SBK-L-12199, Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage
| ML12271A276 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/20/2012 |
| From: | Walsh K NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-12199 | |
| Download: ML12271A276 (15) | |
Text
Attachment I Contains Proprietary Information Withhold Attachment 1 from public disclosure under 10 CFR 2.390 EN ER CGY,/4
,AXl,r ,t SAROOK September 20, 2012 10 CFR 50.90 SBK-L-12199 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage
References:
- 1. NextEra Energy Seabrook, LLC letter SBK-L-1 1245, "License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage,"
January 30, 2012
- 2. NRC letter "Seabrook Station, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage (TAC No. ME7946)," March 30, 2012
- 3. NextEra Energy Seabrook, LLC letter SBK-L-12099, Supplement to LAR 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage, May 10, 2012
- 4. NRC Letter "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage (TAC No. ME8688)," July 24, 2012 In Reference 1 and supplemented by Reference 3, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed change would revise the TS for new and spent fuel storage as the result of a new criticality analyses for the new fuel vault and the spent fuel pool.
ADO/
NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874
United States Nuclear Regulatory Commission SBK-L-12199 / Page 2 In Reference 4, the NRC staff determined that additional information is required to complete its review of the proposed change. The Enclosure to this letter provides NextEra's response to the request for additional information. to the enclosure (RRTI-2064-002, "Response to Request for Technical Information", Seabrook, RAI) contains information proprietary to Holtec International and is supported by an affidavit in Attachment 2 (Holtec Letter 2064-AFFI-03) signed by Holtec International, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations.
Accordingly, NextEra requests that the information that is proprietary to Holtec International be withheld from public disclosure in accordance with 10 CFR 2.390.
A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91 (b).
Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.
Sincerely, NextEra Energy Seabrook, LLC.
Kevin T. Walsh Site Vice President Enclosure cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305
United States Nuclear Regulatory Commission SBK-L-12199 / Page 3 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
a FPL Energy Seabrook Station AFFIDAVIT I, Kevin T. Walsh, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this response to request for additional information regarding license amendment request 11-04 are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed before me this 40 day of .2012 Kevin T. Walsh
/ -Notary Pub/ Site Vice President
Enclosure Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage
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1.0 Responses to NRC Reauest for Additional Information (RAI:
The NRC RAI is provided below. The RAI is annotated by NextEra with item numbers within brackets to highlight the information requested.
NRC RAI:
In the letter dated May 10, 2012, NextEra states that the acceptance criteria is 45 mil for the uniform void. Please clarify how the 45 mil limit was determined [Item 1] and why the uniform void is the conservative parameter to model the blisters [Item 2]. Also, please clarify how the uniform void volume is calculated including what measured blister dimensions-are used in the calculations
[Item 3].
[Item 11 The 45 mil criterion for the uniform void volume was chosen as a bounding value based on the early coupon measurements for BoralTM blistering. The 45 mil value is conservative relative to the measured blistering while not overly penalizing the criticality analysis.
[Item 2]
The response to the question of whether the uniform void model is conservative is supplied in . Two models were developed which examined the reactivity effect of having heterogeneous blisters on the BoralTM panels. The first model placed a large blister (with dimensions greater than the largest blister found on the coupons) on each vertical edge of the panel in every axial plane. Placement of the blisters on the edges is representative of the configuration found on the coupons in that the vast majority of the blisters are concentrated along the edges. The second model also placed these two large blisters in each axial plane but alternated placement between the edge and the center of the panel. This model was designed to evaluate the impact of the small number of center blisters observed on the coupons. Both heterogeneous blister models had the same void volume as the uniform void case previously evaluated. For the large blisters it is assumed that the BoralTM panels are touching the box wall of the racks. The total thickness of the poison thickness (0.075 inches) and void thickness (0.1075 inches) are combined and compared to the original poison gap thickness (0.09 inches) to determine the local reduction in the amount of water present in the flux trap. These large blisters result in a local reduction of the flux trap to 0.8650 inches from the nominal 1.05 inches since the blisters are modeled conservatively by placing all the blisters in the same location for each panel. As shown in , the results show that the reactivity due to the heterogeneous blister distribution is less than or statistically equivalent to that of the cases that utilized the uniform void model.
-I-
[Item 3]
The uniform void volume is calculated based on the coupon measurements.
Each BoralTM blister on a coupon is evaluated and contributes to the calculation of the uniform void volume. The height of each blister is measured with a precision height gage. This process yielded a reproducibility of + 0.0005 inches (one sigma).
