ML11208C453

Units, 1 and 2 - Exemption Request for Nuhoms Dry Shielded Canisters Loaded to Incorrect Heat Load Limits

ML11208C453
Person / Time
Site:	North Anna
Issue date:	07/21/2011
From:	Hartz L Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
11-262
Download: ML11208C453 (21)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 21, 2011 ATTN: Document Control Desk Serial No.11-262 Office of Nuclear Material Safety and Safeguards NLOS/TJS R1 U.S. Nuclear Regulatory Commission Docket Nos. 50-338 Washington, D.C. 20555-0001 50-339 72-56 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 EXEMPTION REQUEST FOR NUHOMS DRY SHIELDED CANISTERS LOADED TO INCORRECT HEAT LOAD LIMITS Pursuant to 10 CFR 72.7, Virginia Electric and Power Company (Dominion) requests a one-time exemption from the requirements of 10 CFR 72.212(b)(3) and (b)(1 1) for NUHOMS Dry Shielded Canisters (DSC), Model Number HD-32PTH, with serial numbers DOM-32PTH-004-C, -005-C, -007-C, -010-C, -013-C, -019-C and GBC-32PTH-011-C due to a non-compliance with the terms and conditions of the Transnuclear, Inc. Certificate of Compliance (CofC) Number 1030, Amendment 0, at the time of cask loading. The regulations require, in part, compliance to the terms and conditions of CofC 1030.

Contrary to this requirement, the seven DSCs identified above were not loaded in compliance with CofC 1030, Amendment 0. The 32PTH DSC is designed for zoned loading with respect to decay heat. The four center locations are divided into an upper Zone "1b" and a lower Zone "la"with the lower Zone "la" locations allowing a greater decay heat than the upper Zone "l b" locations. The upper and lower orientation of the Zone "Ib" and Zone "la" locations were reversed when preparing the DSC loading maps for the affected DSCs. As a result, fuel assemblies qualified to the Zone "la" decay heat limit were placed in Zone "l b" locations when the DSCs were loaded. It has been determined that the DSC Zone "1b" location decay heat limit was exceeded for twelve fuel assemblies distributed over the seven affected DSCs at the time of loading.

Upon discovery, an extent of condition review was performed on all North Anna DSCs.

It was verified that all DSC loadings were below the total heat load limit for the DSC and the combined Zone la and Zone lb heat load limit at the time of loading. Only the decay heat limit for the individual fuel cell was exceeded at the time of loading for the twelve fuel assemblies distributed over the seven affected DSCs. The decay heat for all but one of the twelve affected assemblies currently meets the decay heat limit for their

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Page 2 of 4 location within the DSC due to the time they have been in storage. Fuel assembly 2B2 in DOM-32PTH-DSC-004-C was determined to be seven watts above its location limit as of the date of discovery (03/24/11). However fuel assembly 2B2's decay heat will meet the location limit of 800 watts after 07/31/11.

The design basis shielding analysis was verified to remain bounding for the as-loaded DSCs. The design basis shielding analysis assumes a DSC loading of 32 assemblies all having source terms applicable to assemblies generating 1.5 kW of decay heat and therefore bounds the as-loaded DSCs. The reactivity parameters for the fuel and DSCs were also verified to be unaffected by the loading error and therefore remain bounded by the design basis analysis assumptions.

A thermal evaluation which conservatively bounds the as-loaded configurations of the affected DSCs has been performed by Transnuclear, Inc., the CoC holder for the 32PTH DSC. This evaluation was performed consistent with the methods and assumptions used for the 32PTH DSC thermal analysis described in the NUHOMS HD Updated Final Safety Analysis Report (UFSAR). The evaluation concludes the fuel cladding temperatures did not exceed the fuel cladding temperature design limit of 4000C (7520 F) for storage or transfer conditions. Further it shows that the DSC fuel compartment and support rail temperatures were bounded by those used in the design basis analysis, indicating there was no impact on the design basis structural evaluation of the DSC basket due to the loading error. The evaluation also concludes that the maximum DSC internal pressure remained below the design limit for the as-loaded configurations.

The seven DSCs are currently considered operable and performing their intended safety functions. Post-loading surveillance parameters have been and continue to be within acceptable limits.

