ML20127B126
| ML20127B126 | |
| Person / Time | |
|---|---|
| Site: | 05000447 |
| Issue date: | 12/29/1983 |
| From: | Rowsome F Office of Nuclear Reactor Regulation |
| To: | Mirgalia F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127A304 | List: |
| References | |
| FOIA-84-175, FOIA-84-A-66, FOIA-84-A066 NUDOCS 8401090189 | |
| Download: ML20127B126 (18) | |
Text
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DEC29 593 FEMORANDLM FOR:
Frank J. Miraglia, Jr., Assistant Director for Safety Assessment Division of Licensing FROM:
Frank Rowsome, Assistant Director for Technology Division of Safety Technology SUEJECT:
REQUEST FOR ADDITIONAL INFORMATION ON GESSAR-II PRA-Ccc re.niew of the GESSAR-II PRA has identified the need for acditional information relating to GE submittals on external events.
Our request is
- entained in the enclosure, part of which (questions on seismic events and
- endit G) have been given I
- and ciscussed with GE on No. ember 18, 1983.
In cecer for us to maintain tne review scheoule, we will need completely adecuate responses to those questions by Janua?y 30, 1984.
Please contact' O. D. Yue (x28129) of RRA6 should you have any questions.
/5/
Frank'Rowsome, Assistant Director
~
'for Technology Division of Safety Technology
Enclosure:
As stated Oistributien Central File RRAE RDG AD/T RDG AIhadani
$10/616/
)
Feaso-e
' ie cur:N
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- 720.150-Coes :ne GESSAR II seistic hazard curve rep esent the best estimate (p.15)?- Descrime the procedure's used to generate
'the GESSAR II hazard curve and the other curves shown in Figure 2.2 of your report.
720.151-(a)-In Section 2.3.3 it was indicated that the GESSAR-II seismic hazard curve was constructed as an " arbitrary bounding curve" of four best estimate curves from plant specific studies.
How does your " arbitrary boundary curve" take into account the possibility that hazard curves calculated for other plants in the eastern U.S. may exceed the GESSAR-II seismic hazard curve.
(b) Provide the supporting evidence and calculations used to' show that t'he GESSAR-II seismic hazard curve as stated in your report (p. 16) would bound "more than 80% of 3he potantial
-GESSAR-II sites."
720.152 Provide the supporting bases-for extrapolating thecexisting seismic hazard curves to cbtain as stated in your report on page 13, "a realistic median-centered upper-bounc curve" beyond 0.8g (p. 15).
. 720.153 Please elaborate on what is meant on page 12 of your report, "the seismic hazard capability,-represented here as a seismic ha70rd curve, is unique."
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.720.154 It _ has been indicated that the individual E' valu's were not estimated; e
however, the combined E for the ot'erall median factor of safety was established _on the basis of engineering judgement.
Therefore, to
'better understand this process and its adequacy, provide a detailed analysis for one cf the p values by examinir.g individual comptnents
, -with a comprehensive discussion'of the site-specific effects.
720.155 Describe the procedure by which the specific structural ccmp6r.ents were selected to evaluate the fragility of the seismic Category I structures (for example, how the flexural capacity of the auxiliary
. building was' derived).
720.156_ Discuss the possible effects of the interaction between the buil di'ngs.
Also, include interaction between seismic Category I and non-Category I structures.
Discuss the plant-specific features and structures which may need 720.157 4
to be evaluated as far as tne structural fragility investigations are co'ncerned.
Provide the interface requirements for plant-specific application (for example, interface requirements for the steel vessel containment which will be designed by.the future applicant referring to GES'SAR).
~
720.15E The relationship given in the Section 3.2.3.1.3 between the ductility and the inelastic energy absorption factor appears to be independent of the damping.
Similarly, it is not clear whether the interaction between duration, damping and the inelastic energy absorption has been considered.
Provide discussion to indicate how individual factors of safety and the logarithm of the standard deviation accounts for interrelationship between these parameters.
720.159 The general fragility model is based on the simple assumption of the multiplicative model which implies independence between individual factors of safety.
As this method has been unverified, discuss how you assured that the overall factor of safety resulting from that approach and associated standard logarithm deviation are reasonable.
720.150 It should be noted that duration effects are dependent upon the magnitude of the earthquake, how did you consider this relationshio?
