ML25230A135
| ML25230A135 | |
| Person / Time | |
|---|---|
| Site: | 07109294 |
| Issue date: | 07/23/2025 |
| From: | Schichlein L Global Nuclear Fuel |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| M250279, EPID L-2025-LLA-0079, CAC 001029 | |
| Download: ML25230A135 (1) | |
Text
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Global Nuclear Fuel Proprietary Notice This letter transmits proprietary information in accordance with 10 CFR 2.390. Upon removal of Enclosures 1 and 2, the balance of the letter may be considered non-proprietary.
M250279 July 23, 2025 Director, Division of Spent Fuel Management Office of Nuclear Materials Safety & Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk Lisa K. Schichlein Global Nuclear Fuel -Americas, LLC Senior Licensing Engineer 3901 Castle Hayne Road Wilmington, NC 28401 USA Lisa.Schichlein@gevernova.us
Subject:
Additional Information Supporting the Review of NEDE-33881P Revision 8 (EPID 001029/L-2025-LLA-0079)
This letter transmits electronic media containing input files for modeling the criticality safety portion of Revision 8 of the New Powder Container (NPC) Safety Analysis Report (SAR),
NEDE-33881P (Reference 1), and provides the Global Nuclear Fuel - Americas, LLC (GNF) response to an Nuclear Regulatory Commission (NRC) question pertaining to the review of Section 6.8.2 of Revision 8 of the NPC SAR.
This information is being submitted specifically to support review of Revision 8 of the NPC SAR. and the associated electronic media contains detailed information that is of the type GNF considers to be proprietary in its entirety. contains proprietary information of the type that GNF maintains in confidence and withholds from public disclosure. Enclosure 3 is the non-proprietary version of Enclosure 2.
GNF hereby requests that the information in Enclosures 1 and 2 and the associated electronic media be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.
The affidavit contained within Enclosure 4 identifies that the information contained in Enclosures 1 and 2 and the transmitted electronic media have been handled and classified as proprietary to GNF and subject to the United States export control laws and regulations. A non-proprietary version of information contained in Enclosure 1 and the transmitted electronic media
M250279 Page 2 have not been provided in accordance with NRC lnfonnation Notice 2009-07, which states: "In instances in which a nonproprietary version would be of no value to the public because of the extent of the proprietary information, the agency does not expect a nonproprietary version to be submitted."
It is GNF's expectation that the NRC staff will use the proprietary infonnation in Enclosure 1 and in the electronic media solely for their review activities for Revision 8 of the NPC SAR. At the conclusion of the NRC review activities or when requested, GNF expects all copies of the electronic media will either be destroyed or returned to GNF and that all files installed, copied, or modified from the files contained on the electronic media will be securely destroyed.
If you have any questions about the information provided, please contact me at (910) 819-4815.
Sincerely, Lisa K. Schichlein Senior Licensing Engineer Global Nuclear Fuel - Americas, LLC Docket No. 71-9294 EPID No. 001029/L-2025-LLA-0079
Reference:
- 1. Letter, Lisa K. Schichlein (GNF) to NRC Document Control Desk, "GNF Request for Revision of the New Powder Container Certificate of Compliance (USA/9294/AF-96),"
M250112, April 4, 2025.
Enclosures:
- 1. Electronic Media Supporting Review of NEDE-33881P Revision 8 - GNF Proprietary Information - Non-Public
- 2. Response to Question on Section 6.8.2 - GNF Proprietary lnfonnation - Non-Public
- 3. Response to Question on Section 6.8.2 - Non-Proprietary Infonnation
- 4. Affidavit cc:
N Garcia Santos, USNRC E Lenning, USNRC M Catts, GEH/Wilmington P Ollis, GNF/Wilmington PLM Specification 008N9790 Revision 2
ENCLOSURE4 M250279 Affidavit
Global Nuclear Fuel-Americas AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Licensing Engineer, Fuels and Digital Engineering, Global Nuclear Fuel -
Americas, LLC ("GNF"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosures 1 and 2 of GNF letter, M250279, L. K. Schichlein (GNF) to Document Control Desk (US NRC),
Subject:
"Additional Information Supporting the Review of NEDE-33881 P Revision 8
(EPID 001029/L-2025-LLA-0079)," dated July 23, 2025 and the associated electronic media. The electronic media in Enclosure 1 contains files that are proprietary in their entirety. The electronic media is labelled with the notation "GNF Proprietary Information -
Withhold in Accordance with 10 CFR 2.390" and "GEH Proprietary Information - Non-PublicPl." The superscript notation (3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination. GNF requests that the Enclosure 1 electronic media be withheld from public disclosure. GNF proprietary information within text and tables in Enclosure 2 is identified by a dotted underline inside double square brackets. ((.This sentence is_an_example.Pl)) Figures and other large objects containing GNF proprietary information are identified with double square brackets before and after the object. In each case, the notation (3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF 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 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4).
