ML20082H357
| ML20082H357 | |
| Person / Time | |
|---|---|
| Site: | 05200004 |
| Issue date: | 04/13/1995 |
| From: | Quinn J GENERAL ELECTRIC CO. |
| To: | Borchardt R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20046D643 | List: |
| References | |
| MFN-046-95, MFN-46-95, NUDOCS 9504170087 | |
| Download: ML20082H357 (11) | |
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GENuclearEnerpy J. E. Quinn, Prm'ects Manager GeneralElectnc Company
. LMR and SBWR Programs 175 Curtner Avenue, A6C 165 San Jose, CA 95125-1014 '
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[ 408 925-1005 (phone) 408 925-3991 (facsimile).
. April 13,1995 MFN 046-95
.i Docket STN 52-004.
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Document Control Desk...
U. S. Nuclear Regulatory Commission Washington DC 20555 Attention:
Richard W. Borchardt, Director i
Standardization Project Directorate
Subject:
SBWR Test and Analysis Program Description, NEDC-32391P, Revision B - (Proprietary)
Reference:
- 1) MFN 018-95, J. E. Quinn (GE) to R. W. Borchardt (NRC), Approach to a
Achieve Closure ' of Items Related to the GE SBWR TAPD, dated February 14, 1995.
- 2) Memorandum to ' John T. Larkins (ACRS from Dennis; M. Crutchfield (NRC), " Draft Safety Evaluation Report (SER) on the? Adequacy of the?
l Technical Approach to the Testing and Analysis Program'(TAP)'for the
{
Simplified Boiling Water Reactor (SBWR)
Design",.
dated November 25,1994.
- 3) ACRS Thermal. Hydraulic Phenomena Subconunittee - Meetings, -
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. December 15 and 16,1994, and January 10,'1995.
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- 4) NRC/GE TAPD DSER Meeting January 9,1995.-
- 5) 417th ACRS Meeting January 12,1995 This letter transmits Revision B of the SBWR Test and Analysis Program Description (TA'PD) :
report, NEDC-32391P, for your review. This report provides a comprehensive, integrated; plan that addresses the testing and analysis elements needed' for. analysis of.SBWR' l
performance. In particular, this revision of the' document describes the resolution of testing i
related issues identified in Reference 1. GE-NE requests NRC concurrence that the planned tests satisfactorily address the concerns in References 2 through 5, and moreover. provide an adequate basis for TRACG qualification.
Revision B replaces Revision A in total. The changes from Revision A to Revision B are-identified by sidebars in the left-hand margins of the affected pages.' Please dispose of all.
=i copies of Revision A in a manner appropriate for the destruction of proprietary materials,'or' return them to GE Nuclear Energy, Attention: K. T. Schaefer, M/C 781.
l Reference 1 identifies the process and approach being utilized to achieve closure on the issues
. raised'in Reference 2, NRC TAPD Draft Safety Evaluation Report (DSER), and References 3 J
through 5, meetings with the NRC and ACRS. This letter provides an u;xlate (see attached ~
table) to Reference 1 with respect to the resolution status of each act: n item from the j
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MFN 046 Page 2 GE-NRC-ACRS meetings held in December 1994 and January l9' 95. This table _(a) describes each action item, (b) identifies where the resolution for each action item is or will be documented, (c) provides the actual or scheduled date that each resolution was or will be sent to the NRC (if available), and (d) provides the GE Master File Number (MFN) of the letter that transmitted each resolution to the NRC (if available). For the action items resolved in NEDC-32391P, Revision B, the table also lists the'affected (changed) report section(s).
Where applicable, the enclosed Revision B provides resolution to the TAPD action items'that
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could be evaluated within a reasonably short (three month) time period. It is recognized that additional information regarding PIRT and scaling need to be submitted to NRC and ACRS for review. The remaining TAPD action items will be resolved in a future revision (Revision C)-
of NEDC-32391P, which will be submitted to the NRC by August 31,1995.
Beyond resolution of the action items addressed above, Revision.B also includes changes related to updated or newer information, editorial corrections and improvements, and -
additional information provided for completeness.