Details of Dominion's need and justification for the issuance of an exemption are included in Attachment 1. contains Transnuclear, Inc. Calculation Number 10494-174, "Effect of the Reversed Loading Patterns on the Thermal Performance of 32PTH DSC". This calculation is PROPRIETARY to Transnuclear, Inc. and is requested to be withheld from public disclosure in accordance with 10 CFR 9.17(a)(4) and 10 CFR 2.390(a)(4). An affidavit attesting to the proprietary nature of the information is provided in Attachment 2.

There are no commitments contained in this submittal.

If you have any questions or require additional information, please contact Mr. Thomas Szymanski at (804) 273-3065.

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Page 3 of 4 Sincerely, L. N. Hartz Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by L. N. Hartz, who is Vice President - Nuclear Support Services, of Virginia Electric and Power Company. She has affirmed before me that she is duly authorized to execute and file the foregoing documernt on behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this day of 41)) (.A, 2011.

Ginger Lynn Rutherfbrd My Commission Expires: 4'O ______

NOTARY PUBLIC Commonwealth of Virginia Reg. # 310847 My Commission Expires 4/30/2015 N ry Public Commitments made in this letter:

1. None Attachments:

1. Exemption Request

2. Transnuclear, Inc. Calculation No. 10494-174, Effect of the Reversed Loading Patterns on the Thermal Performance of 32PTH DSC with Affidavit attesting to proprietary nature of Calculation No. 10494-174 and request for withholding from public disclosure cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Page 4 of 4 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. R. E. Martin NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Attachment 1 Exemption Request Virginia Electric and Power Company I (Dominion)

North Anna Power Station Units 1 and 2

Serial No.11-262 Docket Nos.i50-338/339, 72-56 Attachment 1 Request for Exemption from the Provisions of 10 CFR 72.212(b)(3) and (b)(1 1) to Allow the Continued Storage of NUHOMS HD DSC Loaded to Incorrect Heat Load Limits at NAPS Table of Contents 1.0 Request for Exemption .................................................. ...... ....... 2 2.0 Background .......................... , ................................................. . 2, 3.0 Technical Considerations ............................................ ........ 3 4.0 Regulatory Considerations................................................... 4 5.0 Summary .......................... ....................................... . 5 6.0 References-.............................. ................................................. 5 Page 1 of 13

Serial No.'11-262 Docket Nos. 50-338/339, 72-56 Request for Exemption from the Provisions of 10 CFR 72.212(b)(3) and (b)(11) to Allow the"Continued Storage of NUHOMS HD DSC Loaded to Incorrect Heat Load Limits at NAPS 1.0 Request for Exemption Pursuant to 10 CFR 72.7, Dominion requests a one-time exemption from the requirements of 10 CFR 72.212(b)(3) and (b)(1 1) for Transnuclear, Inc. NUHOMS HD 32PTH DSCs with serial numbers DOM-32PTH-004-C, -005-C, -007-C, -010-C, -013-C,

-01 9-C and GBC-32PTH-01 1-C due to a non-compliance with the terms and conditions of the Transnuclear, Inc. Certificate of Compliance (CofC) 1030, Amendment 0, at the time of cask loading. The regulations require, in part, compliance to the terms and conditions of CofC 1030. Contrary to this requirement, these seven DSCs were not loaded in compliance with CofC 1030, Amendment 0. The 32PTH DSC is designed for zoned loading with respect to decay heat. The four center locations are divided into an upper Zone lb and a lower Zone 1a with the lower Zone 1a locations allowing a greater decay heat than the upper Zone 1b locations. The upper and lower orientation of the Zone 1b and 1a locations were reversed when preparing the DSC loading maps for the affected DSCs. As a result of this error, twelve fuel assemblies were placed in DSC locations where their decay heat at the time of loading slightly exceeded the Functional and Operating Limits established by CofC 1030, Amendment 0 Technical Specification Section 2.1. The twelve fuel assemblies are distributed over the seven DSCs identified above.

