ML20205F134
| ML20205F134 | |
| Person / Time | |
|---|---|
| Site: | 07109195 |
| Issue date: | 10/22/1985 |
| From: | Cunningham G GENERAL ELECTRIC CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19344C129 | List: |
| References | |
| 25955, NUDOCS 8511040499 | |
| Download: ML20205F134 (13) | |
Text
F 7MM GENERAL $ ELECTRIC UlUgr n
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NUCLEAR ENERGY BUSINESS OPERATIONS WE GENERAL ELECTRIC COMPANY e VALLECTOS NUCLEAR CENTER e PLEASANTON, CAUFORNIA 94566 Sb October 22, 1985 g
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Mr. C. E. MacDonald, Chief g ' Ogc#@s$
Transportation Certification Branch WQ p/
Office of Nuclear Material Safety and-Safeguards U.S.. Nuclear Regulatory Commissio.n
.. b w Washington, D.C.
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References:
- 1) Application for a Certificate of Compliance for the GE Model 2000 Shipping Container,.G. E. Cun'ningham to C. E. MacDonald; October 31.-1984.
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- 2) Letter with the GE Model 2000 Stress Report and Affidavit, G. E. Cunningham to C. E. MacDonald; December 10, 1984.
- 3) Letter with Enclosure, C. E. MacDonald to_
G. E. Cunningham; April 17, 1985.
Dear Mr. MacDonald:
O r ai ietter i i= re Pe e te veur rea ueet c a er 3) rer ea attie=ei i=rer etie=
on the GE Model 2000 shipping container.
Because of the extensiveness of the revisions to the " Safety Analysis Report", NEDO-30778, and the " Stress Report", NEDE-30779, complete ne'W copies of both documents are enclosed rr.ther than revised pages.
Please. replace the, texts of both binders with the new editions.
General Electric considers the " Stress Report", NEDE-3b779, as proprietary, and the appropriate affidavit for Withholding the document' from the Public i
Document Room (PDR) required by_10CFR2.790 is attached.
The affidavit also requests that certification drawings -1297 4946,129D4947, and 129D4948 3
contained in the " Safety Analysis Report", NEDO-30778, be withheld from the PDR.
These drawings contain sufficient detail to permit unauthorized construction of the Model 2000.
Because of its proprietary nature, General Electric requests that all copies of the previously submitted text of NEDE-30779 be returned.
The following items are responses to the specific comments and questions contained in your correspondence of April 17, 1985 (Ref. 3).
The outline and nu bering-follow the same format as your inquiries,
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S GENERAL $ ELECTRIC C. E. MacDonald ' October 22, 1985 Item
Response
Drawings -
1.-2 and
.New certification drawings have been issued (129D4946, 5.-12.
129D4947,129D4948) which incorporate the requested changes.
3.
The vertical spacer tubes are welded to the overpack shell as shown on Drawing 129D4947 using a 0.25-inch fillet weld.
The welds are one inch in length at increments of four inches.
4.
The fabrication specification controlling the construction of the Model 2000 outlines the examination procedures and acceptance criteria for each nondestructive examination method indicated on the certificate drawings.
These procedures and criteria are based on ASME,Section III, Subsection HG-5000.
General 1.
. Neutron sources have been eliminated as a requested loading.
2.
Section-5.0 of the SAR has been modified to include an analysis
'O demonstrating the shielding capabilities of the cask for various
_ photon energies.
The shielding incurs no damage or deformation' in the accident case.
3.
The typo on bolt designation has been corrected.
4.
The spacer tubes have been reclassified as safety related.
5.
The toroid. shells are formed by joining four 900 elbows manufactured under ASTM A403.
6.
" Standard mill tolerances" have been replaced.on the drawings with actual numbers.
7.
An explanation was added to Section 2.4.3 of the SAR.
8.
A description is contained in Section 7.1.7 of the SAR.
9.
A description has been added to Section 2.3 of the SAR.
l 10.