Please note that NEDC-32391P contains information of the type which GE maintains in confidence and withholds from public disclosure. They have been handled and classified as proprietary to GE as indicated in the attached affidavit.
We hereby request that this mformation be withheld from public disclosure in accordance with - the provisions of 10CFR2.790. Revision B to NEDC-32391P provides sidebars in the right-hand margins to distinguish those parts of the document which are deemed Proprietary to the General Electric Company. Affidavit statements (4)a, (4)b and (4)d are in all cases the reasons for withholding the information marked by lining in the margin.
If you have any questions regarding this report, please contact John Leatherman of our staff on (408) 925-2023.
Sincerely, W
James E. Quinn, Projects Manager LMR and SBWR Programs
Enclosure:
SBWR Test and Analysis Program Description (TAPD),
NEDC-32391P, Revision B cc:
P. A. Boehnert (NRC/ACRS) - [7 copies]
- 1. Catton (ACRS) - [1 copy] ]
S. Q. Ninh (NRC) - [21 copies J.11. Wilson (NRC) - [(1 copy]
List of NRC/ACRS Action items (Reference 1)
Where To Be
- Actual or FN No.
Item Description Documented Scheduled Date (Section # *)
to NRC MSLB outside containment - TRACG analysis. Perform TRACG analysis for this SSAR accident with focus on containment response and PCCS purging.
BDB outside containment -TRACG analysis Perform TRACG analysis of accident.
2 For RPV, clarify timing of events leading to isolation of system. For containment, SSAR focus on PCCS purging.
3 Document TRACG time step determination logic. (Part of item 53)
MODEL Develop chimney technical basis. Develop supporting data for void fraction in 4
large diameter pipes and capability of TRACG to analyze flow distribution in TAPD Rev. C 8/31/95 parallel channels.
5 Document description on chimney technical basis developed in item 4 in TAPD TAPD Rev. C 8/31/95 Develop figure of SBWR/SBWR nodalization similar to Figure 2.1 of NEDE-32178 6
MODEL for reactor vessel and containment 7
Derivation of TRACG conservation equations w/ assumptions. (Part of item 53)
MODEL Details of assumptions and range of applicability for correlations in TRACG (Part 8
MODEL of item 53)
Provide report on separator modeling in TRACG (Sections 4&5 of NUREG/CR-2574, 9
"BWR Refill-Reflood Program Task 4.7 - Model Development TRAC-BWR LETTER 2/25/95 022-95 Component Models")
Document range of separator data vs. range of SBWR conditions during normal 10 QUAL 3/31/96 operation and transients Comparison of TRACG decay heat model (used in transients in conjunction with y
MODEL neutronics model) vs. ANS standard (1979)
Describe SBWR TRACG BOP model used in transient analysis. Justify 12 representation of dynamic components such as pumps by control system APP 3/31/96 elements.
Provide scaling study of CRIEPl tests to demonstrate that appropriate SBWR TAPD Rev. B i
"046-95 parameters are properly scaled (B.4 )
Expand scaling study to include global scaling of entire system.This should TAPD Rev. C 8/31/95 include detailed scahng of interactions between loops and components.
I Extend GIRAFFE scaling study to the late blowdown phase (starting at~10 bar) 14b 4/13/95.
046-95 B.2.6, Att.B2)
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- Tables figures referenced in the noted report sections may have also been modified or added in response to the subject Action item.
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List of NRC/ACRS Action items (Reference 1)
Where To Be Actual or g
N o.
Item Description Documented Scheduled Date (Section # *)
to NRC Develop scaling groups for individual PIRT parameters (ranked High, Medium) and' 15 TAPD Rev. C 8/31/95 compare values of these parameters for SBWR and test facUittes Add description of Main Steam line break to TAPD Section 2.2.1 TAPD Rev. B 16 4/13/95 046-95 Consideration of medium and low phenomena -Include medium ranked 17 phenomena in assessment matrix; low ranked phenomena only in checks for TAPD Rev. C 8/31/95 cxistence of models in TRACG Review best estimate LOCA scenario accounting for equipment availability and TAPD Rev. B 18 4/13/95
'046-95 1
operator actions. Determine if any additional items need to be added to PIRT.