2.0 Background

The Transnuclear, Inc., NUHOMS HD 32PTH storage system, utilizes a dry shielded canister (DSC), designed to hold 32 spent fuel assemblies for independent spent fuel storage installation (ISFSI) deployment., The system commonly referred to as the NUHOMS HD 32PTH DSC or 32PTH DSC is listed in 10 CFR 72.214 as Certificate Number 1030. This system is currently installed and in use at the North Anna Power Station under a general license. During an internal review of historical NAPS NUHOMS HD 32PTH System ISFSI Fuel Certifications on March 24, 2011, Dominion discovered that due to a miss-orientation of the Zone la and Zone lb locations on the DSC loading maps, twelve fuel assemblies distributed over seven DSCs had been loaded in a manner inconsistent with the CofC for the NUHOMS HD 32PTH storage system and exceeded the decay heat limit for their storage location (Figures 1 through 7).

Upon discovery of the condition, the actions contained in Appendix A, Section 2.2 of CofC 1030, Functional and Operating Limits Violations, were initiated. The affected fuel and DSCs were verified to be in a safe condition, the NRC Operations center was notified of the event within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Reference 1) and a 30-day special report was sent to the NRC (Reference 2).

Page 2 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 The maximum decay heat of the twelve NAPS affected fuel assemblies at the time of loading was 0.859 kW which exceeded the specific location limit of 0.8 kW by 59 watts.

The twelve affected fuel assemblies have been in storage for a minimum of 1.3 years and with the exception of one fuel assembly now meet their DSC location specific decay heat limit.

No Technical Specifications (TS) changes for North Anna Units 1 and 2 are required as this exemption request is only to be applied to the seven DSCs identified and TS compliance is restored as of 07/31/11.

3.0 Technical Considerations Upon discovery, an extent of condition review was performed on North Anna DSCs. It was verified that the as-loaded configurations were below the total heat load limit for the DSC and the combined Zone 1a and Zone lb- heat load limit at the time of loading.

Only the decay heat limit for the individual fuel cell was exceeded at the time of loading for the twelve fuel assemblies distributed over the seven affected DSCs. The decay heat for all but one of the twelve affgcted assemblies currently meets the decay heat limit for their location within the DSC due to the time they have been in storage. Fuel assembly 2B2 in DOM-32PTH-DSC-004-C was determined to be seven watts above its location limit as of the date of discovery (03/24/11). However fuel assembly 2B2's decay heat will meet the location limit of 800 watts after 07/31/11 (Table 1).

Transnuclear, Inc. has performed a therrmal analysis which conservatively bounds the as-loaded configurations of the affected DSCs (Attachment 2). This evaluation was performed consistent with the methods and assumptions used for the 32PTH DSC thermal analysis provided in the NUHOMS HD UFSAR. The evaluation conservatively assumed fuel assembly decay heat loads consistent with the UFSAR design basis loading pattern configuration that achieves the maximum fuel clad temperature results, with the exception of the Zone 1b locations. The decay heat for the Zone 1b locations was increased to 0.86 kW to bound the as-loaded (maximum 0.859 kW) heat loads of the Zone lb locations. This analyzed configuration bounds the as-loaded decay heat conditions for the affected DSCs and conservatively increases the total DSC decay heat to greater than the current design basis analysis decay heat limit. Additionally this results in a combined Zone 1a and 1b total decay heat load greater than the allowable decay heat load for this region. Consistent with the NUHOMS HD UFSAR, the evaluation assumes -an ambient temperature of 115 0F consistent with off-normal storage conditions for determining the maximum fuel cladding and component temperatures. This evaluation concludes the fuel cladding temperatures did not exceed the fuel cladding temperatUre design limit of 4000C (752 0 F) for storage or transfer conditions. Further it shows that the DSC fuel compartment and support rail temperatures were bounded by those used in the design basis analysis, indicating there Page 3 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 is no impact on the current design basis structural evaluation of the DSC basket due to the loading error. The evaluation also concludes that the maximum DSC internal pressure remained below the design limit for the as-loaded configurations.

The-design basis shielding analysis assumed a DSC loading of 32 assemblies, having source terms applicable to assemblies generating 1.5 kW of decay heat (Reference 3).

As the Technical Specifications restrict the number of actual assemblies that can have a decay heat of 1.5 kW to eight, this significantly bounds the as-loaded DSCs providing assurance the design basis shielding analysis remains bounding.