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720.151 P c.ida d :2' led calculaticr.s su;;crt-:r; fragility values preser.:cd
' n Tables 3-2 thrcu;h 3-19.
i The applicant should discuss the considerations given to the 720.162 pertinent geotechnical parameters in developing factors of safety associated with fragility analyses.
Specifically, the applicant should address the contributions of the geotechnical parameters to the degree of uncertainty associated with each factor cf safety. '
.720.;53 The appli:ar.t should discuss the uncertainties associated with the
.following potential site-specific external-events-related' failures on the core-r.elt probabilities:
(i) liquefaction of site soils, (ii) differential settlements affecting structures, systems and components failures, (iii) corsideration of dynamic earth pr,essures beycnd these considered in the design, and (iv) slope failures affecting performance of ultimate heat sink functicr.s.
d The se'.snic leading to be considered in the analyses cf ita. s r.entici.ed above should reflect leading beyond the" seisr.ic ir.put considered in ths GESSAR II design (up to 0.95;).
The applicant shculd also justify the applicability of these analyses en a generic basis to all potential sites meeting GE55AR II design criteria.
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720:164 It is not clear that the applicant has considered the p ssible failure of ren-safety related structures or ecuipnent which could ir. pact on se#ety-related items.
The applicant is recuested to provide a descriptien of the procedure of evaluating the effects cf f ailures of r.on-safety related structures or ec.uipnent en safety-related stru:tures and saf.ety-related piping systems and comconents and their supports, which could lead to a possible core r.el tdown.
720.165 It is not clear that the applicant has considered the possible failure of piping systers and'cenponents due to differential neve ent or tiltirg of structures.
In addition, it is not clear how the applicant has censidered the failure modes of buried pipirg which may be influenced by gectechnical parameters, e.g., soil amplificatien.
The applicant is requested to confirn that these effects which could eventually lead to a core meltdcwn, have been censidered and included in its evaluation.
Alternatively, provide the basis fcr not considering them.
720.165 With resoect to design and construction errors, the staff concern is that these errers (e.g., concerns of IE Bulletin t.o. 79-14, Seist.,ic Analyses for As-Luilt Safety Deleted Piping System) may becone important in the seismic fragility analysis for pioing systems and components. Provide sensitivity analysis to show the impact of design and construction errors 'n the seismic fragility
~
o analysis.
720.167 There are several essential piping systens which are required to deliver rated flow and be designed to retain dimensional stability when stressed to the allowable limits associated with the emergency and faulted conditions, e.g., the functional capability of the piping is reouired to be demonstrated.
It is not clear that the applicant has censidered the functional capability in its evaluation of piping failure modes.
The applicant is requested to assess its evaluatien given the above concern.
720.163 There are several safety systers corrected to the reactor crolant pressure bcundary that have desien pressure below the reactor coolant system (RCS) pressure.
There are also some systens which
,are rated at full reacter pressure on the discharge side of pur;s but have puto suction below RCS pressure.
In order tc protect these systems frer RCS pressure, two or rcre isolation valves are placed in series to forn the interface between the high pressure RCS and the low pressuee systems.
Failure of these isolatien valves (frer eitner excessive leakage or ru;ture) will allow are high pressure reacter cc:lant te corrumicate with the low-:ressLre pipir.g outside of containrent.
Ru;ture of the low-pressure syste-wculd result in loss Cf reactCT CcClant c.05 ice of certainnEr! a5C p:ssible co e rc'ic:wr.
It is n:t clear hev. the arelicant has ccesidered t"? ateve concern in it! evaluatice cf valve failure r :
-5.
The 1::lica-t is recuestt: te assess its esaltat :r gi.er J
tre a::ve cc trn.
720.169 High fragility values of structures and components (35g for pedestal shear, Table 3-3; 8.4g for RPV Shirt bolt, Table 3-12) are indicated.
These values should initiate an overall failure e.:de such as foundation failure, a ground stability pecblem etc.
~
' There should be a cap on structures and compcnents fragility level that it consistent with an overall failure mode.
720,170 Fragility estimates for components whose seismic failure could lead to a core melt should be examined in some detail.
This could be accomplished by looking at similar components from an actual plant /
reference plant.
In addition, sensitivity of the seismic contri-bution to core melt due to a shift in the capacities of those components that are very near the capacities of the critical components should provide greater insights into the robustness of GESSAR design, for example shroud support, CRD Guide Tube, Hydraulic Control Unit, Electrical Power etc.
