ML20091P269

Forwards Proprietary Rev C to Topical Rept NEDC-32391P, Sbwr Test & Analysis Program Description. Topical Rept NEDC-32391P Withheld (Ref 10CFR2.790)

ML20091P269
Person / Time
Site:	05200004
Issue date:	08/28/1995
From:	Quinn J GENERAL ELECTRIC CO.
To:	Quay T NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19330G254	List: ML20091P269
References
MFN-166-95, NUDOCS 9509010112
Download: ML20091P269 (11)

Text

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GENuclearEnergy

$165 San Josa. CA 95125-1014 MR B

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n 408 9251005 (phone) 408 925-3991 (facstmile)

August 28,1995 MFN 166-95 Docket STN 52-004 Document Control Desk U. S. Nuclear Regulatory Commission Washington DC 20555 Attention: Theodore E. Quay Director Standardization Project Directorate

Subject:

SBWR - Test and Analysis Program Description, NEDC-32391P, Revision C (Proprietary)

Reference:

1. MFN 136-95, J. E. Quinn (GE) to T. E Quay (NRC), SBWR - Response to Requestfor AdditionalInformation (RAI) Regarding the Simphfied Boiling Water Reactor (SBWR) Design (Q900.102 - Q900.181), dated 6/29/95, July 28,1995.

2. MFN 018-95, J. E. Quinn (GE) to R. W. Borchardt (NRC), Approach to Achieve Closure of Items Related to the GE SBWR TAPD, February 14, 1995.

3. Memorandum to John T. Larkins (ACRS from Dennis M. (NRC), Draft Safety Evaluation Report (SER) on the Adequacy of the Technical Appraach to the Testing and Analysis Program (TAP)for the Simphfied Boiling Water Reactor (SBWR) Design, November 25,1994.

4. ACRS Thermal IIydraulic Phenomena Subcommittee Meetings, December 15 and 16,1994, and January 10,1995.

5. NRC/GE TAPD DSER Meeting January 9,1995.

6. 417th ACRS Meeting January 12, 1995.

This letter transmits Revisican C of the SBWR Test and Analysis Program Description (TAPD) report, NEDC-32391P, for your review. This report provides a compreheasive, integrated plan that addresses the testing and analysis elements needed for analysis of SBWR performance. In particular, this revision of the document describes the resolution of testing related issues identified in References 1 and 2.

GE-NE requests NRC concurrence that the planned tests satisfactorily address the concerns in References 1 and 3 through 6, and moreover provide an adequate basis for TRACG qualification.

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I GENuclearEnergy MFN 166-95 s

Revision C replaces Revision B in total. The changes from Revision B to Revision C are identified by sidebars in the left-hand margins of the affected pages. Please dispose of all i

copies of Revision B in 9 manner appropriate for the destruction of proprietary materials, or return them to GE Nuclear Energy, Attention: J. E. Ixatherman, M/C 781.

4 Reference 2 identifies the process and approach being utilized to achieve closure on the issues raised in Reference 3, NRC TAPD Draft Safety Evaluation Report (DSER), and References 4 through 6, meetings with the NRC and ACRS. This letter provides an update (see attached table) to References 1 and 2 with respect to the resolution status of each TAPD related action item from the responses to RAIs 900.102-181 and the GE-NRC-ACR5 meetings held in December 1994 and January 1995. The table includes the affected (changed) report locations.

Revision C also includes changes related to updated or newer information, editorial corrections 1

and improvements, and additional information provided for completeness.

?

j Please note that NEDC-32391P contains information of the type which GE maintains in l

wnfidence and withholds from public disclosure. They have been handled and classified as j

proprictary t.s GE as indicated in the attached affidavit.

We hereby request that this mformation be withheld from public disclorure in accordance with the provisions of 10CFR2.790. Revision C to NEDC-32391P provides sidebars in the right-hand margins to j

1 l

distinguish those parts of the document which are deemed Proprietary to the General Electric Company. A non-proprietary version of the subject report will be supplied under a separate cover letter.