The requested information has been incorporated into Drawing No. 129D4947.
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r GENERAL $ ELECTRIC C. E. MacDonald October 22, 1985 Item
Response
Finite Element Model 1.
Sections 5.2.2 and 5.2.3 of the " Stress Report" (SR) have been modified using a cylindrical lid in the analysis.
2.
Appendix A of the SR was expanded to give a summary of the verification data for the LIBRA program including testing performed by General Electric.
3.
Section 4.2.3 and Appendix A of the SR have been expanded to include the requested information.
Analyses 1.
Section 2.7.2 of the SAR has an added discussion of lifting devices.
2.
Section 2.4.4 of the SAR has been rewritten, and the detailed calculations are contained in Section 2.7.4.
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3.
Section 5.2.3 of the SR addresses lead slump showing the motion of the lead relative to the cladding for coincident nodes in each material.
4.
The buckling analysis has been added to Section 4.2.9 of the SR.
5.
Appendix A of the SR has been revised to include justification for the analytical approach taken.
Stress Report 1.
Table 2 of Regulatory Guide 7.8 indicates the use of maximum internal pressure in this case.
For the Model 2000, the design pressure is 30 psia.
2.
Example calculations have been added to 5.2.2 of the SR.
No averaging was done between dissimilar materials.
3.
Section 5.2.2 of the SR was enlarged, and additional examples are shown both for the cases in which discontinuity bending stresses and in which membrane stresses are produced.
A 1
1.
October 22, 1985 C. E. MacDonald Item
Response
Stress Report (Continued)
- 4. (a)
A summary of work performed to justify this approach has been
. added to Section 5.2.2 of the SR.
(b)
Section 4.2.7 of the SR has been rewritten and expanded.
(c)
Section 4.2.5 of the SR has been rewritten to include the requested information.
(d)
The whole structure, not just a few predetermined locations, are analyzed.
The stresses reported in Section 3.2.0 of the SR are the maximum stresses.
(c)
The approach used is conservative as explained in Section 4.2.7.2 of the SR.
(f)
Section 4.2.6 and Appendix A of the SR now address this question.
'5.
All three references listed are for chemical lead.
Section 5.2.2 of the SR addresses reducing the lead module.
6.
Section 4.2.3.1 of the SR has been expanded to include the requested information.
7.
Section 4.2.3.1 of the SR has been expanded to include the requested information.
- 8. (a)
Sections 4.2.3 through 4.2.7 of the SR now include the requested information.
(b)
Appendices A and G of the SR have been expanded to cover the question.
-(c)
See Section 4.2.3.2 of the SR.
(d)
The material properties used have been added to Sections 4.2.4 to 4.2.9 of the SR.
(f)
Appendix F of the SR has been rewritten to more clearly address the stress correlations.
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O GENERAL $ ELECTRIC C. E. MacDonald October 22. 1985
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Item
Response
Stress Report (Continued) 9.
The requested information is contained in the expanded Section 4.2.3.3 and Appendix G of the SR.
- 10. (a)
The justification is presented in Section 4.2.4 of the SR.
(b)
The juetiGention is presented in Section 5.2.2 of the SR.
(c)
See Sections 4.2.3.2 and 4.2.4 of the SR, 11.
Section 4.2.5 of the SR has been rewritten to include the information requested.
12.
The revised Appendix A to the SR has been revised to address these questions.
13.
Sections 4.2.7 and 5.2.1 of the SR address these questions.
14.
See revised Section 4.2.7.2 of the SR.
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- 15. (a)
See Section 5.2.2 and Appendix G of the SR.
(b)
Appendix G of the SR has been expanded to cover the question.
(c)
See revised Section 5.2.2 of the SR.
16.
Section 4.2.8 of the SR has been rewritten to include the requested information.
17.
The accident analysis demonstrates that all of the damage occurred in the toroid and that the rest of the overpack remained intact.
The thermal analysis was made using the intact overpack without the toroid, i.e., it was assumed that the toroid was totally lost.