A detailed look at fragility estimates should highlight the local response values in teres of accelerations and corresponding frequency range of critical / controlling components such as relays, contactors, breakers, control logic elements etc.
720.171 In order to understand the influence of earthquakes on the course and consequence of a severe accident it should be clear in our minds whether or not the earthquake happens before or after the accident.
If the accident occurs after an earthquake,,we should consider the effect of the earthquake on the consequences of the accident, for example the f ailure of the stack may cause ground level release of radioactivity, buckling of steel containment can affect its ability to prevent leakage through large penetrations.
Should the accident occur prior to the earthquake, fragility levels for certain parts lyf containment can.be substantially affected because of the accident loading. Provide an assessment of the impact of after shocks following severe earthquake on a core damage frequency and risk.
720.172 Assumptions regarding leak path and behavior of locks, seals and 0-rings are very much influenced by time at temperature.
- Also, certain' types of details can be more prone to deterioration due to temperature.
Inflatable seals are generally exposed to local temperature effects such as in personal airlocks for some plants.
Detailed discussion regarding leak path and orientation and design of critical penetrations is necessary to assess the protection available in the GESSAR design against, severe accicent.
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o 720.17.3 Identify any new equipment and modification to specific plant features that if incorporated have a high potential for risk reduction relating to seismic events, fire, and internal floods.
720.174 Indicate what interface performance specifications are envisioned to compensate for the lack of design detail in the
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BOP features.
720.175 Provide basis for not considering variations in the construction material of the containment basemat or variations in the ultimate stre'ngth of containment.
720.176 Following a postulated severe earthquake, assuming the following structures and systems have failed, (a)
Loss of offsite and onsite AC power, (b)
Scram discharge volume pipeline breaks, (c)
Failure of 50% of control rods to insert, (d)
Small pipeline breaks inside and outside of-the containment, (e)
Small c. racks.in the condensate storage tanks and the suppression pools, (f)
Failure of the offgas treatment system, followed by manual isolation from the main condenser, provide a PRA of the synergistic effects of those events, including fault-and event-trees, and estimate the core damage probability and offsite risks relating to the accident sequences of those events following a severe earthquake.
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720.177 The ultimate capacity calculatiens by GE for the steel contain er.:
based on limit analysis using the ultimate strength of SA 516 grace 70 steel may be questionable.
Please provide justification fcr -
su:h an approach.
720.178 The discussion on fracture, especially in weidments is not presented in a manner that could be evaluated.
The contention that cracks will develop only when stresses are between yield and ultimate strengths should be justified.
720.179 The use of Equatien G.S.25 for calculation of buckling of the knuckle region geometry should be justified.
It is also not clear how therral effects are factored into the calculation.
720.180 In reviewing the pressure tine curves for hydrogen detonation (i.e., Fig. G.10-1) with the 5NL accident analysis group, we were told that the figure may not represent the time pressure phenomen:n accurately.
Any impact due to the inaccuracy of the time pressure phenomenon on the containment capacity should be further assessed.
720.151 The use of dynamic load f' actors to represent the dynamic effects of H detonation in the analysis of complex structural systems uh.dergoing large plastic deformations is questionable.
Provide a discussion to justify such a usage.
720.182 PP.597:
The loss of integrity has been assumed te occur when eitner the ultimate tensile strength in the high stress region is reached-or cracks develop.
Reasons for not using other criteria, e.g., maximum strain in the steel containment, are not given.
Please discuss the basis for not using other failure criteria.
' I 720.183 PP_Enni Detailsofdeterminingthecracksizeincentrete(__
id gW
___,,Are n:t provided.
Provide the basis for the crack s;ze ot '.e rmi na ti o n.
720.184 FP.607:
Ter erature range that was cons'idered in the analysis has nct been icer.tified.
Please identify the range and the basis there-of.
720'.185 FP. 609:
Details of stress calculations in the knuckle region p acie E.2-1) are not given.
Provide details of the stress calcu-lation.
7 2 0. '. E t FP. 609:
f c- ;1a for d' in the c:lur.n f or P. sh:- lc tg pr/2h insteac cf pr/h.
In thI sare celu n 0; sncaic te repia:ec ty C.
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720.1 E 7 Del e te d.
720.188 P'P.. 611:
The ring-s'tiffeners and the trant-girder used in the finite element mocel (Figure G.2-2) are not described in the report.
