM overpack) provides criticality control, shielding, heat removal, and confinement functions, independent of any other facility structures or components. The structural design of the cask system also maintains the integrity of the fuel during storage.

The MPC design requires certain limits on spent fuel parameters, including fuel type, assembly weight, initial enrichment, total uranium weight, maximum burnup, maximum decay heat, minimum cooling time, and physical condition to safely store the spent fuel. These limitations are included in the thermal, structural, radiological, and criticality evaluations for the cask.

CoC No. 1014, HI-STORM 100S Version E Cask, Appendix D, Table 2.1-1,Section V, "MPC MODEL: MPC-32M," Item Conly permits one NSA to be loaded per MPC-32M cask. The NSA must be located in a cell in the inner part of the basket. This approach was initially implemented to simplify the qualification of NSAs, because no distinction needs to be made between different types of sources.

However, that differentiation can be important, because some NSAs (e.g., some primary sources) continue to have a significant neutron source term, whereas the neutron source term for others (secondary sources) vanish quickly over time and have a negligible affect by the time they are loaded into dry storage. This simplified approach was sufficient when loading casks during plant operations, because the number of sources is small relative to the number of assemblies in a spent fuel pool, and any "problematic" cases can be deferred to later casks. However, this

HDI-IPEC-22-030 Page 3 of 6 simplified approach is no longer beneficial or even feasible when loading all assemblies and Non-Fuel Hardware (NFH) from a decommissioned plant into dry storage due to the following reasons:

• In some cases, an NSA cannot be removed from the fuel assembly it is currently located in, or there is no alternative location for the NSA. Under such conditions, the current requirements prevent some fuel assemblies from being loaded into dry storage systems, therefore preventing the full unloading of all assemblies from a spent fuel pool.

• There is a large number of NSAs to be loaded. Allowing only a single NSA per cask may complicate full unloading post-shutdown and may require unnecessary swaps of NSAs and NFHs between assemblies to meet this requirement.

• Some damaged fuel assemblies contain an NSA. However, a damaged assembly is not authorized to be loaded in the center of the basket, the only location where an NSA is authorized to be loaded. Again, otherwise unnecessary swaps of NSAs and NFHs may be needed to meet the requirements.

Holtec Calculation Hl-2220153 (Enclosures 2 and 3), "Revised NSA Qualifications for HI-STORM Storage Systems," presents an evaluation of the neutron source strength of the various NSA types, to allow the implementation of more realistic and flexible loading requirements that resolve the issues stated above.

When an NSA source strength is small compared to the corresponding source strength of the fuel assembly, the dose effects of the NSA do not need to be considered. Holtec Calculation Hl-2220153 (Enclosures 2 and 3) concluded that NSAs of the Californium 252 (Cf-252), Polonium-Beryllium (Po-Be), and Antimony-Beryllium (Sb-Be) type, with cooling times that exceed the values listed in Section 4 of the Holtec Calculation, can be loaded into every cell of a basket without any limit on the number of NSAs per basket, and without further considerations of source strength in any dose rate evaluations. Holtec Calculation Hl-2220153 (Enclosures 2 and 3) also concluded that up to five (5) NSAs of the Pu-Be type can be loaded per basket with no other restrictions on source strength.

The additional gamma dose due to activation of components of the NSA will remain within the limits of 10 CFR 72.104 for normal conditions and 10 CFR 72.106 for accident conditions. HDI will confirm the site-specific shielding analysis (Hl-2094405 "Dose versus Distance from a HI-STORM Containing the MPC-32" Revision 21 dated September 13, 2021) remains a bounding analysis when considering the gamma source from the activated portions of the NSAs.

No modifications are needed to any other safety evaluations due to the following reasons:

• Criticality: As discussed in Section 6.4.9 of the Final Safety Analysis Report for the HI-STORM 100 Cask System, Hl-2002444, neutron sources may increase the neutron source terms but not the multiplication factor, hence the criticality safety evaluations are not affected.

• Confinement: The MPC enclosure vessel is the confinement boundary for the system. The storage of up to 32 NSAs does not increase the pressure inside the MPC or change the stresses in the enclosure vessel. Therefore, leakage from the MPC remains non-credible, and the confinement safety is unchanged.

