ONS-2014-015, Responses to U.S. Nuclear Regulatory Commission Request for Additional Information for Duke Energy Carolinas, LLC Exemption Request from Certain Requirements of 10 CFR 72.212(b)(3) and 72.212(b)(11)
| ML14346A008 | |
| Person / Time | |
|---|---|
| Site: | Oconee, 07200040  |
| Issue date: | 12/08/2014 |
| From: | Batson S Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| ONS-2014-0157, TAC L24946 | |
| Download: ML14346A008 (9) | |
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SCOTT L.BATSON Vice President Oconee Nuclear Station ENERGY, Duke Energy ONO 1VP / 7800 Rochester Hwy Seneca, SC 29672 864-873-3274 864-873-4208 fax ONS-2014-0157 Scoff. Batson@duke-energy.com December 8, 2014 10 CFR 72.7 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Duke Energy Carolinas, LLC Oconee Nuclear Station Units 1, 2, and 3 Independent Spent Fuel Storage Installation (ISFSI)
Docket No. 72-40
Subject:
Responses to U.S. Nuclear Regulatory Commission Request for Additional Information for Duke Energy Carolinas, LLC Exemption Request from Certain Requirements of 10 CFR 72.212(b)(3) and 72.212(b)(11)
[Docket No. 72-40, TAC No. L24946]
References:
- 1. Duke Energy Exemption Request to Certain Requirements of 10 CFR 72.212(b)(3) and 72.212(b)(1 1) pursuant to 10 CFR 72.7, dated August 28, 2014.
- 2. NRC Certificate of Compliance for Spent Fuel Storage Casks Issued to Transnuclear, Inc., Certificate No. 1004, Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Amendment No. 9.
- 3. NRC letter, "Request for Additional Information for Request for Exemption from 10CFR72.212(b)(3) and 72.212(b)(11)," dated November 3, 2014.
On August 28, 2014, Duke Energy Carolinas LLC (Duke Energy) submitted an exemption request to certain requirements of 10 CFR 72.212(b)(3) and 72.212(b)(11) pursuant to 10 CFR 72.7 (Reference 1). These regulations require, in part, compliance to the terms and conditions of the NUHOMS Certificate of Compliance (CoC) 1004 (Reference 2). The CoC conditions require the general licensee to meet the requirements of the Technical Specifications (TS) for the NUHOMS storage system (Attachment A to the CoC).
In this submittal Duke Energy requested a permanent exemption from the TS inner seal weld helium leak rate acceptance value for five (5) dry storage containers (DSCs) where the seal weld helium leak check had been performed using an incorrect Enclosures 3 and 6 to this letter contain proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390. 3 Upon removal of Enclosures 3 and 6 this letter is uncontrolled.
U. S. Nuclear Regulatory Commission December 8, 2014 Page 2 temperature correction coefficient. The justification for the request was that the reduction in both the risk of a cask handling accident and substantial personnel exposure during cask re-test activities outweighed the risk associated with the small increase in the TS acceptance value for these containers.
On November 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) requested additional information related to this exemption request (Reference 3). The attachment to this submittal includes Duke Energy's responses to those RAI items. In addition:
Enclosure 1 provides an affidavit, in accordance with 10 CFR 2.390, specifically requesting that the proprietary information included in Enclosure 3 and Enclosure 6 of this submittal be withheld from public disclosure. A non-proprietary version of Enclosure 3 is provided in Enclosure 4. A non-proprietary version of Enclosure 6 is not being provided as these files are entirely proprietary.
Enclosure 2 provides Calculation Number 13922-0402, Revision 0, Helium Leak Rate Evaluation for 24PHB DSC.
- Enclosure 3 provides Calculation Number 1098-8, Revision 3, Helium Leak Testing Vent and Siphon Ports for Leak Tight NUHOMS DSCs (Proprietary version).
- Enclosure 4 provides Calculation Number 1098-8, Revision 3, Helium Leak Testing Vent and Siphon Ports for Leak Tight NUHOMS DSCs (Non-proprietary version).
- Enclosure 5 provides a listing of the 24 PHB leakage rates.
- Enclosure 6 provides input and output for the 24 PHB leakage rates (Proprietary).
There are no regulatory commitments contained within this submittal.
If you have any questions or require additional information, please contact Stephen C. Newman, Lead Engineer, Oconee Nuclear Station Regulatory Affairs Group, at (864) 873-4388.
Sincerely, Scott L. Batson Site Vice President Oconee Nuclear Station Attachment 7 Enclosures Enclosures 3 and 6 to this letter contain proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390.
Upon removal of Enclosures 3 and 6 this letter is uncontrolled.
U. S. Nuclear Regulatory Commission December 8, 2014 Page 3 cc: w/attachment/enclosures Mr. Victor McCree Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Robert P. Carrion, Division of Reactor Safety U. S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 Mr. James R. Hall, Senior Project Manager (by electronic mail only)
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mailstop O-8G9A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management SC Dept. of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201 Catherine Haney, Director Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 14A12 Rockville, MD 20852-2738 Michele Sampson - Chief, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 14A44 Rockville, MD 20852-2738 Enclosures 3 and 6 to this letter contain proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390.