Please describe these items in sufficient detail for use in analysis.
-720.189 PP. 616:
The calculations.'for P in Region 4, and fo.r P( + Pb I"
Regions 1, 3 and 4 need to be clErified.
720.190 PP. 619:
It is not clear what the compatibility condition (Eq.
G.4-3) represents.
Provide a discussion.
720.191 PP. 620:
Details of the pressure
- carrying capability of the ECCS lines are not given.
Please provice a more detailed discussion.
.720.192 PP. 655-The details of the calculation for p
)
Id 3
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snouic be provided.
1 720.193 PP. 655 & 655:
The notation used in Eq. G.9-2 is not consistent w;tn Eq. G.9-3.
.In Eq. G.9-2. F (s) should be replaced by f (s) and x should be replaced'by s z
720.194 PP. 656:
How was the expression for the ultimate nement (i.e.,1.5 Mo +. ( 5
/Sy - 1) Mo] derived?
lt 720.195 PP. 656:
What do the cases A, B and C represent?
Please explain.
'720k96 PP. 659:
What is the basis fo/
lhowninFig.G.9-1?
Id h,
Please provide a justification.'
720.197 PP. 659:
What is the definition of " normal deviation" in Fig.
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G.9-1 and Fig. G.9-27 l
720.198
's How does the Appendix G fit into PRA analysis?
How are the results
[
of Appendix G utilized in PRA?
What specific end products of l
Appendix G are required by PRA?
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720.199 Provide bases and calculations that backed up the resuits of pressure capabilities listed in Tables 6.1-1 and G.1-2.
Also explain how truttonclusion that. "when tne acclied internal _. pressure j
iL5c.5 ps_ig,
'y is' arrived at.
4d 720.200 Provide backe :und inforcation of the ASHSD ccm? uter program (Ref.
G.2-1).
Can this program, which is based on axisy retrical finite ele,er. shell m::el, be used for n:n-axisyrre.rical icading?
If yes, please e> plain how it is a:hieved.
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720.201 Indicate the significance and location where various stresses listed in Table G.2-1 occurrsd, such as P, P), P ' 0' 'IC' b
722.2 2 At,the lower portion of containment shell the S.' concrete shell has teen treated as " thin" shell (Eq'uations G.4-2 and G.4-3).
What r.acnituce of error has been introduced by this assumption?
cc ;are the calculated capability pressure of 74.9 psi (p.15.D.3-E19) with
-he calculation cf the stress in the steel shell when the concrete wa,ll,is treated as thick shell.
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720.203 Del eted.
720.204 NE 3133 of ASMSection III code consists of design formulas and procedures for shells under external pressure.
It is not clear what is meant by "the buckling criteria given in NE 3133."
(p.
15.D.3-535). ^
720.205 It is not ' clear how the failure mcde of maximum shear be ccnsidered.
It is mertioned in Section G.2, but not in G.E.
720.206 Define X, in Eq. G.8.10 and P in Eq. G.B.25.
Is Q in Eq. G.8.4 transverse shear or in-plane Ehear?
There are mixed-ups of notations in App. G: 6" has been used for stress and standard deviations; P for pressure, load, and probability; and stress can be #, S, or f.
720.207 What is the relation 1$~etween : loss of integrity and ' failure'?
What is the difference between " fracture" and " crack"?
What is
- " plastic yield"?
Is it something different from " yield" or
" elastic yie3d"?
723.208 What a're tne. bases of making the following assumptions?
\\-
- a.
Structurel capability ' depends only on geometrical dimension and vield str'eneth of material.
b.
Normal-distribution of probability cf yield and ultimate s rength.at testing.
c.
Preb3bility of deselcping cracks varies linaarly be wean 5 ard 1
< lt*
- u d.
Only 6'
= 0.2 i and 6' = 0.15 'x are censidered.
x X
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qwe 4
S
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is
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720.20g L' hat is the physical significance that DLF is less than 1?
Should i
ce re:uire: tr.at sta-ic loac be used when D;F is less -han 1 such as the case indicated in Table G.10-5?
- 720.210 Describe how and why does a local detonition affect the structural response (e.g., location and distribution of the pressure pulse, shock wave propagation and refraction / reflection, thermal effects) and how are the dynamic load factors obtained.
Indicate locations of potential failures in containment _o~r at drywell and the probabi_lity corresponding to each failure.