Reactivity parameters for the fuel assemblies or DSCs were not affected due to the loading error. The reactivity parameters of the fuel at the time, of loading met Technical Specification requirements as verified in the respective loading certification documents for each DSC.

The seven affected DSCs are currently considered operable and performing their intended safety functions with associated surveillance parameters within acceptance limits.

4.0 Regulatory Considerations The specific requirements for granting exemptions to 10 CFR Part 72 licensing requirements are set forth in 10 CFR 72.7, Specific Exemptions, which reads as follows:

"The Commission may, upon application by any interested person or upon its own initiative, grantsuch exemptions from the requirementsof the regulations in this partas it determines are authorized bylaw and will not endangerlife or property or the common defense and security and are otherwise in the public interest." Dominion has determined that an exemption to 10 CFR 72.212(b)(3) and (b)(1 1) is necessary to allow continued storage of spent fuel assemblies in NAPS ISFSI DSCs DOM-32PTH-004-C, -005-C, -

007-C, -010-C, -013-C, -019-C and GBC-32PTH-01 1-C due to non-compliance with the terms and conditions of CofC 1030, Amendment 0, at the time of loading. Dominion's evaluation and Transnuclear, Inc.'s thermal analysis have determined that the affected DSCs remain bounded by the system's design basis limits.

The decay heat of all but one fuel assembly in the affected DSCs has decreased to within the CofC limits for the location, and the remaining assembly's decay heat will be below the CoC limit by July 31, 2011. However, loading fuel assemblies outside of location specific, heat load CofC limits is not allowed, and therefore, Dominion requests an exemption in order to document the acceptability and safety basis for allowing the affected DSCs to remain loaded in their current configuration. An alternative exists to unload the seven DSCs; however, it is Dominion's position that it would not be prudent to do so. Unloading the DSCs in question would subject station, personnel to unnecessary radiation exposure, generate additional contaminated waste, increase the risk of a possible fuel handling accident, and increase the risk of a possible heavy load Page 4 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 handling accident. Given that the Dominion and Transnuclear, Inc. evaluations performed support that the DSCs as-loaded are in a safe condition, an exemption to allow the continued storage of the seven DSCS in their current configuration is justified and requested.

The requested exemption to continue to store fuel as-loaded in the seven DSCs identified above has low safety significance and will not endanger life and property or the common defense and security. It is also in the public's iynterest to grant an exemption since the small improvement in safety margin achieved by unloading the affected -DSCs is not commensurate with the increased dose to station workers, increased risk of contamination, and increased risk of both a possible fuel handling accident and a possible heavy load handling accident during the unloading. Dominion considers that the requirements to grant an exemption pursuant to 10 CFR 72.7. have been met and that an exemption is justified.

5.0 Summary Dominion requests a one-time exemption from the requirements of 10 CFR 72.212(b)(3) and (b)(11) for Transnuclear, Inc. NUHOMS HD 32PTH DSCs stored at NAPS with serial numbers DOM-32PTH-004-C, -005-C, -007-C, -010-C, -01 3-C, -01 9-C and GBC-32PTH-01 1-C due to their non-compliance with the terms and conditions of CofC 1030, Amendment 0, at the time of loading. The regulations require, in part, compliance with the applicable CofC. Contrary to this requirement, seven DSCs located at NAPS were not load-ad in compliance with CofC 1030, Amendment 0, in that a total of twelve fuel assemblies distributed over the seven DSCs were loaded with a decay heat slightiy in excess of that allowed for their storage location in the DSC. Dominion and Transnuclear, Inc. evaluations have determined the integrity of the seven DSCs affected and the twelve fuel assemblies involved was not compromised due to the misloading.

This one-time exemption will not endanger life or property or the common defense and security and are in the public interest and meet the intent of 10 CFR 72.7.

6.0 References

1. Reactor Plant Event Notification Worksheet, EN 46697, 03/24/11

2. Special Report on NUHOMS Dry Shielded Canisters Loaded to Incorrect Heat Load Limits, Serial No.11-236, 04/25/11

3. "Safety Analysis Report for the NUHOMS HD Horizontal Modular Storage System for Irradiated Nuclear Fuel", Transnuclear, Inc.

