ML24004A040

Response to Nrc’S November 8, 2023, Request for Additional Information - Related to Independent Spent Fuel Storage Installation

ML24004A040
Person / Time
Site:	Sequoyah
Issue date:	01/03/2024
From:	Marshall T Tennessee Valley Authority
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24004A039	List: ML24004A040
References
EPID No. L-2022-LLE-0027
Download: ML24004A040 (12)

Text

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Sequoyah Nuclear Plant, P.O. Box 2000, Soddy Daisy, Tennessee 37384 January 3, 2024 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 NRCs November 8, 2023, Request for Additional Information -Related to Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation (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. 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

4. 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

5. 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), dated April 27, 2023

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 U.S. Nuclear Regulatory Commission Page 2 January 3, 2024

6. NRC letter to SQN, Request for Additional Information - August 4, 2022, Exemption Request for Deviating from the Conditions of Certificate of Compliance No. 1032, Amendment No. 3, Related to Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation, dated November 8, 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.

The NRC review of the exemption request identified information necessary to continue evaluation, References 2 and 3. In response, TVA provided subsequent information in References 4 and 5, respectively. Additional information is being sought by Reference 6. provides the TVAs response to Reference 6. Enclosure 2 to this letter is an affidavit prepared in accordance with 10 CFR 2.390 requesting that the proprietary evaluation provided in Enclosures 3 and 4 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 Enclosures 3 and 4, 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 or rmedina4@tva.gov.

Respectfully, Thomas Marshall Site Vice President Sequoyah Nuclear Plant

Enclosure:

1. TVA Response to Request for Additional Information

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

3. Response to Request for Technical Information RRTI-3087-0007R4 (Proprietary)

4. Node List for Stress Plots (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: 2024.01.03 16:21:49 -05'00'

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 E1-1 of E1-2 ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION TVA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Structural Evaluation RAI 1 [validation of resultant stresses]

Describe the methodology that was used to determine the new stress values and justify how the relevant stress intensity plots correspond to the affected weld region in terms of its actual location in the model, and relative to the stresses and location of the plots from the original analysis.

As illustrated in Figure 1.5 of calculation no. HI 2094418, revision 20, Structural Calculation Package for HI-Storm FW System, the section of the weld missing radiograph test results is in a transitional stress zone, where stresses can vary significantly with minor changes in location. Although the analysis provided in the exemption request (RRTI-3087-0007, Revision 3) states that the presented maximum stress results are for the multipurpose cask (MPC) shell at the affected weld region between 10"-30" from the bottom of the baseplate, the information provided was not sufficient to clearly correlate and validate the maximum stress results provided for the exemption request.

Additional information is necessary to help verify the computed results and to better understand the methodology followed to select and analyze the affected location to correlate the new stress values with those of the original certificate of compliance (CoC).

This information is necessary to demonstrate compliance with the regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR) 72.24(c) and 10 CFR 72.24(d) with respect to the technical information necessary to support the exemption request. Sections 4.5.2 and 4.5.4 of NUREG-2215 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities provides guidance on the design criteria and analytical approach that is acceptable to the U.S. Nuclear Regulatory Commission staff that the applicant can follow to qualify the structural performance of each of the structures, systems, and components.

TVA Response Per the request, additional information is provided in the revised RRTI-3087-0007 (R4),, to show correlation for the stresses in the specific location in question (10-30 from the bottom of the MPC baseplate) for one of the five cases using plots generated from the existing MPC stress analysis in HI-2094418, Revision 20. In addition, Enclosure 4, provides the Z (vertical) direction coordinates of all the nodes included in the stress plots presented in RRTI-3087-0007(R4) in the region of interest. As shown in the Enclosure 4, the nodes start from approximately 9 inches and end at approximately 31 inches from the bottom of the MPC.

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 E1-2 of E1-2 NRC RAI 2 [analysis of postulated accidents]

Provide additional information to demonstrate that the package design is capable of withstanding the postulated accidents in the CoC after considering the weld strength reduction factor proposed for the exemption request.

For CoC No. 1032, a cask drop and tipover analysis was considered as part of the evaluation. The results of the LS-DYNA analysis demonstrated, in part, that the MPC confinement boundary was not breached after a tipover event. Since the analysis assumed full-strength capacity for the welds at the MPC shell and the exemption request considers a reduction factor to account for potential imperfections in the weld at the shell, additional information is necessary to demonstrate that the stresses at MPC shell remains within the code allowable limits for the postulated accidents conditions and to demonstrate that confinement boundary is maintained after these events..

This information is necessary to demonstrate compliance with the regulatory requirements in 10 CFR 72.122(b) and 10 CFR 72.122(c) with respect to the design of structures, systems and components important to safety being capable to withstand postulated accidents in support of the exemption request. Sections 4.5.2 and 4.5.4 of NUREG 2215 provides guidance on the design criteria and analytical approach that is acceptable to the staff that the applicant can follow to qualify the structural performance of each of the structures, systems, and components..

TVA Response Per the request, additional information is provided in the revised RRTI-3087-0007 (R4),, for stresses in the applicable region of the MPC shell (10-30 from the bottom of the MPC baseplate) from non-mechanistic tipover analysis of HI-STORM FW cask with MPC-37 presented in Section 3.4 of HI-STORM FW FSAR.

It is noted that no new analysis is performed and the governing simulation results from the existing analyses in Holtec Report HI-2094353 (supporting documentation for HI-STORM FW FSAR) are post-processed to obtain the specific information and used to calculate the safety factors using the same weld strength reduction factor from Section 1.5 of RRTI-3087-0007. All calculated safety factors are greater than 1.0.

There is no cask drop analysis performed for CoC No. 1032 (Amendment 3) because single failure proof equipment are required to be used to handle the casks making a drop non-credible.

Therefore, no additional information for cask drop analysis is provided herein.

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 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 4 and the node list file (Enclosures 3 and 4), which contain 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.l 7(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).

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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

( 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 lilJUry.

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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 STATE OF NEW JERSEY COUNTY OF CAMDEN

)

)

)

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 19th day of December, 2023.

Kimberly Manzione Director of Licensing Holtec International Subscribed and sworn before me this 2o day of oecembec, 2023.

KORIN M FAGAN Notary Public, State of New Jersey

1. 1 My Commission Expires

,,f.s b_~~ary 15, 2024

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Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 E3 ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION Response to Request for Technical Information RRTI-3087-0007R4 (Proprietary)

Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 Proprietary Information - Withhold Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 3 and 4 E4 ENCLOSURE 4 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION Node List for Stress Plots (Proprietary)