NLS2007007, Response to Request for Additional Information Regarding License Amendment Request for Onsite Spent Fuel Storage Expansion
| ML070440316 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/07/2007 |
| From: | Minahan S Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2007007 | |
| Download: ML070440316 (10) | |
Text
N Nebraska Public Power District Always there when you need us NLS2007007 February 7, 2007 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Request for Additional Information Regarding License Amendment Request for Onsite Spent Fuel Storage Expansion Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. Letter from Bhalchandra Vaidya, U.S. Nuclear Regulatory Commission, to Randall K. Edington, Nebraska Public Power District, dated January 9, 2007, "Cooper Nuclear Station - Request for Additional Information Re:
License Amendment Request for Spent Fuel Pool Storage Capacity (TAC NO. MD3349)"
- 2. Letter from Randall K. Edington, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated October 17, 2006, "License Amendment Request to Revise Technical Specification - Onsite Spent Fuel Storage Expansion" (NLS2006028)
The purpose of this letter is for the Nebraska Public Power District (NPPD) to submit a response to the Nuclear Regulatory Commission (NRC) Request for Additional Information (RAT) sent by NRC letter dated January 9, 2007 (Reference 1). The additional information in this letter is to support NRC review of the license amendment request for onsite spent fuel storage expansion at the Cooper Nuclear Station submitted by NPPD letter dated October 17, 2006 (Reference 2).
The response to the RAI contains information proprietary to Global Nuclear Fuels (GNF) pursuant to 10 CFR 2.390(a)(4). Attachment 1 is the proprietary response to the RAI. The proprietary information is indicated by double underlining and is enclosed in double brackets. Attachment 1 is requested to be withheld from public disclosure. Attachment 2 is the non-proprietary response suitable for public disclosure. The affidavit from GNF required by 10 CFR 2.390(b)(1) supporting the request for withholding is provided as Enclosure 1.
The information submitted by this RAI response does not change the evaluation of the No Significant Hazards Consideration submitted by the Reference 2 letter.
COOPER NUCLEAR STATION 7 P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2007007 Page 2 of 2 Should you have any questions regarding this submittal, please contact Paul Fleming, Licensing Manager, at (402) 825-2774.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ZOO
- r1 Sincerely, Stewart B. Minahan Vice President-Nuclear and Chief Nuclear Officer
/rr Attachments Enclosure cc: Regional Administrator w/ Attachments, Enclosure USNRC - Region IV Cooper Project Manager w/ Attachments, Enclosure USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ Attachments, Enclosure USNRC - CNS Nebraska Health and Human Services w/ Attachments, Enclosure Department of Regulation and Licensure NPG Distribution w/o Attachments, Enclosure CNS Records w/ Attachments, Enclosure
NLS2007007 Page 1 of3 Attachment 2 Response to Request for Additional Information Regarding License Amendment Request for Spent Fuel Pool Storage Expansion Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
Letter from Bhalchandra Vaidya, U.S. Nuclear Regulatory Commission (NRC), to Randall K. Edington, Nebraska Public Power District, dated January 9, 2007, "Cooper Nuclear Station - Request for Additional Information Re: License Amendment Request for Spent Fuel Storage Capacity (TAC NO. MD3349)"
- 1. NRC Request The Nuclear Regulatoiy Commission staff requests the licensee to provide the following information that is applicablefor the CNS Spent Fuel Pool (SFP)expansionfor thefuel assemblies expected to be dischargedin thefitture:
a) The types offuel assemblies to be stored.