4. NUHOMS HD Certificate of Compliance No. 1030, Amendment 0 Page 5 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 1 DSC ID: DOM-32PTH-004-C Decay Heat at Time of Loading 3 4 11 2 3 4 J42 2B4 2A3 2A2 881 804 786 805 1100 1500 1500 1100 Z2 Z3 Z3 Z2 5 6 7 8 9 10 J27 1B8 2B0 0B7 3P0 0B3 859 825 821 822 914 829 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 12o:* ý4 15 16 2S4 J22 1A0 , 2B2:. J32 2S3 1093 830 <:331;> 845 635 1075 1500 1100 800* 803 1100 1500 Z3 Z2______ 1715 22 M3 17 18 19 20 21 22 IS6 J37 W31 W51 J28 1S9 1091 823 734 666 844 1077 1500 1100 1050 1050 1100 1500 Z3 Z2 ZlA ZIA Z2 Z3 23 24 25 26 27 28 J06 J18 3P2 J15 J34 0B8 860 845 918 846 848 868 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 jZ2 Z2 Z2 29 30 31 32 J39 2S2 1 F3 J46 871 1085 1097 879 1100 1500 1500 1100 Z2 Z3 Z3 Z2 Z2 Z2 Cell No.

F/A ID Total Decay Heat for DSC = 28,204 Watts Limit = 34,800 Watts Decay Heat (Watts) Total Decay Heat for Combined Zones lb and la = 3,076 Wafts Limit = 3200 Watts Zone Limit (Waits)

Zone ID Page 6 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 2 DSC ID: DOM-32PTH-005-C Decay Heat at Time of Loading 4

2 I1 2 3 4 2A4 4A1 ,OP2 OBS 845 808 995 833 1100 1500 1500 1100 Z2 Z3 M3 Z2 5 6 7 8 9 10 0B6 2P0 1B1 1B2 1P5 1B3 858 1007 853 848 991 854 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 11 12 13 14 15 16 0F8 1A5 3A9 03B2 1P7 0F3 1191 856 776 1006 1153 1500 1100 800 800. 1100 1500 ZM Z2 ZIB ZiB'.,'.":, Z2 Z3 17 18 19 20 21 22 0F7 0P7 4A0 3A3 2P2 0F4 1197 1011 762 772 1013 1148 1500 1100 1050 1050 1100 1500 Z3 Z2 ZlA Z1A Z2 Z3 23 24 25 26 27 28 2P4 0P9 2P8 2P6 1 P4 OPi 1005 1009 1026 1010 1016 1007 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 29 30 31 32 2P1 0F6 0F5 1P0 991 1240 1247 983 1100 1500 1500 1100 Z2 Z3 Z3 Z2 Cell No.

F/A ID Total Decay Heat for DSC = 31,167 Watts Limit = 34,800 Watts Decay Heat (Wafts) Total Decay Heat for Combined Zones Ilb and 1a = 3,169 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 7 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 3 DSC ID: DOM-32PTH-007-C Decay Heat at Time of Loading 4

3 1 22 3 4 Y03 3N3 4N6 Y04 762 1228 1189 754 1100 1500 1500 1100 Z2 Z3 Z3 Z2 5 6 7 8 9 10 4L3 3N2 4NO 6L1 5N1 5LI 859 875 889 842 876 844 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 112i1415 16 5NO 51-2 4L9 51-9 51-O 4N4 1208 967 3482901196 1500 1100 8 800 1100 1500 Z3 Z2 Z1iB  ;.IB AZ2 Z3 17 18 19 20 21 22 5N6 5L5 Yol Y05 4L4 6NO 11189 962 757 733 954 1244 1500 1100 1050 1050 1100 1500 Z3 Z2 ZIA Z1A Z2 Z3 23 24 25 26 27 28 3N5 3N1 4L1 5L8 5L6 3N7 871 895 837 936 918 "895 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 29 30 31 32 4N3 5N8 4N1 5N3 881 1208 1191 884 1100 1500 1500 1100 Z2 Z3 Z3 Z2 Z2 Z2 Z3 Cell No.