720.211 In assessing the response to non-condensible gas generation or to local and global hydrogen combustion, it is stated that loss of containment integrity wculd eventually occur in the torispherical dome region (15.D.3-661,662).
What are the physical failure boundaries? How would it affect the release of. radioactive material to the environment?.
720.212 If the pressure-carrying capability in the torispherical region is significantly higher than that predicted by the analysis, what.
would be the wcrst impact on. steel containment due to a hydrogen detonation?
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d.
720.213
-The specific GESSAR design seems to have minimized the
~
possibility of a fire causing both an initiating event and disabling the mitigation systems..The analysis performed by GE indicates that the dominant contribution to failure of mitigation systems will be due to random failure of components rather than the impact of fire.
Hence, for a fire PRA performed under this condition it is.necessary to include all the areas for which a fine can cause initiating events into any study of the estimations of proper residue core melt probability, regardless of the impact of fire on the mitigation systems.
Provide an assessment of the impact on the core damage frequency from such considerations.
720.214-Due to the fact that the GESSAR fire PRA takes credit for rated barriers as a strong fire propagation prevention measure, it is important that the adequacy of barriers.and penetrations be systematically analyzed.
Provide an assessment of the impact due to such considerations on the core damage frequency.
720.215 Since almost half of the cabling in the GESSAR plant is routed thro ~ ugh conduit embedded in concrete, it is'important to consider fire progagation to adjacent arens through migration of cumbustible vapors in conduit.
Provide an assessment of the impact due to such considerations on the core damage frequency.
720.216
.For a plant design such as GESSAR it is strongly recommended that a fire area adjacency matrix be constructed to assess effects of high fuel load areas contiguous to critical areas.
Provide an assessment of the impact due to such considerations on the core damage frequency.,
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720.217 Smoke propagation to the control room or the remote shutdown panel should be considered.
Provide an assessment of the impact due to such considerations, including human error probability, on the core damage frequency.
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4 720.218 On c. 2-1 cf the fire analysis, it was stated that a screeninc process was used to identify critical' fire locations.
Provide criteria used in the screening process.
920,219 The probability of loss of offsite power 4cgether =ith tne pr::a3111ty :f l
fire in the diesel ger.eratcr when ru ning has to be considered (r.ct star.cty mode).
i The probability of diesel catching fire /:er deund
- 7.3x:0-4 Pr:basility of loss of offstte :o=er (LOS F) = 0.3 /ytar, j
LOSP A fire in one diesel ger.erater reom::2.1x10-4
~
Provide an assessmer.t Of the impact cn core dame. e fre:vency and risk.
i20.220 The P fact:r is net an appropriate partneter to be inecrporated sia.ce i-does not relate the Gl:5584 plant to tne data scurce, if used at all the factor should relate the avaliable fuel surface area (n:t ;roje:ted ares) of the GESSAR geomtry to the saee quantity in areas froes w".ich fire initt4 ting data was takea.
In other =:rds to use the GISS28. plant-s;er.1fic P-factor, the. plant-specific P-facter from which the fire-fre: ency data was culled should be factored into the area-specific fre;.;ency estimates.
I20.221 A factor of 4 reduction for the Zone-I cerridor ard electrical etuf; rent roan ignition probability is taken into account based on the ses11er actual area of these reons in GESSAR plant compared to'other NPPs.
If the fatter of 4 reduction is used, then it is not clear why cnly the Zone-1 Corridor is inchded in the analysis and the Zoa.e-2 is esc 1cded.
'20.222 It is claimaid that the resultant ignition frequencies as def'ned in this report are more consefvative relative to those defined in the Lnerick evaluation (P-2-il).
That may not he true in all cases.
F:r example, in the cpntrol equt;me..t room there are la power generation c:ntr:1 cypieses and termination cabinets, hence Id 18x2.2x10-4 7 3.:E-03 wnere GESS:R usert.'
}
3#
Provide a list of cases in which results in GESSh -li areInon-censervativ$g and assess its i :act..
20.223 It is net clear bow fire :rewth tine-wss estirated to te 12 t.ws sa:res-
'sion ttw f:r fire pre;s;stic-thrc-;h a 3 5'ur wall 50 f t of c:..t. 31 reon ar.d ar.ct5er 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> *sil.