HDI-IPEC-22-030 Page 4 of 6

• Structural design and thermal: The NSA are physically similar to burnable poison assemblies of thimble plug devices, which are already qualified for their presence in fuel assemblies in the MPC. The fuel assemblies containing the NSAs must continue to meet all the per cell heat load requirements as outlined in the Coe Thus, the NSAs have no effect on any of these safety evaluations The fuel assemblies to be loaded in the HI-STORM 100S Version E Cask, MPC-32M continue to meet all other fuel parameters, burnup and enrichment limits, and decay heat requirements.

Because the fuel assemblies meet all other requirements, and the system is operated in the same manner as described in the Final Safety Analysis Report for the HI-STORM 100 Cask System, there is no change to the structural, thermal, shielding, or confinement analysis of the system, and those areas are not further evaluated.

4) Environmental Consideration HDI has evaluated the environmental impacts of the proposed exemption request and has determined that neither the proposed action nor the alternative to the proposed action will have an adverse impact to the environment. Therefore, neither the proposed action nor the alternative requires any Federal permits, licenses, approvals, or other entitlements.

a) Environmental Impacts of the Proposed Action The interaction of a loaded HI-STORM 100S Version E Cask with the environment is through the thermal, shielding, and confinement design functions for the cask system.

• Steady state fuel cladding temperatures will not be impacted, because there is no change to the allowable decay heat limits of the spent fuel.

• The NSA source strength is small compared to the corresponding source strength of the spent fuel assembly, thus, the dose effects of NSAs that meet the cooling time requirements do not need to be considered. Additionally, HDI will confirm the site-specific shielding analysis (Hl-2094405 "Dose versus Distance from a HI-STORM Containing the MPC-32" Revision 21 dated September 13, 2021) remains a bounding analysis when considering the gamma source from the activated portions of the NSAs.

• Design aspects of the MPC enclosure vessel (i.e., the confinement boundary) will remain unchanged.

HDI has also determined that there are no increase in gaseous, liquid, or solid effluents (radiological or non-radiological), radiological exposures (worker or member of the public), or land disturbances associated with the proposed exemption. Therefore, approval of the requested exemption has no impact on the environment.

The proposed exemption does not increase the probability or consequences of accidents, no changes would be made to the types of effluents released offsite, and there would be no increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action. Additionally, the proposed action would not involve any construction or other ground disturbing activities, would not change the footprint of the Independent Spent Fuel Storage Installations (ISFSI), and would have no other

HDI-IPEC-22-030 Page 5 of 6 significant non-radiological impacts. The ISFSI is located on previously disturbed land, thus, the proposed exemption does not have the potential to create any significant impact on aquatic or terrestrial habitat in the vicinity of the ISFSI, or to threatened, endangered, or protected species. In addition, the proposed exemption does not have the potential to cause effects on historic or cultural properties, assuming such properties are present at the site of the Indian Point Energy Center ISFSI.

b) Adverse Environmental Effects Which Cannot be Avoided Should the Exemption be Approved Since there are no environmental impacts associated with approval of this exemption, there are no adverse environmental effects which cannot be avoided should the exemption request be approved.

c) Alternative to the Proposed Action In addition to the proposed exemption request, HDI has considered the alternative action.

Specifically, HDI would need to request the Coe holder to submit a request to amend Coe No.

1014, which the NRC would need to review and approve. While 10 CFR 72.7 does not require a description of "special circumstances," application of the applicable regulations [i.e., 10 CFR 72.212(b)(3) and (b)(11)] to the particular circumstances at IPEC would still serve the underlying purpose of the rule.

The underlying purpose of 10 CFR 72.212 is to allow reactor licensees to utilize dry fuel storage casks that have previously been found to be safe and appropriately analyzed for use by the cask designer, the cask user, and the NRC. As described above in the Safety Analysis Section, the storage of NSAs that meet the cooling time limit described above in an MPC-32M has been found to be non-safety significant, and in agreement with the underlying purpose of 10 CFR 72.212.