F/A ID Total Decay Heat for DSC = 30,480 Watts Limit = 34,800 Watts Decay Heat (Watts) Total Decay Heat for Combined Zones l b and la = 3,176 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 8 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 4 DSC ID: DOM-32PTH-010-C Decay Heat at Time of Loading I 1~243 3 4 K49 K53 K57 K48 748 732 739 746 1100 1500 1500 1100 Z2 Z3 Z3 Z2 5 6 7 8 9 10 K43 K46 K45 K55 K51 K38 758 755 748 751 758 760 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 11 12 3 1'4 15 16 K26 K29 K17 .32 K28 K23 792 788 .809 807 805 802 1500 1100 800 * ,800 1100 1500 Z3 Z2 ZiB: ZiB KZ2 Z3 17 18 19 20 21 22 K15 K30 K34 K54 K27 K18 800 794 783 758 804 771 1500 1100 1050 1050 1100 1500 Z3 Z2 ZIA Z1A Z2 Z3 23 24 25 26 27 28 K37 K36 K62 K24 K39 K40 747 775 763 772 770 767 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 jZ2 Z2 Z2 29 30 31 32 K50 K14 K21 K44 761 777 786 766 1100 1500 1500 1100 Z2 ZM Z3 Z2 Cell No.

F/A ID Total Decay Heat for DSC = 24,689 Wafts Limit = 34,800 Watts Decay Heat (Wafts) Total Decay Heat for Combined Zones l b and 1a = 3,156 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 9 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 5 DSC ID: GBC-32PTH-01 1-C Decay Heat at Time of Loading 3 4 11 2 2 3 4 J45 4A8 5A0 J47 885 783 780 882 1100 1500 1500 1100 Z2 Z3 Z3 Z2 5 6 7 8 9 10 J51 0D4 2D4 2D5 0D7 1 B5 890 859 845 853 844 884 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 11 121 _15 16 1F2 2D1 1136, -< 3 11D6 0F9 1232 856 4 ` 33.847 .1226 1500 `"00 8 1100 1500 M3 Z2 ___., __, ,._ __?': Z2 Z3 17 18 19 20 21 22 1F4 1D3 4A4 4A6 0D8 IFO 1183 851 742 762 852 1180 1500 1100 1050 1050 1100 1500 Z3 Z2 ZIA ZlA Z2 Z3 23 24 25 26 27 28 J52 2B3 3D9 2D9 2B1 11B4 873 883 970 953 835 844 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 29 30 31 32 1BO 1F5 2S6 J58 899 1221 1237 899 1100 1500 1500 1100 Z2 Z3 Z3 Z2 Cell No.

F/A ID Total Decay Heat for DSC = 29,528' Wafts Limit = 34,800 Watts Decay Heat (Watts) Total Decay Heat for Combined Zones lb and 1a = 3,180 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 10 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 6 DSC ID: DOM-32PTH-013-C Decay Heat at Time of Loading 3 4 I1 2 2 3 4 GN4 6N1 1 A7 ON11 839 828 788 839 1100 1500 1500 Z2 Z3 ZM Z2 5 6 7 8 9 10 0N4 6N3 0N8 0N6 6N2 1N5 863 837 835 836 837 375 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 11 12 13 14'  ;;"' ' 15 16 2F3 3D3 2A1 IN9, 2N1 2F0 1126 938 795 , 85i.< 840 1044 1500 1100 800 SO 100 080 1500 M3 Z2 Z1iB Z1B ~ 1Z2 Z3 17 18 19 20 21 22 2F4 .2N2 W34 W44 3D5 2F2 1115 849 744 743 912 1063 1500 1100 1050 1050 1100 1500 Z3 Z2 ZIA ZlA Z2 Z3 23 24 25 26 27 28 1N3 1N7' 1N4 0N7 2N3 ON5 864 851 860 861 862 866 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 29 30 31 32 2N6 2F1 1 F9 2N7 869 1110 1102 873 1100 1500 1500 1100 Z2 Z3 Z3 Z2 £ LZ2 Cell No.