1 If you have any questions regarding this report, please contact John Leatherman of our staff on (408) 925-2023.

Sincerely,

, /.gf //

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s ames E'Quinn, Pr@ects Manager

Attachment:

Status of TAPD, Rev. C + Scaling Report Commitments and RAls

Enclosure:

SBWR Test and Analysis Program Description (TAPD),

NEDC-32391P, Revision C 1

l i

cc:

P. A. Boehnert (NRC/ACRS) - [7 paper copies w/ att & w/ encl., plus E-Mail w/ att]

I. Catton (ACRS) - [1 paper copy w/ att & w/ encl., plus E-Mail w/ att]

l S. Q. Ninh (NRC) - [21 paper copies w/ att & w/ encl., plus E-Mail w/ att]

l J. H. Wilson (NRC) - [1 paper copy w/ att & w/ encl., plus E-Mail w/ att]

D

'Attachmer!t to MFN 166-95 J

1 Status of TAPD, Rev. C Scaling Report Commitments and RAls Source or Scheduled ID or RAI Date Where Date No.

Received Comments or Action Documented Develop chimney technical basis. Develop supporting TRACG 12/94 &

data for void fraction in large diameter pipes and Qualification LTR 4/1/96 4

1/95 capability of TRACG to analyze flow distribution in NEDE-32177P meetings parallel channels. Document in Qual. report.

Red in TAPD Rev. C, consideration of medium and low TAPD-C Tables 2.3-12/94 &

phenomena - Include medium ranked phenomena in 1 through 2.3-5; 4.1-8/31/95 17 1/95 assessment matrix; low ranked phenomena only in 1a through 4.1-5b; meetings checks for existence of models in TRACG.

5.1-1a through 5.5-2b.

12/94 &

In TAPD Rev. C, clarify interaction studies discussed TAPD-C Sec. 4.2 &

8/31/95 19 1/95 in Sections 4.2 and Appendix C of TAPD to address C.3 meetings specific questions in DSER.

12/94 &

In TAPD Rev. C, include vessel / containment TAPD-C Table 2.3-8/31/95 20 1/95 interactions as specific highly ranked phenomena in 2; Section 2.3-1 meetings PIRT.

12/94 &

in TAPD Rev. C, discuss PCCS purge / vent process TAPD-C Section 8/31/95 21 1/95 from phenomenological point of view.

A.3.1.1.4 meetings 12/94 &

in TAPD Rev. C, separate out SRV air clearing loads TAPD-C Table 2.3-8/31/95 22 1/95 as an item in PIRT for containment.

2; Section 2.3.1 meetings 12/94 &

In TAPD Rev. C, include discussion of PAR TAPD-C Sections 8/31/95 24 1/95 interactions. Add description of performance ggg meetings characteristics and flow patterns induced by PARS.

In TAPD Rev. C, expand discussion of PIRT tables.

12/94 &

RquesM Add new Appendix D which willinclude a brief 8/31/95 25 1/95 nformation is in new discussion of each parameter and the basis for its 4

meetings TAPD Suppioment i ranking.

l In TAPD Rev. C, address phases of the transient in 12/94 &

Section 3. Add column to Table 3.2-1 to indicate for TAPD-C Section 8/31/95 26 1/95 what transient the phenomena are ranked and for what 3.2, Table 3.2-1 meetings phase. Clarify discussion on SBWR unique features and phenomena.

12/94 &

In TAPD Rev. C, document use of GIST data. Roie of TAPD Rev.C 8/31/95 38 1/95 GIST data in validation of TRACG.

Section 7.0; i

meetings Appendix A.3.1.4.2 12/94 &

In TAPD Rev. C, define PANDA tests MS,M7, M9.

TAPD-C Section

]

8/31/95 46 1/95 Define test conditions for PANDA tests based on A.3.1.3.3; Table A.3-meetings TRACG resuts and engineering judgment.

10b In TAPD Rev. C, justify test initial conditions and 12/94 &

range. Compare the range of parameters in the test t TAPD-C Section j

8/31/95 32 1/95 those expected in SBWR. Develop basis for how the A.3.1.7.4 i

meetings. test is picked up "on the fly"; i.e. how rate of change of parameters is treatad.

l Page1

1 "Attachmer)t to MFN 166-95 l

i Status of TAPD, Rev. C Scaling Report Commitments and RAls Source or Scheduled ID or RAI Date Where Date No.

