ML23117A116

Response to Follow-up Questions to Tva’S Response to Nrc’S Request for Supplemental Information (Rsi) Related to August 4, 2022, Sequoyah ISFSI Exemption Request

ML23117A116
Person / Time
Site:	Sequoyah
Issue date:	04/27/2023
From:	Marshall T Tennessee Valley Authority
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML23117A115	List: ML23117A116
References
EPID L-2022-LLE- 0027
Download: ML23117A116 (1)

Text

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Sequoyah Nuclear Plant, P.O. Box 2000, Soddy Daisy, Tennessee 37384 April 27, 2023 10 CFR 72.7 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327, 50-328, and 72-034

Subject:

Sequoyah Nuclear Plant - Response to Follow-up Questions to TVAs Response to NRCs Request for Supplemental Information (RSI) Related to August 4, 2022, Sequoyah ISFSI Exemption Request (EPID No. L-2022-LLE-0027)

Reference:

1. TVA letter to NRC, Sequoyah Nuclear Plant - Request for Exemption from Various 10 CFR Part 72 Regulations Resulting from Non-Destruction-Examination Compliance, dated August 4, 2022

2. NRC letter to SQN, Request For Supplemental Information - Request for Exemption from Various 10 CFR Part 72 Regulations Related to Non-Destructive Examination Compliance, Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation [Enterprise Project Identification Number L-2022-LLE-0027], dated November 18, 2022

3. Sequoyah Nuclear Plant - Response to Request for Supplemental Information (D-RSI) Request for Exemption from Non-Destruction-Examination Compliance (EPID No. L-2022-LLE-0027), dated December 19, 2022

4. NRC email to SQN, Staff followup questions to TVA's 12/19/2022 response of the staff's RSI regarding 8/4/2022 SQN exemption request, dated February 27, 2023 Pursuant to 10 CFR 72.7, Specific exemption, TVA requested an exemption from the requirements of 10 CFR 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(11) and 72.214 by Reference 1.

1\\14 TENNESSEE VALLEY AUTHORITY

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 U.S. Nuclear Regulatory Commission Page 2 April 27, 2023 The NRC review of the exemption request identified information necessary to continue evaluation, Reference 2. Subsequent information was provided in Reference 3. Additional information is being sought by Reference 4. Enclosure 1 provides the TVAs response to Reference 4. Enclosure 2 to this letter is an affidavit prepared in accordance with 10 CFR 2.390 requesting that the proprietary evaluation provided in Enclosure 3 be withheld from public disclosure.

provides the Certificate Holders (Holtec International, Inc.) proprietary evaluation of the condition relative to the HI-STORM FW System licensing basis that includes SQN site specific conditions for a loaded Multipurpose Canister (MPC).

When separated from Enclosure 3, this cover letter, Enclosures 1, and 2 are decontrolled.

This document contains no new regulatory commitments. If you have any questions, please contact Rick Medina, Site Licensing Manager, at (423) 843-8129.

Respectfully, Thomas Marshall Site Vice President Sequoyah Nuclear Plant

Enclosure:

1. TVA Response to Request for Supplemental Information No. 2

2. Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

3. Response to Request for Technical Information RRTI-3087-007R3 (Proprietary) cc:

NRC Regional Administrator - Region II NRR Project Manager - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant Marshall, Thomas B.

Digitally signed by Marshall, Thomas B.

Date: 2023.04.27 08:30:25 -04'00' y

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-1 of E1-9 ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION TVA RESPONSE TO REQUEST FOR SUPPLEMENTAL INFORMATION No. 2 NRC Material Discipline

1.

Provide supporting information confirming that all repairs were performed on the outside diameter of the multipurpose canister (MPC) on weld #21. [RSI-M1, RSI-M2]

TVA Response 100% of repairs to Weld No. 21 were performed on the outside diameter (OD) of the Multipurpose Canister (MPC). The inspection results on the Visual Examination (VT) and Penetrant Examination (PT) reports for the excavation areas indicate that the 1st and 2nd repair iterations were performed on the outside diameter of the canister. The highlighted fields of Figures #1 and #2 on the VT and PT Reports provide objective evidence. For comparison and as an example, Figure #2 shows a VT and PT examination of Weld No. 4 on both the OD and inner diameter (ID).

