ML20136G139
| ML20136G139 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/11/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20057G445 | List: |
| References | |
| NUDOCS 9703170217 | |
| Download: ML20136G139 (8) | |
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k Tennessee Valley Authority, Post Office Box 2000. Decatur, Alabanu 35609-2000 March 11, 1997 l
U.S. Nuclear Regulatory Commission 10 CFR 50.46 (a) (3) (ii)
ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 r
BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 ADOPTION OF THE GENERAL ELECTRIC (GE) SAFER /GESTR LOSS OF COOLANT ACCIDENT METHODOLOGY k
On February 23, 1996, TVA provided a letter detailing the s
adoption of the General Electric (GE) SAFER /GESTR model for
,j evaluation of the LOCA analysis for BFN.
Due to an
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administrative error the analysis was omitted from the j to the letter.
This letter corrects the error, s
j As discussed in the cover letter transmitted February 23, l
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1996, TVA reported the change in the evaluation model utilized to analyze the LOCA for BFN in accordance with the requirements of 10 CFR 50.46 (a) (3) (ii).
That is, TVA is adopting the GE SAFER /GESTR model for evaluation of the LOCA
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analysis for BFN.
NRC accepted this model of LOCA analysis evaluation for use by the owners of Boiling Water Reactors l
(BWR) (BWR/3, BWR/4, BWR/5, and BWR/6) designed by GE.
This is further discussed in the letter from C. O. Thomas, NRC to J.
F.
Quirk, GE (see Reference).
TVA has utilized the SAFER /GESTR model evaluation for LOCA analysis for Unit 2 cycle 9 operation and will utilize it for Unit 3 Cycle 8 operation.
Unit 1 is in an extended outage; nevertheless, TVA anticipates utilizing the SAFER /GESTR model for Unit 1 when restarted.
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. U.S. Nuclear Regulatory Commission Page 2 i
March 11, 1997 J
J As a result of using the SAFER /GESTR model for evaluating a
- LOCA, the limiting-license basis fuel rod peak cladding temperature (PCT) for a. postulated event is reduced by more j
than 50 degrees fahrenheit '(F) and remains below 2200 degrees F.
Additionally, the application of this methodology results in an upper bound PCT of less than the Licensing Basis
- p PCT and is less than 1600. degrees F.
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- 't Changing to the SAFER /GESTR evaluation model does not require j
any changes in the parameters that initiate Engineered Core
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Cooling System logic.
Therefore, no Technical Specification l
change will be required to implement this change.
4 A plant specific analysis in supp h t of the change to I
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SAFER /GESTR model-is provided in Enclosure-1.
This enclosed i
information is proprietary to GE and GE requests that this i
document be withheld from public disclosure in accordance with
An affidavit supporting the request in i.
accordance with 10 CFR 2.790 (b) (1) is provided in the l.i enclosure.
1 There are no new commitments introduced by this letter.
The commitments made in the February 23, 1996, letter which have not been completed are provided in. Enclosure 2.
If you have jl any questions please contact me at (205) 729-2636.
S4'acerely
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g Tim E.bney
,I Manager of censi g l'
and Indus rial A fairs Enclosures cci - See page 3 m w w
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U.S. Nuclear Regulatory Commission Page 3
' March 11, 1997
Reference:
NRC letter dated June 1, 1984, " Acceptance'for Refe,rencing of Licensing Topical Report NEDE-23785 Revision 1, Volume III(P),
The GESTR-LOCA'and SAFER Models for the Evaluation of the i
Loss-of-Coolant Accident."
Enclosures cc (Enclosures) :
Mr. Mark.S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta' Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector
. Browns. Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr. J. F. Williams, Project Manager 1
U.S.. Nuclear Regulatory Commission One White Flint,-North 11555 Rockville Pike Rockville, Maryland 20852
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ENCLCSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 SAFER /GESTR LOSS OF COOLANT ACCIDENT (LOCA) ANALYSIS This enclosure provides the following:
An affidavit from General Electric (GE) requesting that the information regarding the BFN Loss of Coolant Accident Analysis be withheld from public disclosure.
The GE Nuclear Energy " Browns Ferry Nuclear Plant Units 1,
2, and 3, SAFER /CESTR-LOCA Loss Of Coolant Accident Analysis," NEDC-3248P Revision 2, Class III (GE Company Proprietary Information), dated February 1996.
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General Electric Company AFFIDAVIT 1, David J. Robare, being duly swom, depose and state as follows:
(1) I am Project Manager, Technical 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) The information sought to be withheld is contained in the GE proprietary report GE-NEDC-32484P. Browns Ferry.Vuclear Plant SAFER /GESTR-LGCA Accident Analysis. Revision 1. Class III (GE Company Proprietary Information), dated February 1996. The proprietary infonnation is delineated by bars marked in the margin adjacent to the specific material.
(3) In making this application for withholding of proprietary information of which it is the owner. GE relies upon the exemption from disclosure set fonh 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 somc portions also qualify under the narrower defmition of" trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatorv Commission. 975F2d871 (DC Cir.1992), and public Citizen Health Research Grouo
- v. FDA,704F2dl280 (DC Cir.1983).
(4) Some examples of categories of information which fit into the defimition of proprietary information are:
Information that discloses a process, method, or apparatus, including supporting a.
data and analyses, where prevention ofits 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 quality, or licensing of a similar product; 12/13/93RTH Affidavit Page !
Information which reveals cost or price information, production capacities, c.
budget levels, or commercial strategies of General Electric, its customers, or its suppliers d.
Infomtation which reveals aspects of past, present. or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric:
Information which discloses patentable subject matter for which it may be e.
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. and (4)b.. 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 beiief consistently been held in con 6dence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions 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) fc,llowing.
(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 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 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 identi6ed in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of the loss-of-coolant accident for the BWR.
wi),93Rm Affidaut Pye '
The development and approval of the BWR loss-of-coolant accident analysis computer codes used in this analysis was achieved at a significant cost. on the order of several million dollars, to GE.
The' development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive -experience database that constitutes a ma.ior GE asset.
(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 protit making opportunities. The information is part of GE's comprehensive BWR safety and 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 development of the expertise to determine and apply the appropriate evaluation process. In addition the technology base it"ludes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a' substantial investment of time and money by GE.
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.
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 its large investment in developing these very valuable analytical tools.
.DumRm Affidavit Page 3
i STATE OF CALIFORNIA
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ss:
COUNTY OF SANTA CLARA David J. Robare. being duly swom 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, information. and belief.
Executed at San Jose. Califomia, this 3 day of PcBfMjQR/
1996.
David J. Robare General Electric Company Subscribed and sworn before me this day of M brvc re _1996.
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PAtxA F. HUSSEY
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Notary Public, State of Californiap 12/i3/93RTFi Aflidaut Page 4
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