Received Comments or Action Documented In TAPD Rev. C, add ATWS scenario in Section 2.2.3 TAPD-C Sec.

12/94 &

and expand Table 2.3-4. For stability, expand Table 2.2.3.1, Tab. 2.3-4, 8/31/95 23a 1/95 n

ah 2.3-5, Rg. 2.2-meetings 6

The use of the term " reactor water level" will be 4

8/31/95 900.102 MFN 136-TAPD-C throughout clarified throughout the TAPD report in Revision C.

GE rees and will make the change in TAPD 8/31/95 900.104 MFN 36-TAPD-C Sec. 2.3.1 95 e [*n 8/31/95 900.105 MFN 36-95 Partial &

This typographical error will be corrected in revision C 8/31/95 900.106 MFN 136-to correctly reflect " water carryover and steam carry TAPD-C Table 3.2-1 95 under."

Partial &

8/31/95 900.107 MFN 136-Table 3.2-1 to be updated in TAPD-C TAPD C Tab. 3.2-1 95 Partial &

GE will use the early GIRAFFE test as " SUPPORTING TAPD-C Sections 8/31/95 900.108 MFN 136-INFORMATION", and indicate this consistently in 3 and 5 95 Sections 3 and 5 of TAPD, Rev. C.

Partial &

Section 3.3.9 will be modified in TAPD, Rev. C t TAPD-C Section 8/31/95 900.109 MFN 136-emphasize that the planned test program will obtain 3.3.9 95 data to qualify TRACG.

P 8/31/95 900.113 MFN 36-TAPD-C Page 6-1 e dn PD ei C

95 GE se MPa (megapascals) in TAPD, Revision C 8/31/95 900.114 MFN 3S-TAPD-C throughout A

c. IC Operation with Non-condensable Gases - The Partial &

text in E. Jon A.3.1.2.4 (Justification of Test TAPD-C Section 8/31/95 900.115 MFN 136-Conditions) will be expanded to note that non-A.3.1.2.4 95 condensable gases are directly injected into the test unit inlet line and do not originate in the vessel.

8/31/95 900.116 MFN 36 Jhe text in TAPD will be revised to reflect the change TAPD-C Section in the IC test procedure.

3.1.2.4 95 The cycles shown in Figure A.3-23 apply to the TAPD-C Sections Partial &

" component demoristration" tests for the IC. The text A.3.1.2.1 &

8/31/95 900.117 MFN 136-and tables for both the " transient" and " component A.3.1.2.3; Tables 95 derr onstration" tests will be revised to provide a more A.3-5b, c & d, and jcomprehensive summary of the test procedures.

A.3-28 Page 2

"Attachmerit to MFN 166-95 Status of TAPD, Rev. C Scaling Report Commitments and RAls Source or Scheduled ID or RAI Date Where Date No.

Received Comments or Action Documented adal &

The requested information will be included in App. A of TAPD-C Section 8/31/95 900.120 MFN 136-TAPD, Rev. C.

A.3.1.7.4 + E7 95 TAPD - Comparisons with CRIEPl data will be made in p,g,; g app. A for " steady circulation flow, period of TAPD-C Sec.

8/31/95 900.121 MFN 136-scillations and flow amplitude in the instability A.3.1.8.2 95 regions, power-temperature stability map".

The scaling material App. B of the TAPD will be moved pg;,; g to the scaling report. This question will be partially Scaling Report (Ref.

9/15/95 900.123 MFN 136-addressed in the revised scaling report. The 32 of TAPD-C) 95 remainder of the response is re-scheduled for 9/95.

This question will be partially addressed in the revised Partial &

scaling report (NEDC-32288 Scaling of the SBWR Scaling Report (Ref.

9/15/95 900.124 MFN 136-Related Tests, Revision 1). The remainder of the 32 of TAPD-C) 95 response is re-scheduled for 9/95.