The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF's competitors without license from GNF 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; M250279 Enclosures 1 and 2 Affidavit Page 1 of 3
- c.
Infonnation which reveals aspects of past, present, or future GNF customer-funded development plans and programs, resulting in potential products to GNF;
- d.
Infonnation which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The infonnation sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs ( 4 )a. and ( 4 )b. above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The infonnation is of a sort customarily held in confidence by GNF, 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 GNF, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the infonnation in confidence.
Its initial designation as proprietary infonnation, 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, or subject to the terms under which it was licensed to GNF.
(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 delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF 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 infonnation identified in paragraph (2) is classified as proprietary because it contains details of GNF's processes and designs. The development of this infonnation was achieved at a significant cost to GNF.
The development of this information is derived from an extensive experience database that constitutes a major GNF asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial hann to GNF's competitive position and foreclose or reduce the availability of profit-making opportunities. The infonnation is part of GNF's comprehensive BWR safety and 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 M250279 Enclosures 1 and 2 Affidavit Page 2 of 3
the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF.
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.
GNF's competitive advantage will be lost if its competitors are able to use the results of the GNF 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 GNF 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 GNF of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 17th day ofJuly 2025.
Lisa K. Schichlein Senior Licensing Engineer Global Nuclear Fuel - Americas, LLC 3901 Castle Hayne Road M250279 Enclosures l and 2 Affidavit Wilmington, NC 28401 Lisa.Schichlein@ge.com Page 3 of3
ENCLOSURE 3 M250279 Response to Question on Section 6.8.2 Non-Proprietary Information IMPORT ANT NOTICE This is a non-proprietary version of Enclosure 2, from which the proprietary infonnation has been removed. Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here ((
)).
M250279 June 17, 2025 NRC Question on Calculation Packages Non-Proprietary Information Page 1 of 7 If available, please provide any calculation packages and input model files used for the Criticality Safety portion of the SAR.
GNF Response The KENO-VI input files listed in Table 1 have been provided via electronic media in. The files in Table 1 correspond to the bounding Hypothetical Accident Conditions (HAC) and Normal Conditions of Transport (NCT) criticality evaluation results provided in Table 6.2 of the NPC SAR (Reference 1).
Table 1 - Bounding KENO-VI Input Files Case KENO-VJ Jnout Filename HAC Array Configuration
((
NCT Array Configuration
))
The bounding HAC analysis is provided in Section 6.6 of the NPC SAR (Reference 1) and the bounding NCT analysis is provided in Section 6.5 of the NPC SAR (Reference 1 ).
Reference
- 1.
Global Nuclear Fuel, "NPC Safety Analysis Report," NEDE-33881P, Revision 8, April 2025.
M250279 June 17, 2025 NRC Question on Section 6.8.2 Non-Proprietary [nformation Page 2 of 7 In section 6.8.2, a Calculational Bias of ((
)) is used in the formula for USL. What is your justification and/or method for obtaining this calculational bias?
GNF Response NOTE: The NRC had previously reviewed the KENO-VI benchmarking documentation as noted in the first two bullets of the Design Documents listed in Section 5 of the June 27, 2025, NRC Inspection Repo11 No. 71-00254/2025-201 (Reference 1 ).