NRC Material Discipline

2.

Provide supporting information confirming that the 7.5 inches of missing radiographic testing (RT) is approximately located between XX inches to YY inches (e.g., 15 inches to 22.5 inches) from the base of the MPC on the longitudinal weld. [RSI-M2]

TVA Response A modified sketch, Figure #3, is provided detailing the radiographic examination (RT) image zones and weld area. The length of weld that was not examined via RT is 10.608 inches which is approximately located between 16.493 (4+11.605+0.888) inches to 27.101 (16.493+10.608) inches from the bottom of the MPC baseplate of the MPC on the longitudinal Weld No. 21. This distance is based on measurements taken from the RT images for view 0-1 and view 1-2.

Datum point 0 begins at four (4) inches from the baseplate bottom with datum point 1 being approximately 11.605 inches. The radiographic image for view 0-1 extends approximately 0.888 inches into view 1-2. View 1-2 begins at 15.605 inches from the baseplate and is approximately 11.496 inches long. The 4 inch value is known as the location for the 0 marker on the MPC shell. The other dimensions are approximate based on measuring from within the RT digital image viewer.

NRC Material Discipline

3.

Provide supporting information explaining the rationale that the 0.327 inches lack of fusion (LOF) indication located in view 0-1 in approximately 8 inches to 14 inches zone extended to be a 16.5 inches excavation that extended approximately from 8 inches to 24 inches. [RSI-M2]

TVA Response The PT performed to verify removal of the defect caused the excavation area to extend into the adjacent view 1-2 which is approximately 15.605 to 27.101 inches from the bottom of the

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-2 of E1-9 baseplate. It should be noted that the removal of the defect may extend past the original area of identification (i.e., a clean PT must be achieved of the areas prior to any repair welding is performed). Excavating is performed until all evidence of defects is removed. The extent of excavation is based on the discretion of the individual performing the grinding activities and is performed until all evidence of discontinuities (i.e., relevant and non-relevant) are removed.

Once this is achieved then the repair welding is performed and subsequent nondestructive examination (NDE) (i.e. weld VT, PT, and RT) is performed and is not deemed acceptable unless all NDE for the area is acceptable.

NRC Material Discipline

4.

Provide supporting information on the identification (e.g., location and type) of any acceptable indications in the available RT examinations for weld #21 views 0-1 and 1-2.

[RSI-M1, RSI-M2]

TVA Response The initial RT identified 3.7 inches of lack of fusion within view 0-1. No indications were identified within view 1-2 during the initial RT. The subsequent RT examination identified 0.327 inches of lack of fusion within view 0-1. No indications were identified in the final RT examination of view 0-1. Figures #4, #5 and #6 provide the initial, 1st and 2nd iteration RT Reports for objective evidence.

NRC Structural Discipline

1.

Provide the resultant safety factor for the combined effects of local membrane plus primary bending stress at the sections of the MPC longitudinal shell-to-shell weld where the RT was missed. [RSI-S3]

In its December 19, 2022, response to RSI-S3, the applicant stated that the contributions from local membrane plus primary bending and secondary stresses are expected to be minimal given the separation distance from the shell-to-baseplate or shell-lid discontinuities. The response further states that the presented safety analysis considers the effects of local membrane plus primary bending stress since the maximum stress intensity values are compared conservatively with the applicable primary membrane stress limits (which are lower than local membrane plus primary bending stress and secondary stress limits) to compute the safety factors.

During the review of Holtec HI-2094418, Revision 20, Structural Calculation Package for HI STORM FW System, it was noted that the structural analysis followed the methodology in Regulatory Guide (RG) 7.6, Design Criteria for the Structural Analysis of Shipping Cask Containment Vessels. In this analysis, both the primary membrane stress AND the local membrane plus primary bending stress were considered, and the safety factors evaluated, in accordance with the regulatory position no. C.2 in RG 7.6.