0 e ;: ssibility is to est'. ste ge:=:n t re as 360 min. fer t'e 2. ree ' cur carrie. s p1,,s ac:ut ;0 n' utes fer t e separatien (33 nir.ates ta each 20 f t.').
T h i s, c r. ' n e.1 t ' u. e o f n everaT) average su;;ressio-ti-= cf 39 miautes - vis resJ t i, a grx./
s-;;ressic" t '9e rat o of 11.5 mi ste s.
- as int s tne reas 7.t ; use:?
f0.224 fire re age to reds:a. ::ns.:..s/
On page 2-13 m t*e r
4511i';
'-e te 0.5x5.r!0 b =ai:2. 5 d 5.:(
dsstete:? E x s i a "' ?
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720.225 In control room and control equipme-:t room tne fire scenario is not clear.
The suppression prcbabilities ar.d growth times are similar to the Limerick Fire PRA for the situation where a cabinet fire prcpagates out of the cab 1-net and ignites cabling at the top.
.Mowever, this situation seems not t:
exist in the above mentioned rones, A.
Why is presagation to cables considered? Aretheseexbosedcablescc are the cables considered internal to the ad;acent ranel?
B.
What rational was used to conclude tr.at panel prcpagatien nas a higher probability than cabinet propagatien?
C.
Wr,ere is Figure A referenced en case 2-14?
D.
The cited Limeri:k calculatien for transient comb; stables (paper) cc -
sidered the igniticn of cable insulation located 10 f t. accve the fire.
How does this relate to the cabinets and panels in these areas?
720.226 In the electrical equipmer.t room the cited C0" FERN evaluatien in th Limerick PRA, yielding a 10 minute fire growth and a failere pr:babil~ity to suppress of 0.4, considers a self icnited cable tray fire propagating to ar.cther cable tray 5 f t. ateve.
He ever, tnere are no exposed cables in this rown.in the GESSAR-II design.
Explain the GESSAR-II design.
- 720.227.
It is net clear why in some scenarios barrier failures are c:nsidered vnen in cthers they are not.
For example, in the control e'quipment r:on t".e possibility of barrier failure and propagatier of fire to the electrical l
equi pper.: room 5as net been considered.
What is the criteria for carrier failure?
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720.228 It is net clea.r which initiating eve its are asscciated with each critical fire area. Please clarify.
720.229 In the auxiliary building electrics' enaipre rcce a.d t5e cable t r. ei the necessity of corsi:ering trans'e-comb..tt 1:!e esecsure f *es is i
incitetec in TaDie 21., tot no a a'.+tes are :rese-ted.
Please provice the analysis.
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i 720.230 For all critical locations, consider _ed in he analyses given in Section f
2.4.2, explain the following:
thich initiating event (transtant) results as a consequence of the a.
fire?
b.
bich transient-mitigating systems (if any) are disabled by the fire?
This information should be given for the case in which the fire is suppressed and for the case it is not suppressed.
Do the fires in their critical locations cisable cables wh'ich sup;1y c.
the K S?
720.231 In page 2-14 it is stated that the control r,oom is assumed to be non.
f%erettmal during a fire in the rows.
However, in the corresponding ev-ent true (Fig. Z.7) it is assumed that the' control com is non-functional only if the fire is not suppressed.
Explain this difference.
720.232 In event tree for the control rom (Fig. 2.7) and for the control equip-ment room (Fig. Z.8) it is assumed that for a shutdown fra the rarmote j
shutcknet panel all systems (HPCS, RCIC, CPCI, RPCS', CIS, ADS, PCk, and mm) are potentially operable from that penal. However, in the GESSAR-II
- SAR the only systes controlled fror: the remote shutdown panel are:
1 EIC, one RHR loop arte 3 non-ADS SRYs.
Explain this difference.
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20.223 In page 2-15 it is stated that the " failure to safely shutdown from the runote shutdown panel was taten to be 1x10-3 frczn 40 REG-1278*.
Explain dh how this value was obtained.
-F
,720.234 In Figia es 2.14 and,2.15, the unavailabilities usec for the HPCS' and for the RCI aWTrAller than the ones used in the Il internal events
. ' Explain tnis ci f f erence.
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- i: res 2.14 and 2.15, the tr.a.ailability cf tFs
If so, explain the value obtained for the ADS unavailability.
If not, explain what is meant by loss of one division of power.