NPPD Response The majority of the fuel assemblies to be stored in the new spent fuel storage racks will be GE14 assemblies. In addition, there are GE6, GE7B, and GE9B fuel assemblies, and eight GEl I lead test assemblies, currently stored in the existing racks that may be placed in the new racks. The GE6, GE7B, GE9B, and GE 14 fuel assemblies were addressed by Holtec, as reflected in Table 4-1 in the Holtec Licensing Report. The results of criticality and storage of these GEl 1 lead test assemblies are bounded by the results for the GE14 fuel assemblies.
b) Unif6rm average enrichment NPPD Response The values of uniform average enrichment for the fuel assemblies to be stored in the new spent fuel storage racks are specified in Table 1.
c) Dischargefuel burnup (MWD/KgU)
NPPD Response It is not known what the fuel burnup of the fuel assemblies currently in the CNS core (GE 14 assemblies) will be when the assemblies are discharged to the SFP. The minimum burnup of
NLS2007007 Page 2 of 3 the GEl4 fuel assemblies discharged to the SFP during the last refueling outage was 34.627 MWD/kgU.
d) Wt. 0% of Gd203 (Gadoliniaburnablepoison), and the number offuel rods that contain the Gadolinia.
NPPD Response The values of weight percent of the Gadolinia burnable poison and the number of fuel rods that contain the Gadolinia for the fuel assemblies to be stored in the new spent fuel storage racks are specified in Table 1.
e) The highest actual or calculatedvaluefor neutron multiplicationfactor (Keffi with the racks fully loadedwith fuel of the highest anticipatedreactivity andpoolflooded with unborated water at a temperature correspondingto the highest reactivity.
NPPD Response The Kerr for fuel at 3.3% enrichment with no Gadolinia is 0.9435. The Ket- for fuel at 4.9%
enrichment with a k-infinity (Standard Cold Core Geometry) of 1.33 at 13.18 MWD/KgU is 0.9424.
J) The highest actual or calculatedvaluefor K-infinity.
NPPD Response The highest actual or calculated values of K-infinity for the fuel assemblies to be stored in the new spent fuel storage racks are specified in Table 1.
- 2. NRC Request Please confirm that each of the limiting criteriafor acceptablestorage, as listed in Table 4-3 of Enclosure I of the submittal, are satisfied in the SFP expansion. lf any of the criteria are not satisfied, then identify it andprovidejustificationfor acceptability.
NPPD Response Each fuel bundle in both the core and SFP will meet one of the three acceptance criteria listed in Table 4-3 of Enclosure I of the license amendment request, letter from Nebraska Public Power District to the NRC dated October 17, 2006.
NLS2007007 Attachment 2 Page 3 of 3 Table I Fuel Information for Operating Cycle 24 Cooper Nuclear Station, Docket No. 50-298, DPR-46 FuelAssembly Uniform Average Peak K- Lattice Gadoliniaweight %
(fuel vendor Enrichment (weight%) Infinity (fuel vendor and number of rods designator) designator) 3881 3.85%[
2476 3.79%
2611 3.93%
2569 3.98%[
2800 3.95% ((
2801 3.93% ((
))l 2901 3.85%o 2902 3.86% ((I 3]6
NLS2007007 Page 1 of 4 Enclosure 1 Global Nuclear Fuels Affidavit Requesting Withholding of Proprietary Information Pursuant to 10 CFR 2.390
Affidavit Affidavit I, Jens G. M. Andersen, state as follows:
(1) I am Consulting Engineer, Thermal Hydraulic Methods, Global Nuclear Fuel -
Americas, L.L.C. ("GNF-A") 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 the attachment, "SFSP Rack Addition Fuel Information RAI Rev I", January 24,2007. GNF proprietary information is delineated by double underlined dark red font text and is enclosed inside double square brackets. Figures and large equation objects are identified with double square brackets before and after the object. The superscript notation ý3 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-A 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 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 Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. t1983).
(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-A's competitors without license from GNF-A 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 GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;
- 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) To address the 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, 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 information in confidence.
(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-A. Access to such documents within GNF-A 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 delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A'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 the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
Affidavit The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.
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-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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-A 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-A 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 affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 24th day of January, 2007.
Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@
0ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSN Correspondence Number: NLS2007007 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None N. A.
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