F/A ID Total Decay Heat for DSC = 18,515 Watts Limit = 34,800 Watts Decay Heat (Watts) Total Decay Heat for Combined Zones lb and la = 3,133 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 11 of 13

I~ "'4 Serial No.11-262 Docket Nos. 50-338/339, 72-56 Figure 7 DSC ID: DOM-32PTH-019-C Decay Heat at Time of Loading 12 3 4 582 W19 W22 487 811 641 709 812 1100 1500 1500 1100 Z2 Z1 Z3 Z2 5 6 7 8 9 10 0E7 481 2B6 380 3B5 0E8 937 816 816 816 779 963 1100 1100 1100 1100 1100 1100 Z2 Z2 Z2 Z2 Z2 Z2 1 12 14 15 16 1G2 ... 435. 1E2 OG5 1268 8956 959 1260 1500 1100 800 1100 1500 M Z2 71  :'1*B Z3

______Z2 17 is 19 20 21 22 0G4 2C6, W62 X09 0C9 2G4 1263 895 739 711 909 1260 1500 1100 1050 1050 1100 1500 Z3 Z2 ZIA ZIA Z2 Z3 23 24 25 26 27 28.

0E4 2C5 lC9 0E2 0E3 1E5 939 911 915 937 937 946 1100 - 1100 1100 1100 1100 1100 Z2______Z2 iZ2 Z2 Z2 Z2 29 30 31 32 OEl 0G7 1GI IE3 947 1263 1262 949 1100 1500 1500 1100 Z2 Z3 Z3 Z2 Cell No.

F/A ID Total Decay Heat for DSC = 29,996 Watts Limit = 34,800 Watts Decay Heat (Watts) Total Decay Heat for Combined Zones l b and 1a = 3,120 Watts Limit = 3200 Watts Zone Limit (Watts)

Zone ID Page 12 of 13

Serial No.11-262 Docket Nos. 50-338/339, 72-56 Table 1 Fuel Assembly Decay Heat Verification Decay Heat at Date of Loading, Burnup For Enrichment Last Cooling Decay Assembly Certification For Irradiation Loading Time Heat North Anna ID (GWD/MTU) Certification Date Date (Years) (Watts)'

DSC 004 1AO 51.219 3.96 09/09/94 07/1:3/09 14.8 831 2B2 50.363 3.96 02/11/96 07/13/09 13.4 845 DSC 005 0B2 49.605 3.95 02/11/96 06/02/08 12.3 859 DSC 007 4L9 48.201 4.16 09/08/96 03/17/08 11.5 844 5L9 48.143 4.16 09/08/96 03/17/08 11.5 842 DSC 010 K17 50.200 3.74 01/04/93 03/03/08 15.2 809 K32 50.170 3.77 01/04/93 03/03/08 15.2 807 DSC 011 1B6 48.985 3.95 02/11/96 06/09/08 12.3 844 1B9 48.528 3.95 02/11/96 06/09/08 12.3 833 DSC 013 1N9 47.863 3.96 04/05/98 07/13/0,9 1.1.3 851 DSC 019 388 48.661 4.13- 05/11/97 07/13/09 12.2 835 4B5 48.699 4.15 05/11/97 07/13/09 12.2 835 Decay Heat at Date of Discovery Burnup For Enrichment Last Cooling *Decay Assembly Certification For Irradiation Date of Time Heat North Anna ID (GWD/MTU) Certification Date Discovery (Years) (Watts)1 DSC 004 1AO 51.219 3.96 09/09/94 03/24/11 16.5 800 2B2 50.363 3.96 02/11/96 03/24/11 15.1 807 DSC 005 0B2 49.605 3.95 02/11/96 03/24/11 15.1 791 DSC 007 4L9 48.201 *4.16 09/08/96 03/24/11 - 14.5 766 5L9 48.143 4.16 09/08/96 03/24/11 14.5 765 DSC 010 K17 50.200 3.74 01/04/93 03/24/11 18.2 " 760 K32 50.170! 3.77 01/04/93 03/24/11 18.2 758 DSC 011 1836 48.985 3.95 02/11/96 03/24/11 15.1 778 1839 48.528 3.95 02/11/96 03/24/11 15.1 768 DSC 013 1 N9 47.863, 3.96 04/05/98 03/24/11 1 13.0 800 DSC 019 388 48.661 4.13 05/11/97 .03/24/11 13.9 791 4853 48.699 4.15 05/11/97 03/24/11 13.9 791 Projected Date at Which Decay Heat Meets Limit Burnup For Enrichment Last Cooling Decay Assembly Certification For Irradiation Projected Time Heat North Anna ID (GWD/MTU) Certification Date Date (Years) (Watts)'