720.236 Provide an assessment in terms of core damace frequency and risk of an ' inadvertent operation of the fire sprinkler system as a potential initiating event of internal flooding in the GESSAR-II design, given the fact that there is present a laroe number of electrical equipment which is not qualified for adverse environmental conditions in he vicinity of the sprinkler system.
720,227 Provide an assessment in terms of core damace. frequency and risk of the flooding of diesel generator and turbine buildings following a severe earthquake and a loss of offsite power.
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GENER AL4 ELECTRIC NUCLEAR POWER SYSTEMS DMslON GE NEW E.ECW. COMD ANY e ' 75 CUCTNEC AVENJE o SAN JOSE CAldODvA W21 M/C 682, (408) 925-2606 MN F-007-84 JN F-003-84
, January 19, 1984 U.S. Nuclear Regulatory Comission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Cecil 0. Thomas, Chief Standardization and Special Projects Branch Gentlemen:
SUBJECT:
IN THE MATTER OF 238 NUCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORT (GESSAR II)
DOCKET NO. STN 50-447 SUBMITTAL OF PROPRIETARY INFORMATION SUPPORTING SEISMIC FRAGILITY ANALYSIS Attached, please find the detailed information supporting the GESSAR II Seismic Fragility Analysis requested at the January 9 and 10, 1984 meetings held in San Jose.
A copy of this information has been provided to Benjamin &
Associates.
We are requesting that the attached information be withheld ~from public disclosure and considered as proprietary pursuant to Section 2.790 of 10 CFR Part 2.
Very truly yours,
(:
L-003 flI J
uirk, Manager R Systems Licensing C & &E: a P DA y
Nuclear Safety & Licensing Operation Nssc N T).5 ON Attachments yMCp cc:
F. J. Miraglia (NRC) w/o attach.
L. S. Gifford (GE-Bethesca) w/q attac-D. C. Scaletti (NRC) w/o attach.
J. Reed (Benjamin & Associatess w/o att3:=,
A. Thadani (NRC) w/o attach.
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GENERAL ELECTRI'C C0MPANY AFFIDAVIT
-I,, Joseph F. Quirk, being duly sworn, depose and state as follows:
1.
I~am Manager, BWR Systems Licensing, Nuclear Safety & Licensing Operation, 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 pertains to the proprietary submittal on the GESSAR II Seismic Event Analysis in support of the Severe Accident portion of the 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II).
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 informa-tion....
Some factors to be considered in determining whether given information is one's trade secret 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 to 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 efit 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 license from General Electric constitutes a competitive economic advantage over other companies; b.
Information consisting of supporting data and analyses, includ-ing test data, relative to a process, method or apparatus, the application of which provide a competitive economic advant.ge, e.g., by optimization or improved marketability;
I>
n c.
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; 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.
5.
In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence 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 all 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 or 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.
7.
The procedure for approval of external release of such a document is reviewed by the Section Manager, Project Manager, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or h'r, delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the s
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 document 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 i nf o r,mati on in support of the severe accident portion of GESSAR II contained in Section 150.3 of the GESSAR II submittal.
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.
11.
Public disclosure of the information sought to be withheld is likely to 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
$500,000.
b.
Public availability of this information would deprive General Electric of the ability to seek reimbursement, would permit competitors to utilize this information to General Electric's detriment, and would impair General Electric's ability to maintain licensing agreements to the substantial financial and competitive disadvantage of General Electric.
c.
Public availability of the information would allow foreign competitors, including competiting BWR suppliers, to obtain containment information at no cost which General Electric developed at substantial cost.
Use of this information by foreign competitors would given them a competitive advantage
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over General Electric by allowing foreign competitors to produce their containments at lower cost than General Electric.
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v-4 STATE OF CALIFORNIA
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COUNTY OF SANTA _CLARA
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Joseph F. Quirk, 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 h day of 7pAfftARtf,198ME
.J edh F. QIirk neral Electric Company Subscribed and sworn before roe this d day ofdAhlt1Al2] 198f Jelse) b, Y ed/ A lb&
NOTARY PUBLIC, STATE OF CALIFORNIA JFQ:ca1/K01179 oececoceaecocococeeeeeeesoce!
OFFICIAL SEAL
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9 NOTARY PUSUC.CAUFotNIA KAREN S. VOGELHUSER I
SANTA CLARA COUNTY My Commisson Empires Dec. 21,1984 oooooooooooooooooooooooooocC