Upon removal of Enclosures 3 and 6 this letter is uncontrolled.
U. S. Nuclear Regulatory Commission December 8, 2014 Page 4 xc: w/attachment/enclosures (continued)
Jennifer Davis, Project Manager, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 7F27 Rockville, MD 20852-2738 Enclosures 3 and 6 to this letter contain proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390.
Upon removal of Enclosures 3 and 6 this letter is uncontrolled.
ATTACHMENT Duke Energy Responses to NRC Request for Additional Information (RAI)
Attachment - Responses to NRC Request for Additional Information (RAI)
Page 1 This information is needed to determine the acceptability of an exemption from 10 CFR72.212(b)(3) and 72.212(b)(11).
NRC RAI Item 1(a)
Provide the following information:
For each affected canister, provide a comparison table illustrating both the leakage rates with the correct and incorrect temperature correction coefficients applied.
Provide calculation(s), including the assumed ambient temperatures, illustrating how the temperature correction factor was applied to arrive at a revised leakage rate limit of 1.02 x 10^1- 0 7 reference cc/ sec.
Duke Energy Response In support of this request, please refer to the following enclosures:
- Enclosure 1 provides an affidavit, in accordance with 10 CFR 2.390, specifically requesting that the proprietary information included in Enclosure 3 and Enclosure 6 of this submittal be withheld from public disclosure. A non-proprietary version of Enclosure 3 is provided in . A non-proprietary version of Enclosure 6 is not being provided as these files are entirely proprietary.
- Enclosure 2 Calculation Number 13922-0402, Revision 0, Helium Leak Rate Evaluation for 24PHB DSC.
- Enclosure 3 provides Calculation Number 1098-8, Revision 3, Helium Leak Testing Vent and Siphon Ports for Leak Tight NUHOMS DSCs (Proprietary version).
- Enclosure 4 provides Calculation Number 1098-8, Revision 3, Helium Leak Testing Vent and Siphon Ports for Leak Tight NUHOMS DSCs (Non-proprietary version).
- Enclosure 5 provides a listing of the 24 PHB leakage rates.
" Enclosure 6 provides input and output for the 24 PHB leakage rates (Proprietary).
Attachment - Responses to NRC Request for Additional Information (RAI)
Page 2 NRC RAI Item 1(b)
ANSI N14.5 identifies leak-tight as lx1OA-07 reference cc/sec and the identified revised technical specification is being identified as 1.02x1 OA^07 reference cc/sec. Understanding the sensitivity of the calculations to the respective temperature correction values, in light of the worst case temperature assumption, is necessary to evaluate whether the 2% increase in the Technical Specification limit has a safety implication requiring the calculation of release fractions. At this magnitude of values, there may be no discernable difference between the two leakage rate limits, given the capabilities of the measuring instruments.
Duke Energy Response Please refer to the response to Item 1(a).
NRC RAI Item 2 Provide the error range for the calibrated or standard leak used during the leak testing operations.
Staff is unclear as to the level of uncertainty in the measured leak testing values without complete information on the calibrated or standard leak used to provide a testing baseline.
Duke Energy Response As stated on the calibration certificate for helium calibrated leak given in Enclosure 7, the total uncertainty in the measured leak rate of the gas leak standard is less than +/- 10%.
ENCLOSURE 1 AREVA Affidavit
i',nclosurm I I,'-4045 1 A*FIDAVIT PURSUANT IQO 1Q 2.9 AREVA Inc. )
County of Howard )
1, Jayant Bondre, depose and say that T am a Vice President of ARRVA Inc., duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the following paragraph. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations ror withholding this Information.
The information for which proprietary treatment is sought is contained in Enclosures 3 and 6, as listed below:
- Enclosure 3, Calculation Number 1098-8, Revision 3, Helium Leak Testing Vent and Siphon Ports for Leak right NUHOMS DSC's, specific sections as identified.
- Enclosure 6, input and output for the 24 PHB leakage rates.
I have personal knowledge of the criteria and procedures utilized by AREVA Inc., in designating information am a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withhold.
I) The information sought to be withheld from public disclosure involves information in Calculation Number 1098-8, Revision 3 and the input and output files for the 24 PHB leakage rates, both related to the design of the NUHOMS' spent fuel storage systems, which are owned and have been held in confidence by ARE.VA Inc.
- 2) The information is of a type customarily held in confidence by AREVA Inc., and not customarily disclosed to the public. AREVA Inc. has a rational basis for determining the types of information customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of AREVA Inc.,
because the information is related to the design of spent fuel storage systems, the application o1r which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with AREVA Inc., take marketing or other actions to improve their product's position or impair the position of AREVA Inc.'s product and avoid developing similar data and analyses in support of their processes, methods or apparatus.
Further the deponent sayeth not.
ia~ Bndm Vice President and COO, AREVA Inc.
Subscribed and sworn to me before this 19Ih day of November. 2014.
Notary Public p ,. Page I of I 380:6T KT-TT-15T. 1310H HNIHUN 26TS1 EElZH :
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