Partial &

The use of GIST data will be defined in Revision C of TAPD-C Section 8/31/95 900.125 MFN 136-the TAPD. The response to the question on the A.3.1.4.2; & Scaling 95 impact of the IC unit will be re-scheduled to 9/95.

Report This question will be addressed in the revised scaling Scaling Report (Ref.

9/15/95 900.126 MFN 36-report.

32 of TAPD-C) 95 ada! &

This question will be addressed in the revised scaling Scaling Report (Ref.

9/15/95 900.127 MFN 136-report.

32 of TAPD-C)

This question will be addressed in the revised scaling Scaling Report (Ref.

9/15/95 900.128 MFN 3 - report.

32 of TAPD-C) 95 Partial &

Several cases with varying numbers of available IC TAPD-C Sec. C.1 &

8/31/95 900.130 MFN 136-heat exchangers and no CRDs have been evaluated C'3, Tab. C.3-1 95 and will be included in App. C of TAPD, Revision C.

ada! &

The second paragraph of Section 2.2.1.3 will be TAPD-C Section 8/31/95 900.133 MFN 136-reviewed and clarified in TAPD, Revision C.

2.2.1.3 adal &

Figure 2.2-5 will be redrafted in TAPD-C to be TAPD-C Figure 2.2-8/31/95 900.136 MFN 136-consistent with Figure C.4-3.

5 95 Partial &

For TAPD Revision C, subsection 2.3.1 will be updated TAPD-C Section 8/31/95 900.137 MFN 136-to clarify the discussion on TRACG modeling of the 2.3.1 95 noncondensible distribution.

A df ussi n f item DW2 will be provided in TAPD, 8/31/95 900.138 MFN 36-u p ement 1 Sec.

so S1.2 Partial &

New TAPD 8/31/95 900.139 MFN 136-WW2 will be clarified in TAPD, Rev.C.

Supplement 1 Table 95 S1-1 t

Page 3 a

'Attichmerit to MFN 166-95 Status of TAPD, Rev. C Scaling Report Commitments and RAls Source or Scheduled ID or RAI Date Where Date No.

Received Comments or Action Documented adal &

900.140a a2. The typographical error on the spelling of PCCS

~

2

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will be corrected in TAPD-Revision C.

~

Partial &

Table 3.3-1 will be updated and the reference to 8/31/95 900.143d MFN 136-GIRAFFE test data as a Technology Basis as well as TAPD-C Table 3.3-1 95 confirming PANDA data will be deleted.

adal &

ltem 69: Relevant scaling results will be included in Scaling Report (Ref.

9/15/95 900.143g MFN 136 the updated Scaling Report.

32 of TAPD-C)

Partial &

GE will provide additional discussion in Section TAPD-C Section 8/31/95 900.144 MFN 136-A3.1.C 4 of TAPD on the basis for a hydrogen A.3.1.6.4 95 concentration.

adal &

The apparent discrepancy in Table 5.3-2 will be TAPD-C Table 5.3-8/31/95 900.149 MFN 136-clarified in TAPD, Rev. C.

2a & Table 5.5-2a TAPD-C - Fcr a breakdown by individual test, see easements wm M elahaW in TaNe 552 of 8/31/95 900.150 MFN 36-me ure er ts see 95 Table A.3-13. For PSTF data, see References 22,38 &

46.

amal &

In Revision C, the first sentence in the final paragraph TAPD-C Sec.

8/31/95 900.156 MFN 136-of TAPD Section A.3.1.5.1 will be revised.

A.3.1.5.1 Pa ial &

In Table A.3-3, page A-51, PANTHERS /PCCS test 78 8/31/95 900.160 MFN 136- (air and helium) should be included as a TRACG TAPD-C Table A.3-3 95 qualification point.

adal &

This question will be addressed in the revised scaling Scaling Report (Ref.

9/15/95 900.163 MFN 136-report.

32 of TAPD-C) 95 Partial &

This question will be partially addressed in the revised S

Re # (Ret 9/15/95 900.165 MFN 136-scaling report. The remainder of the response is re 32 of TAPD-C) 95 scheduled for 9/95.

This question will be addressed in the revised scaling Scaling Report (Ref.