The blister areas are measured using a digital macrophotograph of both sides of each coupon and
__Graphical Analysis Software thatidetermines blister area from the number of pixels in each blister image.
The blister areas were converted to square inches using the appropriate pixels per square inch conversion factor for each photo. This method has demonstrated a reproducibility of + 2.7% (+/- one sigma).
For the purposes of computing the blister volume, it is assumed that the outline of all blisters is circular and that the volume of the blisters is given by volume of a spherical cap of height h on a sphere of radius
- r. The volume of the cap is:
V= (113)rrh 2(3r- h) (Equation 1)
The area of the cap is:
2 A = 2rrrh - rrh Thus, r can be expressed in terms of h and the area of the blister A as:
r = A/2Trh + h12 In terms of the measurable quantities A and h, Equation 1 becomes:
V = h16 [3A + rrh2]
Using this method a volume for each blister is determined. Since the height of some blisters now exceeds the clearance within the coupon jackets, some blisters experience slight deformation when the coupon is again encapsulated in the jackets. Itshould also be noted that the blister measurement technique has improved over the years as more exact instruments and software have become available.
Therefore, the maximum volume for each blister from the coupon measurement campaigns from Cycle 12 onward is the data used to calculate and project future total blister volume.
The blisters found on both the front and back of the coupon are measured and combined to compare to the blister limit. An example of the results from the limiting coupon is presented below. The first column presents the maximum volume for the numbered blisters from the previous measurement campaigns (Cycles 12 and 13). The Cycle 14 volume is presented in Column 3 and the maximum of any of the three cycles is presented in Column 4 and carried forward as the blister volume. The total number of blisters and their combined measured volume are indicated at the bottom of the table for each side of the coupon.
Coupon Al 12 Front Exam #6 Jan. 2011 Coupon Al12 Back Exam #6 Jan. 2011 Cycle 13 C14 A112 F Cycle 14 C14Al12 B 0134 Cycle 14 Larger Vol. Bllsters# Vol. cu. In. Max. Larg rVol. Blister# Vol . I. Max.
0.02583 1 0.02263 0.02583 0.00208 1 0.00114 0.00208 0.00653 2 0.00493 0.00653 0.00404 2 0.00377 0.00404 0.01484 3 0.00901 0.01484 0.00848 3 0.00367 0.00848 0.02776 4 0.02400 0.02776 0.00134 4 0.00063 0.00134 0.00770 5 0.00676 0.00770 0.00572 5 0.00624 0.00624 0.10043 6 0.06430 0.10043 0.00460 6 0.00502 0.00502 0.01855 7 0.01682 0.01855 0.00839 7 0.00602 0.00839 0.00301 8 0.00289 0.00301 0.01850 8 0.01678 0.01850 0.00243 9 0.00345 0.00345 0.00414 9 0.00290 0.00414 0.00309 10 0.00234 0.00309 0.00425 10 0.00000 0.00425 0.02371 11 0.01702 0.02371 0.00278 11 0.00390 0.00390 0.00056 12 0.00073 0.00073 0.00166 12 0.00188 0.00188 0.00040 13 0.00054 0.00054 0.00081 13 0.00043 0.00081 0.00304 14 0.00186 0.00304 0.00326 14 0.00354 0.00354 0.00011 15 0.00022 0.00022 0.00311 15 0.00378 0.00378 0.00011 16 0.00006 0.00011 0.00106 16 0.00123 0.00123 0.00184 17 0.00268 0.00268 0.00065 17 0.00056 0.00065 0.00198 18 0.00239 0.00239 0.00187 18 0.00160 0.00187 0.00397 19 0.00475 0.00475 0.00319 19 0.00343 0.00343 0.00213 20 0.00241 0.00241 0.00236 20 0.00244 0.00244 0.00087 21 0.00103 0.00103 0.00715 21 0.00462 0.00715 0.00230 22 0.00312 0.00312 0.00405 22 x 0.00405 0.21271 23 0.20748 0.21271 0.00619 23 0.00469 0.00619 0.02687 24 0.02981 0.02981 0.00897 24 0.00963 0.00963 0.00045 25 0.00071 0.00071 0.00396 25 0.00324 0.00396 0.00861 26 0.03876 0.03876 0.01289 26 0.01145 0.01289 0.03340 27 0.00000 0.03340 0.00050 27 0.00022 0.00050 0.00047 28 0.00053 0.00053 0.00334 28 0.00322 0.00334 0.00105 29 0.00137 0.00137 0.00175 29 0.00119 0.00175 0.00110 30 0.00114 0.00114 0.01409 30 0.01127 0.01409 0.00633 31 0.00667 0.00667 0.00084 31 0.00062 0.00084 0.00664 32 0.00608 0.00664 0.02217 32 0.02311 0.02311 0.00863 33 0.00857 0.00863 0.00289 33 0.00232 0.00289 0.00000 34 0.00000 0.00000 0.00227 34 0.00235 0.00235 0.00395 35 0.00300 0.00395 0.00350 35 0.00346 0.00350 0.03244 36 