(2.2.1.6 )
es discussed in Sections 4.2 and Appendix C of TAPD t address specif. " * "t.
TAPD Rev. C 8/31/95 19 ic ques ions in DSER in lude vessel / containment interactions as specific highly ranked phenomena in 20 TAPD Rev. C 8/31/95 PIRT 21 Discuss PCCS purge / vent process from phenomenological point of view TAPD Rev. C 8/31/95 22 Separate out SRV air clearing loads as an item in PIRT for containment TAPD Rev. C 8/31/95 Add description of ATWS scenario in Section 2.2.3 and expand Table 2.3-4. For stability, expand Table 2.3-5 PIRT format. Include consideration of bouyancy-23 TAPD Rev. C 0/31/95 driven oscillations during startup at low pressure and power, but with large subcooling.
include discussion of PAR interactions. Add description of performanc g
TAPD Rev. C 8/31/95 characten,stics and flow patterns induced by PARS.
Expand discussion of PIRT tables. Add new Appendix E which willinclude a brief 25 TAPD Rev. C 8/31/95 discussion of each parameter and the basis for its ranking.
Address phases of the transient in Section 3. Add column to Table 3.2-1 to 26 indicate for what transient the phenomena are ranked and for what phase. Clarify TAPD Rev. C 8/31/95 discussion of what is meant by SBWR unique features and phenomena.
Prepare Qualification Data Base (QDB) report for NRC review. Review for 27 completeness, consistency and quality and upgrade as necessary. Add purpose ODB 8/31/95 and a brief summary of the process.
Quantification of data uncertainties. Quantify measurement uncettainties in major TEST test parameters. (included in plan for Test Reports)
- Tabies figures referenced in the noted report sections may have also been modified or added in response to the subject Action item.
Page 2 4/13/95
List of NRC/ACRS Action items (Reference 1)
Where To Be Actual or No.
Item Description Documented Scheduled Date (Section # *)
to NRC Quantification of correlation uncertainties. Quantify uncertainties in the 29 correlations used in TRACG with reference to application to SBWR. (Included in MODEL ltem 53)
Update detailed test objectives in Appendix A to be consistent with discussions TAPD Rev. B 30 4/13/95 046-95 A.3.1.3.2, A.3.1.6.2, A.3.1.7.2)
Expand test conditions description.
TAPD Rev. B 31 4/13/95 046-95 A.3.1.3.1, A.3.1.6.1, A.3.1.7.1)
Justification of test initial conditions and range. Compare the range of parameters TAPD Rev B in the test to those expected in SBWR. Develop basis for how the test is picked up (A.3.1.1.4, A.3.1.2.4 32 "on the fly";i.e. how rate of change of parameters is treated.
I A.3.1.3.4, A.3.1.6.4, A.3.1.7.4) & Rev. C Test facility design details. (included in individual test reports on the various test 33 TEST programs) st insWmentadon MaHs - Wpes of instmments, locations and acuacy.
34 TEST (included in test reports)
Test procedure details - details of test loop preconditioning and initiation of test.
35 TEST (Included in test reports) 36 QA plans -included as part of test documentation.
TEST Use of GIRAFFE data. Role of GIRAFFE data in validation of TRACG.
TAPD Rev. B 37 4/13/95 046-95 (A.3.1.5.1) 38 Use of GIST data. Role of GIST data in validation of TRACG.
TAPD Rev. C 8/31/95 Determination of TRACG biases and uncertainties. Delineation of sources of data for quantifying bias and uncertainty in specific models. Roles of separate effects A
3N6 and integral tests in determination of overall uncertainty. (included in plan for Qual. LTR)
- Tables figures referenced in the noted report sections may have also been modified or added in response to the subject Action item.
- Page 3 4/13/95
7 List of NRC/ACRS Action items (Reference 1)
Where To Be Actual or No.
Item Description Documented Scheduled Date (Section # *)
to NRC TRACG model ranges vs. SBWR range. Quantify range of parameters over which TRACG models have been assessed vs. range of parameters expected in SBWR 40 QUAL 3/31/96 transients & LOCAs. Comparisons will be made for scaling groups identified for high and medium ranked PIRT Scope and range of sensitivity studies. Quantify the range of sensitivity studies APP 3/31/96 planned for the high ranked PIRT parameters as part of CSAU application.