The regulatory position states that, for normal conditions, the value of the stress intensity resulting from the primary membrane stress should be less than the design stress intensity, Sm, and the stress intensity resulting from the sum of the primary membrane stresses and the primary bending stresses should be less than 1.5 Sm. However, the analysis in Section 1.5 of Holtec RRTI 3087 007, Revision 2, only includes the calculated safety factor from stress intensity resulting from the primary membrane stress.

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-3 of E1-9 In addition, the exemption request does not contain adequate information in demonstrating the safety factor available/remaining at the shell, as resulted from the effects of local membrane plus primary bending stress remains within acceptable limits, after considering a reduction factor for the RT that was missed at the MPC longitudinal shell-to-shell weld.

This information is necessary to evaluate the requested exemption, under 10 CFR 72.7, from the requirements of 10 CFR 72.154(b), 10 CFR 72.212(a)(2), 72.212(b)(5)(i),

72.212(b)(11) and 72.214.

TVA Response TVAs spent fuel cask vendor, Holtec International, acknowledges Staffs follow up question and has revised RRTI-3087-007, found in Enclosure 3, to present separate evaluations and safety factors for both the primary membrane stress and the local membrane plus primary bending stress under all conditions. This is consistent with Holtec Report HI-2094418, Revision 20 and avoids any confusion caused by presenting the maximum computed stress (inclusive of contributions from primary membrane, local membrane and primary bending) and comparing it against the lower allowable for primary membrane stress (Sm) to compute a conservative safety factor in RRTI-3087-007 Revision 2.

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-4 of E1-9 Figure #1 Repair Iteration #1 (Repair Iteration 1): VT 12306-541 Rev 0 and PT 12306-530 Rev 0 MINF ll:lUINl DMSIIN HOLTEC IN TE R NATION AL General Description VT ofDR Rej ect Excavation Areas - 12306--888392-52 PWRPINCRIMIC 123~392-52 Procooun,: H SP 11 04 I Inspection Mll1elials:

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Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-5 of E1-9 Figure #2 Repair Iteration #2 (Repair Iteration 2): VT 12306-549 Rev 1 and PT 12306-538 Rev 1 c

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Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E1-6 of E1-9 Baseplate 27.101 0.888 15.605 10.608 Weld #21 0

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4 11.605 11.496 Figure #3 SQN S/N 234 EST 12306-888392-52 Note1:ThelengthofweldthatwasnotexaminedviaRTis10.608incheswhichis approximatelylocatedbetween16.493(15.605+0.888)inchesto27.101inchesfrom thebaseplateoftheMPC.

Note2:Theradiographicimageforview01extendsapproximately0.888inchesinto view12.View12beginsat15.605inchesfromthebaseplateandisapproximately 11.496incheslong.

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Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E2 ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk TV A Letter - Sequoyah Nuclear Plant - Request for Exemption AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:

(1)

I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2)

The information sought to be withheld is RRTI-3087-007 Rev 3, which contains Holtec 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), 2.390(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, 704F2dl280 (DC Cir. 1983).

1 of 5

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk TV A Letter - Sequoyah Nuclear Plant - Request for Exemption 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 2 of 5

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk TV A Letter - Sequoyah Nuclear Plant - Request for Exemption AFFIDAVIT PURSUANT TO 10 CFR 2.390 regulatory prov1s10ns 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 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 mJury.

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk TV A Letter - Sequoyah Nuclear Plant - Request for Exemption AFFIDAVIT PURSUANT TO 10 CFR 2.390 (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.

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.

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk TV A Letter - Sequoyah Nuclear Plant - Request for Exemption AFFIDAVIT PURSUANT TO 10 CFR 2.390 ST ATE OF NEW JERSEY COUNTY OF CAMDEN

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ss:

Kimberly Manzione, 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 25 th day of April, 2023.

Kimberly Manzione Director of Licensing Holtec International Subscribed and sworn before me this.Z)S-il-day of~,J_

, 2023.

5 of 5 Erika Grandrimo NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES JANUARY 17, 2027

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 3 E3 ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION Response to Request for Technical Information RRTI-3087-007R3 (Proprietary)