ML20065F917

Provides Addl Info to Re Cooperative Evaluation Program W/Nrc,Per NRC 820720 Request.Program Provides Capability for Rapid Response to NRC Concerns & Supports near-term Approval of Item II.K.3.30

ML20065F917
Person / Time
Site:	Midland
Issue date:	09/10/1982
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TASK-2.K.3.30, TASK-2.K.3.31, TASK-TM 18819, NUDOCS 8210010437
Download: ML20065F917 (6)

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Jemas w cook j Vnce Persident - ProjectL Engsmerving and Construction +

Generei oNic es. 1945 vroet PerneH Road, Jackson. MI 49201 + (5171788 o453 -

' September 10, 1982 I

1. ~ O C TED cargy,yy ,

CCItified Iy

~,.w Harold R Denton, Director  !

Office of Nuclear Reactor Regulation  !

i Division of Licensing '

US Suelear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 EVALUATION PROGRAM FOR B&W TEST VERIFICATION FILE: 0926.2 SERIAL: 18819 This letter compliments the proposal made in our letter, Serial 18441 of j

August 12, 1982, by providing the details of a cooperative evaluation program i

' with the NRC as requested in the July 20, 1982 meeting. The cooperative I evaluation program is designed to satisfy the following objectives.

l o Provide the capability for rapid response to Staff concerns. -

o Support the near term approval by the Staff during their evaluation of ,

our SB LOCA Methods Program (II.K.3.30). Approval of this program will  !

then allow for a timely response to Item II.K.3.31.  !

o Expand the test data base for SB LGCA phenomena by providing two phase IST data to benchmark calculational tools used to predict long tem plant performance following a SB LOCA.

o Improve the Staff's knowledge of the B&W plant design and increase their confidence in our prediction of plant performance under various transients.

dh The cooperative evaluation program outlined in the attachment will lead to the development of research priorities and the determination of the most cost-

.. effective method of satisfying those priorities. This is responsive to the Staff request of July 20, 1982 as we understand it.

The near term test data from GERDA and the long term data from SitI-2 will be evaluated to verify scaling assumptions and predicted loop performance for that facility. The program will also provide a comprehensive data base for oc0882-1258a131 8210010437 820910 PDR ADOCK 05000329 A PF

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8 2 code benchmarking by the Staff and the Owners. Such codes should then provide the Staff with more confidence in the analytically predicted behavior of B&W plants.

The GERDA test data would be made available on a proprietary basis to the Staff for their code benchmarking efforts. The data from SRI-2 will be in the public domain.

This proposed program is a prerequisite to further analysis and testing and will provide input into the design, modification, or confirmation of a test facility should the eval'uation dictate such a need.

The success of this cooperative program is dependent on all parties striving to reach a common point. The success of this effort, thus is dependent on the commitment of the necessary resources. As a participating B&W Owner, we will obtain the integral systems test data from the German GERDA facility and SRI-2. We expect that the NRC Staff will support the issuance of an SER which will close out Item II.K.3.30, and allow II.K.3.31 work on the operating plants and those plants to be licensed by the NRC Staff to proceed without further diversion of Owner and Staff resources. As stated above, we would offer to provide GERDA data to the NRC Staff at no cost for their use in benchmarking TRAC and RELAP 5 provided that the NRC Staff provide their models of a B&W plant to B&W for review and QA. This review and QA effort by B&W is expected to be funded by the NRC.

We have selected this approach because it provides near term IST test results from an existing facility, representative of the B&W design, as well as longer term two loop data from SRI-2 which will also reflect the B&W design. The program provides an expanded base of knowledge about the B&W design which will aid the Staff in future regulatory actions and will prove invaluable in the decision making process regarding future testing and test facilities.

We feel that testing must be technically justified and that it must be supported by a cost benefit analysis. Changes in the commitments in this letter would have to be justified before being accepted by the B&W Owners Group.