18.
See revised Section 5.2.3 of the SR.
Shielding See Item 1., General.
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C. E. MacDonald October 22, 1985 Item
Response
Operating Procedures, Etc.
The operating procedures, maintenance program, and acceptance tests are included in Sections 7.0 and 8.0 of the SAR.
, Sincerely,
.E
. E.
unnin ham Senior Licensing Engineer (415) 862-2211, Ext. 4330
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GENERAL ELECTRIC C0MPANY SUPPLEMENTARY AFFIDAVIT I, R. Villa, being duly sworn, depose and state as follows:
1.
I am Manager, Products Licensing, General Electric Company, 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 "Model 2000 Radioactive Material Transport Package Safety Analysis Report",
NED0-30778, Class I, October, 1984, and in the proprietary document, "Model 2000 Radioactive Material Transport Package Stress Report",
NEDE-30779, Class II, August 1984 issued fa support of the analytical results reported in the Safety Analysis Report (NE00-30778) for the Model 2000 transport package. The Stress Report describes the analytical methods used and detail calculations for the design of Type B packages.
Also, it presents listing of computer subroutine employed in the analyses.
3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it...
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information...
Some factors to be considered in determining whether given information is one's trade secrete are:
(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and his competitors; (5) the amount of effort or money expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
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 where prevention of its use by General Electric's competitors without I
license from General Electric constitutes a competitive economic advantage over other companies; i
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Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the
. application of which provide a competitive economic advantage, e.g.,
by optimization or improved marketability; c.
Information which if used by a competitor, would reduce his expenditure resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product;
'd.
.Information which reveals cost or price-information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; e.
Information which reveals aspects of past, present or future General
' Electric customer-funded development plans and programs of potential commercial value to General Electric; f.
Information which discloses patentable subject matter for which it-may be desirable to obtain patent protection; g.
Information which General Electric must treat as proprietary according to agreements with other parties.
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5.
k addition to proprietary treatment given to material meeting the st-ndards enumerated above, General Electric customarily maintains in
'O coi fidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review. This practice is based on the fact that draft documents often do not appropriately reflect a11' aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures. Also, until the final document is completed it may not be possible to make any definitive determination as to its proprietary nature. General Electric is not generally willing to release such a document to the general public in such a preliminary form.
Such documents are, however, on occasion' furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant and potentially significant information. Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.
6.-
Initial approval of proprietary treatment of a document is made by the Subsection Manager of the originating component, the man most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
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7.
The procedure for approval of external release of such a document is
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reviewed by the Section Manager, Project Manager, Principal Scientist or v
other equivalent authority, by the Section 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 in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or proprietary agreements.
8.
The documentation mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
9.
The information mentioned in paragraph 2 provides additional information in support of the licensing of the Model 2000 Transport Package.
- 10. The information to the best of my knowledge and belief, has consistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence.
O 11.
Public disclosure of the information sought to be withheld is likely to b'
cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit-making opportunities because:
a.
It was developed with the expenditure of resources exceeding
$200,000.
b.
Public availability of this information would deprive General Electric of the ability to seek reimbursement, and would permit competitors to utilize this information to General Electric's detriment.
c.
Public availability of the information would allow competitors to obtain information at no cost which General Electric developed at substantial cost.
Use of this information by competitors would have given them a competitive advantage over General Electric by allowing competitors to design Type B packages at lower cost than General Electric.
The above initial evidential justification requesting that the information contained in the proprietary document be withheld from public disclosure is further supplemented by the additional following information.
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NED0-30778 contains drawings 12904946, 129D4947, and 129D4948.
These
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drawings contain sufficiently detailed information to permit a competitor to copy the Model 2000 design.
The NEDE-30779 document, "Model 2000 Radioactive Material Transport Package Stress Report" presents a detailed account of the analytical method developed by General Electric (GE) for the design of Type B radioactive packages in accordance with 10CFR71.