Provide vacuum breaker white paper. Justify exemption from single failure criteria LtIitR 2/16/95 021-95 based on demonstrated reliability.
s res stant design. General concept to screen m inlet fmm deMs 43 SSAR resulting from blowdown. (Detailed design features not part of this program.)
Justify PCCS test data range (at LOCA vs 1 hr). Compare maximum credible PCCS TAPD Rev. B 4/13/95 046-95 flow (limited by main vent uncovery) with PANTHERS test data range.
(A.3.1.1.4)
PANTHERS IC additional tests (LOW PRESSURE, He). Include additional test and TAPD Rev. B 45 new test matrix in, TAPD Appendix A.
( A.3.1.2.4, Tab.A.3-4/13/95 046-95 Sa) en n
A es s ne es conMons for NA tests 46 TAPD Rev. C 8/31/95 based on TRACG results and engineering judgment.
GIRAFFE / Helium test objectives. Add to TAPD, Appendix A.
TAPD Rev. B g
4/13/95 046-95
( A.3.1.6.2) e ne a nal n egral sys e s s. Wop mst maw aM inWal MhB 48 4/13/95 046-95 conditions. Add to TAPD, Appendix A.
(A.3.1.7)
Additional GIRAFFE analysis. Perform TRACG analysis of additional tests defined 4g QUAL 3/31/96 in item 48.
A nal MME analysis. Mon WM anahsis d aMonal Ws 50 QUAL 3/31/96 defined in item 45.
Justification of U('8 correlation for Hydrogen. Define appropriate correlation t 51 MODEL use for condensation in the presence of Hydrogen.
l Reconcile SBWR nodalization vs. tests. Review TRACG nodalization used for individual test comparisons with the corresponding regions in SBWR. Perform 52 QUAL 3/31/96 sensitivity studies to establish appropriate SBWR nodalization,if significantly different from tests.(in s aM Coneladons RepomWal content Mo@ WQ Wel m 53 MODEL l
(32176) to include items 3,6,7,8,11 and 29.
- Tables figures referenced in the noted report sections may have also been modified or added in response to the subject Action item.
Page 4 4/13/95 l
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1 List of NRC/ACRS Action items (Reference 1)
Where To Be Actual or No.
Item Description Documented Scheduled Date (Section # *)
to NRC 54 Models and Correlations Report-Production MODEL Presentation on startup process. Prepare discussion of Dodewaard startup 55a procedure and SBWR startup procedure, showing trajectory of power, pressure, Presentation ACRS Meeting flow and intet subcooling.
55b Discussion of startup process. Prepare presentation based on item 55a.
TAPD Rev. C 8/31/95 Treatment of noncondensible distribution-TRACG. Develop plan for validation and TAPD Rev. B 56a 4/13/95 046-95 application of TRACG for noncondensible distribution.
(2.3.1)
Treatment of noncondensible distribution-measurement. Add capability for TAPD Rev. B 56b measurements of noncondensible distributions in the containment regions of the (A.3.1.6.1, Tab.A.3-7, 4/13/95 046-95 SBWR test facilities.
Fig.A 3-13d)
TYer data rangeJabulaMe range oNata om wWM model is 57 MODEL applicable.
Develop TRACG documentation plan. Prepare a detailed plan and table of contents 58 LETTER 4/30/95 for the modified TRACG Model LTR for discussion with NRC Staff.
Develop outline for test reports. List proposed test reports. Review proposed TAPD Rev. B 59 4/13/95 046-95 content with NRC Staff.
(A.2.5.1, Att.A1)
Develop outlines for preliminary validation reports. List propoced preliminary TAPD Rev. B (App.A, 60 4/13/95 046-95 validation reports. Review proposed content with NRC Staff.
Att.A1)
Add "roadmap* to introduction section. Include list of reports and tables of TAPD Rev. B 61 contents as an appendix.
( 1.2.1.3, 1.4.1, 1.4.2, 4/13/95 046-95 A.2.5.2)
- Tables figures referenced in the noted report sections may have also been modified or added in response to the subject Action item.