We have initiated contact with H Sullivan of the NRC Staff and established a first meeting date of September 16, 1982. To facilitate the initial steps of the program, we request that the NRC Staff provide the preliminary cost benefit analysis performed by their consultants for various IST alternatives at that time.

We are reviewing GERDA test specifications and have initiated financial arrangements with the Germans. EPRI has provided a test plan for SRI-2 for your review. We are willing to participate in a joint panel with the NRC as outlined in this letter. This program is one we can support both financially and technically and we invite the NRC to join us in this effort. Your timely concurrence is needed because of the near term financial commitment involved.

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i If you have any questions, please contact Mr Robert Dieterich, Chairman of the B&W Cuners Analysis Subco=ittee or Mr Louis Gibson of our staff.

i JWC'/LSG/fas CC RJCook,-Midland Resident Inspector -

RHernan, US NRC DBMiller. Midland Construction (3) i f

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t ATTACHMENT #1 TEST ADVISORY GROUP v

The Test Advisory Group (TAG) will consist of members from the NRC and Industry whose job will be to evaluate test data which supports the B&W designed NSS and to prepare a cost benefit analysis of any identified future testing needs.

An orderly way to proceed would be to: ,

4 Identify all relevant technical phenomenon in codes used to analyze the B&W system and list all current testing support for these phenomenon.

4 Evaluate GERDA and SRI-2 as sources of additional benchmarks for other phenomenon.

8 Perform a cost benefit analysis of identified tests and test facilities to address residual phenomenon.

The general approach proposed by the B&W Owners Group is to take advantage of near term available test facilities and test results to decide what if any additional testing is needed.

GERDA will provide data to benchmark relevant phenomenon associated 'with natural circulation, interruption, and refill with an SB LOCA. SRI-2 is planned to provide two 1000 data for investigating loop-to-loop instability and S.G. tube ruptures.

En addition, B&W designed plants will be starting up within the next two years and the Owners plan to evaluate plant testing as a source of useful two loop data.

'The completion of the program oroposed by the Owners will provide a reasonable tech-nical basis for the identification of additional testing needs and will supply useful data to confirm or modify the design of additional test facilities.

! An outline of the B&W Owners approach to the Test Advisory Group is provided for. con-venience of review. A schedule has also been prepared to integrate the activities of the. Test Advisory Group and related support work to be perfonned by the Owners to cul-minate in the preparation of a final report on testing needs to support the B&W designed l

plant.

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OUTLINE FOR TEST ADVISORY GROUP (TAG) WORK Objective: e Evaluate Testing Needs e Develop Cost Benefit of Future Testing s)

1. Members:

e NRRES - Sullivan (Chair) e Reactor System Bra 6ch e B&W Dwners '

Group Analysis Subcommittee e EPRI e B&W

2. Scooe:

e Develop List of Phenomena that Codes Simulate e Identify Benchmark Needs e Evaluate the Acceptability of Current Data ~

e Evaluate the Acceptability of GERDA/ SRI-2/ Plant Testing to Satisfy POI

e. Identify Possible Ways to Fill Residual Testing Needs and Cost Benefit Evaluation panel will not manipulate / control GERDA/ SRI-2 Testing or Code Benchmarking by the Owners.

.3. Products:

e Listing of Phenorena in Codes that Data.Must Support e Phenomena Supported by Current Information e Phenomena Supported by GERDA/ SRI-2/ Plant Testing e Cost Benefit of Facilities to Address Residual Issues

4. Conditions:

e List is Composed of Phenomena, Not Licensing Concerns e Commitment of Resources by all Participating Parties e We Will Provide Data to benchmark TRAC. NRC to Agree to Certify a Deck for B&W Plants to Be Approved by B&W e Reports Must Include All Participants' Positions (i.e. Dissenting Views) l A-2

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. INTEGRATED SCilEDULE FOR TAG AND OWNERS GROUP ACTIVITIES -

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