ZS-2020-0015, Independent Spent Fuel Storage Installation - Response to NRC Request for Additional Information for Magnastor Basket Material Investigation for NAC CARs 19-01 and 19-02

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Independent Spent Fuel Storage Installation - Response to NRC Request for Additional Information for Magnastor Basket Material Investigation for NAC CARs 19-01 and 19-02
ML20076C526
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 03/11/2020
From: Gerard van Noordennen
ZionSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20076C524 List:
References
ZS-2020-0015
Download: ML20076C526 (9)
v • d • e


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~~~~~~~~z10NS0Lur10Nsl-LC~~~~~~~- An Enc,gySo'- Company March 11, 2020 ZS-2020-0015 U.S. Nuclear Regulatory Commission AT1N: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 Independent Spent Fuel Storage Installation Docket No. 72-1037

Subject:

Response to NRC Request for Additional Information for MAGNASTOR Basket Material Investigation for NAC CARs 19-01 and 19-02

References:

1. Revised Request for an Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC MAGNASTOR Storage System, Zion Nuclear Power Station, Units 1 and 2, dated January 30, 2020
2. Application for Exemption for Zion Independent Spent Fuel Storage Installation -

Request For Additional Information; Docket No. 72-1037, dated February 21, 2020

Background:

On August 26, 2019, Nuclear Assurance Corporation (NAC) issued CAR 19-01 to identify that material test certificates associated with specific MAGNASTOR basket material reported the Charpy V-notch specimen orientation as "TL", indicating that the v-notch specimens were tested in the longitudinal or,ientation. This longitudinal orientation is contrary to the requirements of NG-2322.2(a)(4) requiring that the Charpy V-notch specimens be oriented in a direction normal

[transverse] to the principal rolling direction.

The response to CAR 19-01 included an Engineering Evaluation of the compliance deficiency resulting from:

  • 3rd Party ASME Code Expert evaluation
  • Extent of condition report from NAC Fabrication
  • A Report of previous project leftover material UT Retesting (all were acceptable), and current project material UT retesting (also, all were acceptable)

On September 30, 2019, NAC issued CAR 19-02 to document a compliance deficiency found by Hitachi Zosen (HZ) during their extent of condition required by CAR 19-01. ASME Code Section III Subsection NG requires (for plate material greater than 0.75" thickness) ultrasonic examination (UT) shall be performed after rolling to size and after heat treatment. HZ's supplier (Kobe Steel) was perfonning the UT examination prior to the heat treatment (normalizing).

101 Shiloh Boulevard, Zion* IL 60099 (224) 789-4016

  • Fax: (224) 789-4008
  • www.zionsolutionscompany.com

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ZionSolutions, LLC ZS-2020-0015 Page 2 of 4 ZionSolutions submitted a revised exemption request (Reference 1) to resolve the deficiencies identified in NAC CARs 19-01 and 19-02. Enclosures 4, 5 and 6 of the exemption request provided the basis for acceptable compliance with the deficiencies identified in CARs 19-01 and 19-02. This letter documents the response to the NRC's Request for Additional Information (RAI) associated with the Exemption Request (Reference 2).

Responses to RAI:

This request for additional information identified information needed by the U.S. Nuclear Regulatory Commission staff in connection with its review of the application. The NRC staff used NUREG-1536, "Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility - Final Report," in its review of the application.

Each question listed below describes information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements. Zion's response to these questions are summarized in italics following each question, and provided in detail in Attachment 1, "NAC Responses to Request for Additional Information for the MAGNASTOR Exemption Requests."

Materials Review

1. (RAI) Provide additional information that demonstrates that the tested material in the NAC International (NAC) assessment of Charpy V-Notch (CVN) specimen orientation is of the subject basket assembly plates.

The NAC assessment in Enclosure 5, Report ID 71160-WP-020, Revision 2, "NAC International Assessment of Longitudinal Versus Transverse Charpy Impact Testing for A5 37 and A51 7 Materials," of the effects of CVN specimen orientation states that it used plate material from past and existing projects that are representative of the materials that are the subject of the requested exemption. However, for some of the subject basket assembly components, information on the steel grade is not available in the design drawings.

