ML22062B028

and Independent Spent Fuel Storage Installation (Isfsi), Response to Request for Supplemental Information Regarding Request for Exemption from 10 CFR 72.106(b)

ML22062B028
Person / Time
Site:	San Onofre
Issue date:	02/28/2022
From:	Bates A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML22062B028 (4)

Text

SOUTHERN CALIFORNIA Al Bates EDISON~ Manager, Nuclear Regulatory Affairs

& Technical Assistant to the CNO An EDISON lNTERNATlONAJf!9 Company Proprietary Information - Withhold from Public Disclosure in accordance with 10CFR2.390 Decontrolled when separated from Enclosures 3, 4, and 5.

10 CFR 72.7 10 CFR 72.106(b)

February 28, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Docket No.72-041 Response to Request for Supplemental Information regarding Request for Exemption from 10 CFR 72.106(b)

San Onofre Nuclear Generating Station (SONGS)

Independent Spent Fuel Storage Installation (ISFSI)

References:

1) Letter from A. Bates (SCE) to Document Control Desk (NRC) dated December 16, 2021;

Subject:

Docket No.72-041, Request for Exemption from 10 CFR 72.106(b), San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) (ADAMS Accession No. ML21355A245)

2) Letter from A. M. Snyder (NRC) to A. Bates (SCE) dated January 26, 2022;

Subject:

San Onofre Nuclear Generating Station, Application Acceptance Review Request for Supplemental Information: Proposed Exemption from Title 10 of the Code of Federal Regulations Section 72.106(b ), Independent Spent Fuel Installation Controlled Area Boundary (ADAMS Accession No. ML22018A313)

Dear Sir or Madam:

By Reference 1, Southern California Edison (SCE) submitted a request for NRC approval of an exemption from a requirement of 10 CFR 72.106(b) for the San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI). The requirement for which exemption was requested was that the minimum distance from an ISFSI to the ISFSI Controlled Area Boundary (CAB) be at least 100 meters (the distance currently being used).

1 By Reference 2, the NRC issue d a Request for Supplementary Information resulting fr~m the acceptance review of Reference 1. This letter provides SCE's response to Reference 2.

Proprietary Information - Withhold from Public Disclosure in accordance with 10CFR2.390 Decontrolled when separated from Enclosures 3, 4, and 5. /V /.-/___ss Z Cf:?

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The NRC's Request for Supplemental Information consisted of two questions. The first question, RSl-10-1, requested storage dose calculations for the Transnuclear (TN) fuel storage system, the storage of Greater-than-Class-C (GTCC) waste in the ISFSI, and the Holtec fuel storage system. The calculation that performs these three dose analyses is provided in . The calculation in Enclosure 1 also refers to various other documents that would be necessary for the NRC to perform confirmatory dose calculations. Enclosures 3 through 5 consist of the TN-related supporting calculations.

Due to the proprietary nature of the calculations in Enclosures 3 through 5, SCE is requesting withholding of those Enclosures from public disclosure in accordance with 10 CFR 2.390. An affidavit for withholding these documents is provided in Enclosure 2.

The NRC's second question, RSl-10-2, requested submittal of References 6 through 9 of the Holtec calculation Hl-2210810, "SONGS HI-TRAC VW Accident Conditions Dose vs. Distance."

These references, along with a Holtec report in response to RSl-10, will be provided directly from Holtec under a separate cover letter.

There are no commitments in this letter or the enclosure.

If you have any questions, please contact Mr. Al Bates c:it (949) 368-7024.

Sincerely, M~

Enclosures:

1. SCE Calculation SO1-207-1-C116, Revision 2, Modified Control Area Boundary ISFSI Dose Calculation

2. TN Affidavit for withholding Enclosures 3 through 5 from public disclosure

3. TN Calculation SCE-23-0508, San Onofre Independent Spent Fuel Storage Installation (ISFSI) Dose Rate Calculation

4. TN Calculation SCE-01.0506, Revision 1, Dose Rate Calculations for SONGS Unit-1 Greater Than Class C (GTCC) Waste Container

5. TN Calculation 21933-0503, SONGS Off-Site Dose Calculation cc: S. A Morris, Regional Administrator, NRC Region IV A M. Snyder, NRC Project Manager, SONGS Units 1, 2 and 3

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ENCLOSURE 2 TN Affidavit for Withholding Enclosures 3 through 5 from Public Disclosure

TN Americas LLC Affidavit AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC .. )

State of Maryland *" ) * * *ss:

County of Howard )

I, Prakash Narayanan, depose and say that I am the Chief Technical Officer of TN Americas LLC, 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 paragraph immediately below. I am submitting this affidavit in conformance with the provisions of JO CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is contained in the letter as listed below:

• TN Calculation 21933-0503, Revision 1, SONGS Off-Site Dose Calculation

• TN Calculation SCE-01.0506, Revision l, Dose Rate Calculations for SONGS Unit-I Greater Than Class C (GTCC)

Waste Container

• TN Calculation SCE-23.0508, Revision 0, "San Onofre Independent Spent Fuel Storage Installation (fSFSI) Dose Rate Calculation These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating infonnation 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 dete1mining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves calculations in their entirety that support a response to a request for supplemental information related to dose calculations for the Standardized Advanced NUHOMS dry spent fuel storage system, which are owned and have been held in confidence by TN Americas LLC.

2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for detem1ining 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 TN Americas LLC, because the information consists of analysis methodology associated with the design of dry spent fuel storage systems, 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 TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC Subscribed and sworn before me this 15 th day of February, 2022. KHYNESYA TAYLOR Notary Public Howard County N ~ Maryland

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