The Upper Subcritical Limit (USL) and calculational bias provided in Section 6.8.2 of the NPC SAR (Reference 2) are derived from the Single-Sided Lower Tolerance Limit (SSLTL) methodology prescribed in Section 2.4 of NUREG-6698 (Reference 3 ). The SSL TL method is appropriate to use when there are no apparent trends in the calculated critical benchmark results and the critical experiment data has a normal distribution. Using the SSL TL method, a weighted mean bias is determined from Equation 8 of NUREG-6698 (Reference 3) and is provided below in Equation ( 1 ).
Bias = keff - 1 for keff < 1, else Bias = 0 (1)
The weighted mean keff is computed from Equation 3 and Equation 6 of NUREG-6698 (Reference 3) and is provided below in Equation (2).
~nkeffi
_ L. atf keff= I 1
n_l_
O"rjZ i
l with (2)
The summation index (i) in Equation (2) spans the total number of critical benchmarks (n),
where keffi is the computed eigenvalue of benchmark i. The critical experiment data relevant for this Area of Applicability (AOA) are based on ((
)) critical benchmarks from ((
))
critical experiments < 5 weight percent (wt.%) U-235 enrichment, which are provided in Table 1.
The computed eigenvalues (keffi) in Equation (2) are determined using KENO-VI with the ENDF /B-Vll cross section library and are provided in Table 2 alongside with the critical benchmarking information.
Table 6.31 of the NPC SAR (Reference 2) provides details regarding the AOA of the critical benchmarks. The summary of the trending analysis for this AOA is provided in Table 3. Linear regression fits are applied to the calculated kerr values versus the trending parameters hydrogen to uranium-235 ratios (H/U-235) and Energy of Average Lethargy causing Fission (EALF) and are provided in figure 1 and Figure 2, respectively. In these figures, K L is the one-sided lower tolerance limit defined by Equation 20 and Equation 21 ofNUREG-6698 (Reference 3).
M250279 Case Identification (ID)
((
Form Non-Proprietary Information Page 3 of7 Table 1-Critical Experiment Information U-235 wt.%
H/U-235 Reflector Geometry Description 11
M250279 Case#
((
((
Non-Proprietary Information Page 4 of 7 Table 2-KENO-VI Tabulated Results for Bias Determination Case ID kerr O"ca1c O"exp EALF (eV)
Mean Free H/U-235*
Path (cm)
))
))
M250279 rr
((
Non-Proprietary Information Page 5 of 7 Table 3 - Summary of Trending Analysis for AOA Parameters H/U-235 EALF
))
))
Figure 1-kerr as a Function of H/U-235 Ratio
M250279
((
((
Non-Proprietary Information Page 6 of 7
))
Figure 2 - kerr as a Function of EALF
)) a dissimilarity penalty is included in the USL using the SCALE6.l/TSUNAMI code system (Reference 4) ((
)) described in Section 6.8.3.6 of the NPC SAR (Reference 2). A comparison of the application systems and the benchmark experiments is provided in Section 6.8.3.7 of the NPC SAR (Reference 2). ((
)) indicating a high degree of similarity to the benchmark experiments. The final expression for the USL which includes the dissimilarity penalty, the bias, the bias uncertainty, and the margin of subcriticality is provided in Section 6.8.2 of the NPC SAR (Reference 2).
References I.
Gerond George (NRC) to Brian Neely (GEH), "GE Hitachi Nuclear Energy Americas, LLC - U.S. Nuclear Regulatory Commission Inspection Report No. 71-00254/2025-201,"
June 27, 2025. (ML25175A273)
- 2.
Global Nuclear Fuel, "NPC Safety Analysis Report,'" NEDE-33881P, Revision 8, April 2025.
- 3.
NUREG/CR-6698, "Guide for Validation of Nuclear Criticality Safety Calculational Methodology," January 2001.
M250279 Non-Proprietary Information Page 7 of7
- 4.
"SCALE: A Comprehensive Modeling and Simulation Suite for Nuclear Safety Analysis and Design," ORNL/TM-2005/39, Version 6.1, June 2011. (Available from Radiation Safety Information Computational Center at Oak Ridge National Laboratory as CCC-785.)