The staff notes that variations in CVN properties with respect to plate orientation are typically due to chemistry and microstructural features that may be unique to the steel grade and heat treatment. As a result, provide the following information and justify that it supports the representative nature of the NAC International assessment:

a. The American Society of Mechanical Engineers specification and grades of all procured plates for which the carbon steel grade is not defined in the drawings (e.g., drive pins and spacers in Drawing Nos 71160-575 (Basket Assembly) and 71160-675 (DF [Damaged Fuel] Basket Assembly).

The table provided on page 2 in Attachment 1 lists the NAC drawings and their bill of material (BOM) item numbers affected by the Charpy Impact Test orientation issue. It also specifies the material specifications procured to and used in fabrication.

ZionSolutions, LLC ZS-2020-0015 Page 3 of 4

b. Clarify whether the NAC assessment tested A516 or A517 steels. The staff notes that the title of the assessment includes" ... A537 and A517 Materials", while the provided tables of data include only A53 7 and A516 steels. This information is needed to demonstrate compliance with 10 CFR 72.122(a) and (b), 10 CFR 72.124(a), and 10 CFR 72.154.

The White Paper, 71160-WP-020 has been revised (i.e., now Rev. 03) by correcting an error in the report title (i.e., changed A517 to A516). This updated report is Enclosure 2 ofAttachment 1.

2. (RAJ) Provide details on the Kobe Steel data in the NAC assessment of CVN specimen orientation that demonstrate that the data is relevant to the behavior of the basket assembly plates. In support of the assessment of the effects of CVN specimen orientation, the exemption request provided Figure 1 from a Kobe Steel report.

It is unclear to the staff what materials were tested to generate the data in Figure 1 and thus whether that data supports the analysis of the basket assembly subcomponents. As a result, provide either the referenced Kobe Steel report or information on the material specification, grade, heat treatment, and thickness of the plates that were tested to generate the data. This information is needed to demonstrate compliance with 10 CFR 72.122(a) and (b), 10 CFR 72.124(a), and 10 CFR 72.154.

Enclosure 3 in Attachment 1 is the Kobe Steel report, "PGAl 9-0903" dated September 11, 2019.

3. (RAJ) Provide details on the ultrasonic re-examination of plates and justify that the results can be used to characterize the effects of normalizing of the subject basket assembly plates.

In support of the analysis of the implications of performing flaw examinations prior the normalizing treatment, some plates were re-examined after normalizing. It is unclear to the staff the extent to which steel plates were re-examined and if those plates are relevant to the subject basket assembly material. As a result, provide the quantity of examined plates, the approximate size/surface area examined, and the plates' material specification, grade, and thickness. Justify that these sampling conditions adequately support the conclusion that normalizing does not introduce additional defects in the material. This information is needed to demonstrate compliance with 10 CFR 72.122(a) and (b), 10 CFR 72.124(a), and 10 CFR 72.154.

Hitachi-Zosen (HZ) retested the remaining available material that was associated with the UT examination timing issue. HZ had 3 plates left in inventory from several lots ofmaterial that were used in TSC fabrication. At NA Cs request, HZ performed UT examinations ofSA-537, Class 1 (1 plate) and SA-516, Grade 70 (2 plates). The results of these re-examinations are shown in Enclosure 4 ofAttachment 1 and show they meet the NG-2500 acceptance criterion.

I I

I ZionSolutions, LLC ZS-2020-0015 Page 4 of 4 Attachment 1 (Enclosures 1, 2 ,3 and 4) contains NAC proprietary information which is being provided in support of the NRC review of ZionSolutions, LLC, Application for Exemption for Zion Independent Spent Fuel Storage Installation. Enclosed with this response is an Affidavit Pursuant to 10 CPR 2.390 by NAC International. The information to be withheld is being transmitted to the NRC as confidential commercial information and should be withheld from the public.