DSC 004 1 282 50.363 3.96 02/11/96 07/31/11 15.5 800

1. Decay Heat determined using CoC 1030, Amendment 0 Technical Specification Table 4.

Page 13 of 13

Serial No.,1 1-262 Docket Nos. 50-338/339, 72-56 Attachment 2 Affidavit pursuant to 10 CFR 2.390(4) Request for Withholding from Public Disclosure Transnuclear, Inc. Calculation No. 10494-174, Effect of the Reversed Loading Patterns on the Thermal Performance of 32PTH DSC Virginia Electric and Power Company (Dominion)

North Anna Power Station Units 1 and 2

A AR EVA Mr. Cary Laroe E-31109 Supervisor, Nuclear Engineering TN Project 10494 Dominion, Nuclear Analysis and Fuel June 21, 2011 500 Dominion Blvd Glen Allen, VA 23060

Subject:

Affidavit for TN Calculation 10494-174

Reference:

1. Dominion Master Services Agreement: 46017934

2. Dominion Release No.: 7010848

3. TN Calculation 10494-174 Attachments: Affidavit Pursuant to 10 CFR 2.390 Dear Mr. Laroe Please find attached an Affidavit concerning the proprietary nature of TN Calculation 10494-174 (Ref 3). TN recognizes that Dominion Resources will be using Ref 3 as an appendix to the following exemption letter:

For Surry:

Letter Serial No.11-251 Virginia Electric and Power Company Surry Power Station Units 1 and 2 Exemption Request for NUHOMS HD Dry Shielded Canisters Loaded to Incorrect Heat Load Limits For North Anna:

Letter Serial No.11-262 Virginia Electric and Power Company North Anna Power Station Units 1 and 2 Exemption Request for NUHOMS HD Dry Shielded Canisters Loaded to Incorrect Heat Load Limits Please attach the affidavit to the cover of the calculation (Ref 3) whenever submitting the document to the NRC as part of the aforementioned letter(s). Reference 3 is intended for Dominion use and is not intended for public dissemination.

If you have any questions, please feel free to contact me at (410) 910-6949 or Ken.Boone@AREVA.com.

Best Regards, Kenneth R. Boone Sr. Project Manger Cc: R. Robins TRANSNUCLEAR INC.

71 35 Minstrel Way Suite 300 - Columbia, MD 21045 Tel: 410-910-6900 Fax: 410-910-6902 www.transnuclear.com

AFFIDAVIT PURSUANT TO 10 CFR 2.390 Transnuclear, Inc.

State of Maryland.

County of Howard I, Jayant Bondre, depose and say that I am a Vice President of Transnuclear, Inc., duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.3 90 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is listed below:

TN Calculation 10494-174 Rev 0: Effect of Reversed Loading Patterns on the thermal Performance of 32PTH DSC.

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Transnuclear, Inc. in designating information as 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 flom public disclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves details and analyses related to Transnuclear, Inc.'s design for the NUHOMS 32PTH Dry Shielded Canister, which are owned and have been held in confidence by Transnuclear, Inc.

2) The information is of a type customarily held in confidence by Transnuclear, Inc. and not customarily disclosed to the public. Transnuclear, 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 Transnuclear, Inc. because the information consists of details and analyses related to Transnuclear, Inc.'s design for the NUHOMS 32PTH Dry Shielded Canister, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Transnuclear, Inc., take marketing or other actions to improve their product's position or impair the position of Transnuclear, Inc.'s product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

J yant Bondre Vice President, Transnuclear, Inc.

v ,.,,. , ,

Subscribed and sworn to me before this 2 1t11day of June, 2011. i4.

Noary Public

...... ". WOP y.PublicLauren McKee Nod NOTARY PUBLIC 4, My Commission Expires Adne Arufdel County, Maryland -i, -*.

My Commission Expires 2/12/2015 Aldso

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