Page5 4/13/95
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'a.
. List of NRC/ACRS Acti::n it;m3:
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s.
GLOSSARY Description Document g
- APP APP = TRACG SBWR Application Topical Report NEDE-32178 LETTER Lh1 I ER = GE to NRC letter.
MODEL MODEL = TRACG Model Topical Report NEDE-32176 Presentation Presentation = GE to ACRS presentation ODB QDB = GE Qualification Data Base, DRF A70-00002 QUAL QUAL = TRACG Qualification Topical Report NEDE/O-32177 SSAR SSAR = SBWR Standard Safety Analysis Report,25A5113 TAPD TAPD = SBWR Test and Analysis Program Description, NEDC-32391P TEST TEST = Test report for the specific facility or series of tests x
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l General Electric Company i
)
. I, D. J. Robare, being duly sworn, depose and state as follows:
(1) I am Project Manager, General Electric Company ("GE") and have been delegated
)
,C the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.-
(2) The information sought to be withheld is contained in the GE Proprietary; Licensing Topical Report, NEDC-32391P, Revision B, "SBWR Test and Analysis Program Description".
(3) In making this application for withholding of proprietary information of which it is an owner, GE 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 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for " trade secrets and conunercial 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 H
" trade secret", within the meanings assigned to those terms for purposes.of FOIA' Exemption 4 in, respectively, Critical Mass Energy Project v. Nucient Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citi7en Health Research Group v. FDA,704F2d1280 (DC Cir.1983).
(4) Some exam,ples of categories of information which fit into the definition of.
proprietary mformation are:
a.
Information that discloses ' a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric 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 quahty, or licensing of a similar product; c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, or future General Electric l-customer-funded development plans and programs, of potential commercial value to General Electric; l
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'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 both paragraphs (4)a,-(4)b and (4)d, above.
(5) The information sought to be withheld is being submitted to NRC in confidence.
The information is of a sort customarily held in confidence by GE, 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 GE, no public disclosure has -
been made, and it is not available in public sources. All disclosures to third parties -
including any rec uired transmittals to NRC, have been made, or must.be made, pursuant to regu atory provisions or proprietary, agreements which provide for -
maintenance of the information in confidence. Its mitial 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 comxment, 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 GE 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 ftmetion (or his.
~
delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.1 DisclosuresL outside GE 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 identified by bars in' the right-side. margins is classified as' proprietary because it contains details of the ' method.of. development and.
supporting data and analyses relative to the TRACG computer program. This program is' intended for use as the licensing-basis code for. evaluating BWR response to transients without scram. This code has been under development by GE for over ten years, at a total cost in excess of $3 million. This information is considered to be proprietary for the reasons set forth in both paragraphs (4)a and (4)b, above.
The information identified in paragraph (2) is classified as. also proprietary y
because it contains details of the SBWR tests aad supporting data and analyses.
This test program has been under development by GE and it associates for more i,
than seven years at a total cost of ten of millions of dollars. This information is considered to be proprietary for the reasons set forth in paragraphs (4)a, (4)b and (4)d, above.
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L(9) Public disclosure of the information sought to be withheld is likely to cause
.. substantial harm to GE's competitive position and foreclose or reduce the '
availability of profit-making opportunities.
The information is part of GE's comprehensive BWR 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 the value derived from providing analyses done with NRC-approved methods.
The_ research, development, engineering, and NRC review costs comprise a.
substantial investment of time and money by GE and its associate.
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.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstratmg that they can arrive at the same or similar conclusions.
The value of this information to GE 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 GE of the opportunity to exercise its competitive advantage to seek an adequate return on the large investment in developing these very valuable analytical tools.
STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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-D. J. Robare, 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 his knowledge, Executed at San Jose, California, this day of APrU L
,19,Q5 su D. J. Robare General Electric Company Subscribed and sworn before me this //d day of
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Itblic, State of California JUU2 A.CURTS COMM d 974657
-l Nowy Puttc - Co!ifornia SANTA CL/ ^ A COUN1Y j
AN Comm. ExV 4 SEP 30.1996
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