Respectfully,

(;~~~

Gerard van Noordennen Senior Vice President Regulatory Affairs Attachment 1: Detailed Response to RAI cc: John Hickman, U.S. NRC Senior Project Manager Bernard White, U.S NRC Senior Project Manager U.S. NRC Region III Regional Administrator Service List (Cover letter only, no attachment and enclosures)

Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service List cc:

Ken Robuck Steven A. Reynolds President and CEO Manager, Nuclear Facility Inspection EnergySolutions Division of Nuclear Safety 299 South Main Street, Suite 1700 Illinois Emergency Management Agency Salt Lake City, UT 84111 245 W. Roosevelt Road, Units 55 & 56 West Chicago, Illinois 60185 John Sauger President and Chief Nuclear Officer Kelly F. Grahn, Senior Health Physicist ReactorD&D Illinois Emergency Management Agency EnergySolutions Division of Nuclear Safety 121 W. Trade Street, Suite 2700 245 W Roosevelt Road, Building 8, Suite 55 Charlotte, NC 28202 West Chicago, IL 60185 Bruce Hinkley William P. Mazzeno Senior Vice President Emergency Management Coordinator D&D Operations Lake County Emergency Management Agency EnergySolutions 1303 N. Milwaukee Avenue 121 W. Trade Street, Suite 2700 Libertyville, IL 60048-1308 Charlotte, NC 28202 John E. Matthews Gerard van N oordennen Morgan, Lewis & Bockius LLP Senior VP Regulatory Affairs 1111 Pennsylvania Avenue, NW EnergySolutions Washington, DC 20004 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111

ZS-2020-0015 Attachment 1 Detailed Response to RAI

NAC

  • INTERNATIONAL NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 Doug Jacobs (Affiant), Vice President, Storage and Transportation Projects, hereinafter referred to as.

NAC, at 3930 East Jones Bridge Road, Peachtree Corners, Georgia 30092, being duly sworn, deposes and says that:

l. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein, and is authorized to request its withholding.
2. The information to be withheld includes the following NAC Proprietary Information that is being provided in support of the NRC review of ZionSolutions, LLC, Application for Exemption for Zion Independent Spent Fuel Storage Installation - Request for Additional Information (ML20050D504).

Docket No. 72-1037 and. Enterprise Project Identifier No. L-2020-LLE-OOOO for Exemption request dated December 30, 2019 (ML20003D845) as resubmitted on January 30. 2020 (ML20035E402) submittal -ZS-2020-0002.

  • Enclosure 2, 71160-WP-020 Rev 03, NAC International Assessment of Longitudinal Versus Transverse Charpy Impact Testing for A537 and AS 16 Materials, Rev. 3
  • Enclosure 3, Kobe Steel Ltd. Report, PGA19-0903, September 11, 2019
  • Enclosure 4, Hitachi Zosen, Record of UT Exam, October 17, 2019 NAC is the owner of this information that is considered to be NAC Proprietary Information.
3. NAC makes this application for withholding of proprietary information based 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 Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.
4. Examples of categories of infonnation that 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 competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.
b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.
c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies of NAC, its customers, or its suppliers.
d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.
e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.

ZionSolutions ZS-2020-0015 Page I of 3

NAC

The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.

5. The information to be withheld is being transmitted to the NRC in confidence.
6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of my knowledge and belief, consistently been held in confidence by NAC. 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 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 Items 7 and 8 folJowing.
7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Specialist, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.

Access to proprietary documents within NAC is limited via "controlled distribution" to individuals on a "need to know" basis. The procedure for external release of NAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside of NAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.

Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NAC's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process. The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment.

ZionSolutions ZS-2020-0015 Page2 of3

NAC

STATE OF GEORGIA, COUNTY OF GWINNETT Mr. Doug Jacobs, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief.

Executed at Peachtree. Corne~s, Georgia, this I b&-day of'-iv\

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tLlf r, LI ,2020.

Vice President, Storage and Transportation Projects, NAC International

  • Subscribed.and sworn before me this lD~day of :wla.,r(,_,L ,2020.

ZionSolutions ZS-2020-0015 Page 3 of3

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