HDI currently plans to load IP2 spent fuel assemblies and the NSAs during the fall of 2022 and plans to commence loading the IP3 spent fuel assemblies and the NSAs in February 2023 as part of a campaign to transfer all spent fuel assemblies from the IP2 and IP3 spent fuel pools to the ISFSI.

Based on the amount of time required by NRC to review and approve previous CoC amendment requests (i.e., ranging from 18 months to 27 months), a CoC amendment request by HOLTEC to amend its currently approved CoC for the HI-STORM 100 Cask System will not provide adequate time for HDI to load the NSAs into MPC-32Ms. This could potentially result in HDI having to delay or postpone executing the scheduled spent fuel loading campaign; and therefore, unnecessarily extending the time frame that the IP2 and IP3 spent fuel pools would have to be maintained.

While this exemption request is made to support the IP2 and IP3 fuel offload schedule, the Coe holder (Holtec) does plan on making this change in a future CoC amendment.

d) Environmental Effects of the Alternatives to the Proposed Action There are no environmental impacts associated with the alternative to the proposed action.

HDI-IPEC-22-030 Page 6 of 6 e) Conclusion and Status of Compliance As a result of the environmental assessment, HDI concludes that the proposed action, which will allow HDI to load NSAs into an MPC-32M, is in the public interest in that it avoids an unnecessary delay in the safe loading and storage of spent fuel that would result from the alternative to the proposed action.

HOLTEC PROPRIETARY INFORMATION Enclosure 2 to HDI-IPEC-22-030 Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems Proprietary Version Withhold Information from Public Disclosure under 10 CFR 2.390 (17 Pages not including this Cover Page)

Enclosure 3 to HDI-IPEC-22-030 Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems Non-Proprietary (Redacted) Version (1 Page not including this Cover Page)

Nuclear Power Division 5014 HOL INTERNATIONAL TEC Sponsoring Company Project No.

Hl-2220153 0 04 Mar 2022 Company Record Number Revision No. Issue Date Report Proprietary Information Record Type Proprietary Classification Nuclear No Quality Class Export Control Applicability Record

Title:

Revised NSA Qualifications for HI-STORM Storage Systems Prepared by: Reviewed by: Approved by:

S.Anton, 03 Mar 2022 J.Rocheleau, 03 Mar 2022 J.Cascio, 04 Mar 2022 Signature histories are provided here for reference only. Company electronic signature records are traceable via C 0 *.

the provided Verification QR Code and are available for review within the secure records management system. A *- C1J valid Verification QR Code and the presence of this covering page indicates this record has been approved and ~ -c;,

accepted. -= 8a::

• =

~ Cf Proprietary Classification This record is the property of and contains Proprietary Information owned by the Company. It is to be used only in connection with the performance of work by the Company, its designated subcontractors, or its client. Dissemination, reproduction , publication or representation , in whole or in part, for any other purpose by any other party is expressly forbidden .

Export Control Status Not applicable.

Enclosure 4 to HDI-IPEC-22-030 Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure I, Jean A. Fleming, being duly sworn, depose and state as follows:

1) I have reviewed the information provided in Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems, which is sought to be withheld , and am authorized to apply for its withholding .

2) The information sought to be withheld is in Hl-2220153, Revised NSA Qualifications for HI-STORM Storage Systems, is provided as Enclosure 2, to HDI Letter HDI-IPEC-22-030. This document is a calculation and the information included in the document 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 of Information 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)(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;

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.

Page 1 of 3

Enclosure 4 to HDI-IPEC-22-030 Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

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.

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 lnternational'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 lnternational's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec lnternational'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.

Page 2 of 3

Enclosure 4 to HDI-IPEC-22-030 Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure Holtec lnternational'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.

STATE OF NEW JERSEY )

) ss:

COUNTY OF CAMDEN )

Jean A. Fleming, 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 J..!l..__ day of March 2022.

Jean A. Fleming Holtec Decommissioning International Holtec International VP, Regulatory & Environmental Affairs Subscribed and sworn before me this ~ day of March 2022 SHARON Y. PAGE NOTARY PUBUCOF NEW .ERSEY M'/CaNnmin &ins01l1&'2Q28 Page 3 of 3