0.02961 0.03244 0.00094 36 0.00056 0.00094 0.00316 37 0.00234 0.00316 0.00083 37 0.00045 0.00083 0.00390 38 0.00581 0.00581 0.00050 38 0.00053 0.00053 0.00062 39 0.00000 0.00062 0.00010 39 0.00015 0.00015 0.00280 40 0.00129 0.00280 0.00035 40 0.00038 0.00038 0.00001 41 0.00068 0.00068 0.00020 41 0.00014 0.00020 0.00917 42 0.00600 0.00917 0.00031 42 0.00156 0.00156 0.00286 43 0.00273 0.00286 0.00047 43 0.00038 0.00047 0.00307 44 0.00425 0.00425 0.00034 44 0.00045 0.00045 0.00001 45 0.00247 0.00247 0.00033 45 0.00008 0.00033 0.00000 46 0.00031 0.00031 0.00001 46 0.00021 0.00021 0.00000 47 0.00223 0.00223 0.00001 47 0.00010 0.00010 0.00355 48 0.00714 0.00714 Laroer Vol. I Blisters I C14 Al12 F IC 14 MAX 0.00001 49 0.00014 0.00014 0.61943 1 47 1 0.55576 1 0.66702 0.00025 50 0.00721 0.00721 0.00000 51 0.00118 0.00118 0.00000 52 0.02006 0.02006 0.00000 53 0.00124 0.00124 0.00000 54 0.00000 0.00000 0.00000 55 0.00335 0.00335 0.00000 56 0.00001 0.00001 0.00000 57 0.00065 0.00065 L Vol. Bs C14Al12F FC14M 0.18509 1 57 1 0.19633 I 0.22941 Reviewing the blister data shows some blisters with zero volume, such as Blister 34 on the front side of coupon Al 12. This blister was identified as a tiny nascent blister during the Cycle 10 exam with a calculated volume of 0.0005 in3 . Such small blisters are difficult to identify and contribute virtually nothing to the total blister volume. Nonetheless, such blisters are characterized to understand blister formation in the event that a sizable blister is observed at that location in subsequent exams. In this case, blister #34 could not be found in the subsequent exams and may have actually been a small nodule on the BoralTM clad formed during original manufacture and subsequently flaked off before the Cycle 11 exam. Blisters are not renumbered between examinations due to the confusion this would cause. Therefore, #34 is carried as a zero volume blister. It is also noteworthy that other blisters may disappear when they merge with adjacent blisters.
Coupon Al 12 shows the largest blister volume. The total volume of blisters is the combination of the front blister volume (0.66702 in3) and the back blister volume (0.22941 in3). The total volume of 0.89643 in3 (or a 10.6 mil uniform void over the coupon) is 23.6% of the equivalent uniform void volume of the limit of 3.8 in3 for the coupon (or a 45 mil uniform void over the coupon).
Attachment 2 Holtec International letter ID 2064-AFFI-03, Affidavit Pursuant to 10 CFR 2.390
MlEEHoltec
~ Center, 555 Lincoln Drive West, Marlton, NJ 08053 H O LTEC IN TERN AT I O N A L Telephone (856) 797-0900 Fax (856) 797-0909 Holtec International Document ID 2064-AFFI-03 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Thomas V. Fitzpatrick, 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 information provided with Holtec letter 2064004, specifically Holtec RRTI-2064-002, which contains Holtec Proprietary information and is appropriately marked as such.
(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)(1) 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, 704F2d1280 (DC Cir. 1983).
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Holtec International Document ID 2064-AFFI-03 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 paragraph 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 regulatory provisions or 2 of 5
Holtec International Document ID 2064-AFFI-03 AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 injury.
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Holtec International Document ID 2064-AFFI-03 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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Holtec International Document ID 2064-AFFI-03 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )
) ss:
COUNTY OF BURLINGTON )
Mr. Thomas V. Fitzpatrick, being duly sworn, deposes and says:
That he 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 Marlton, New Jersey, this 14 th day of September, 2012 Thomas V. Fitzpatrick Holtec International Subscribed and sworn before me this _ _ day of k-,o4c4 , 2012.
MARIA C. MASSI NOTARY PUBLIC OF NEW JERSLV My Commission Expires April 25,2015 5 of 5