9/15/95 900.166 MFN 136-report.

32 of TAPD-C) 95 Partial &

This question will be partially addressed in the revised Scalig RepWRef I

9/15/95 900.167 MFN 136-scaling report. The remainder of the response is re-32 of TAPD-C) 95 scheduled for 9/95.

Partial &

We agree that " component structural performance" is a TAPD-C Section 8/31/95 900.170 MFN 136-better description and will make that change in A.3.1.2.1 95 A.3.1.2.1 of TAPD-C.

Page 4

'Attechmerit to MFN 166-95 l

Status of TAPD, Rev. C Scaling Report Commitments and RAls i

1 Source or Scheduled ID or RAI Date Where Date No.

Received Comments or Action l

Documented Partial &

The text in Section A.3.1.1.4 will be revised to include TAPD-C Section 8/31/95 900.171 MFN 136-discuss;on of the condensate return flow from the A.3.1.1.4 95 PCC.

For clan 6 cation, Table 4.21 is u%ated wkh a footnote TAPD-C Tab. 4.2-1 8/31/95 900.172 MFN 3 - on the operation of RWCU System.

GE will correct the far right hand box in Figure 1.4-3 to TAPD-C Figure 1.4-8/31/95 900.174 MFN 36-say "lETS" and also define the acronyms in the text.

3; Section 1.4 95 Partial &

GE will update Table 1.2-2 to clarify the SBWR 8/31/95 900.175 MFN 133-Feature description, and change ADS Valves to SRVs TAPD-C Tab.1.2-2 95 in the table.

The test objective and other text will be improved in p,g, g TAPD, Rev. C to more closely reflect the process that TAPD-C Section 8/31/95 900.180 MFN 136-will be used to confirm the mechanical design of the IC A.3.2.2.2.

95 heat exchanger.

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g General Electric Company AFFIDAVIT I, George B. Stramback, being duly sworn, depose and state as follows:

-(1) I am Project Manager, Licensing Services, General Electric Company ("GE") and have been delegated 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) GE is an owner of the information sought to be withheld. The information sought to be withheld is contained in the GE report, NEDC-32391P, SBWR Test and Analysis Program Description, Revision C, Class 3 (GE Proprietary Information), dated August 1995. The proprietary information is delineated by bars in the right-hand margin adjacent to the specific material.

(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 commercial 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 " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citi7en Health Research Group v. FDA,704F2d1280 (DC Cir.1983).

j (4) Some examples of categories of information which fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including suppon ng data and analyses, where prevention of its use by General Electric's competitors without h.

se from General Electric constitutes a competitive economic advantage over other companies; Affidavit page 1

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 quality, 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 customer-funded development plans and programs, of potential commercial value to General Electric; e.

Information which discloses patentable subject matter for which it may be desirable 4

to obtain patent protection.

i 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.

l (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 mtde, and it is l

not available in public sources. All disclosures to third parties including any required j

l transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions i

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 paragraphs (6) and (7) following.

i (6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, 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 i

review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by

}

the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory l

bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the infonnation, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

1 i

Affidavit page 2 4

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(8) The information identified in paragraph (2), above, 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 three million dollars.

The information identified in paragraph (2), above, also is classified as proprietary because it contains details of the SBWR tests and supporting data and analyses. This test program has been under development by GE and its associates for more than seven years at a total cost of tens of millions of dollars.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial hann 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 associates.

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 demonstrating that they can arrive at the same or similar conclusions.

l The value of this information to GE would be lost if the information were disclosed to the i

public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide i

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.

i a

Affidavit page 3 1

STATE OF CALIFORNIA '

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ss:

COUNTY OF SANTA CLARA

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George B. Stramback, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are tnie and correct to the best of his knowledge,

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Executed at San Jose, California, this dNday of der /o[,19_YJ f

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L George B[Stramback General Electric Company Subscribed and sworn before me this.2M day of

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Mtary Public, State of C '

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JUUE A.CURTS h"

COMM. # 974657 Notory PubGe - Cofifornio f

E SANTA CLARA COUNTY 4

j My Comm. Expires SEP 30.1996 l

/Endavit page 4

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