This method, developed over a two year period, includes a substantial amount of developmental computer calculations and prototype testing at a cost to GE in excess of
$200,000.
The basis of the analytical method is finite element (FE) computational techniques. A LIBRA FE computer program was used to perform all the required analyses.
However, as indicated above GE developed the unique application of LIBRA to shipping container design as described in NEDE-30779.
The applications of FE techniques depends on the following parameters:
the computer program used; the geometrical representation of the structure or model; material properties assignment; and the application of boundary and loading conditions to the model to represent the design case.
GE believes that those sections within NEDE-30779 document that would significantly assist a competitor in applying these techniques in analyzing a similar package are proprietary to GE and should be protected accordingly. These sections are:
1)
Section 4.0, " Analysis": This section contains the description of n
the finite element models employed in the thermal and structural U
analyses, development of the material property functions, and development of boundary and loading conditions. This information represents the bulk of the computational techniques developed by GE to analyze shipping packages using the LIBRA computer program.
Public disclosure of it would allow GE competitors to apply the LIBRA program in their packaging program with minimal developmental cost.
2)
Section 5.2.1, " Energy Absorbing Characteristics of Overpack Toroidal Shell": GE feels this section is proprietary because, the method employed and results to determine the deformation characteristic of the toroidal shell are presented.
GE competitors, with little effort on their part, could apply this method to employ a toroidal shell as an energy absorbing device.
3)
Appendix B, " User Defined Subroutine CHGPROP":
This appendix presents the computer listing of the LIBRA program subroutine developed by GE. This subroutine contains the material properties relationship of the thermal model as a function of temperature and represents a significant portion of the developmental work performed by GE.
4)
Appendices C, D, and E: These appendices show in detail the FE models employed throughout the analyses. This information includes element size, type and material assignation.
These appendices were U
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included on the report, not only to present the reviewer with a (V) detailed description of the three major FE models employed but also
'as a permanent record for GE to use. Disclosure of this information would allow GE competitors to short cut development of similar models for the analysis of their packages.
5)
Appendix F: This appendix shows how the two major FE models employed in the structural analyses corres;ond to each other despite difference in the element selection and mes'1 density. Disclosure of this information would allow GE competitors to employ hereto for unavailable substructuring techniques in analyzing their packaging.
6)
Appendix G: This appendix describes how the loading produced by the i
side drop event is transferred from the package overpack onto the cask surface and how the cask is then analyzed. The non-symmetric nature of this loading condition makes its analysis complex and costly. Therefore the simplified approach developed by GE and presented in this Appendix-is of significant value to GE.
Disclosure of it would allow GE competitors to employ this approach without the use of substantial resources.
7)
Appendix H:
This appendix shows how the cask bolt stresses were determined from the results of FE analysis with the model representing the seal region. Disclosure of this section would give GE competitors a new methodology to treat similar problems in their package program.
8)
Appendix J:
The top and bottom parts of the package overpack are joined together with a stainless steel function designed to withstand the forces developed in the overpack during the hypothetical accident conditions. -This appendix presents the model and the FE analysis conducted. GE believes that in view of the considerable resources that were employed by GE in developing the analytical technique presented in this Appendix that its disclosure would give significant advantage to GE competitors.
GE feels that all the information, sought to be withheld, is truly proprietary in nature.
Public disclosure of this information, sought to be withheld, would permit GE's competitors in need of similar Type B packaging design to apply the unique analytical procedure and methods outlined in this document without incurring significant development cost. This would place GE at a competitive disadvantage in providing design services and 1n making these Type B containers available to industry.
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STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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R. Villa, 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, information and belief.
Executed at San Jose, California this f2 ay of #cdbr,198[
R. Villa
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General Electric Company Subscribed and sworn before me this 2.2#oday of 6e /oseg 198f Y}
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0NA NOTARY PUBLIC, STATE OF SALIFORNIA SANTA CU.RA COUNTY My cort:m. expires CEC 30, 1983 O
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