ML20129E954
| ML20129E954 | |
| Person / Time | |
|---|---|
| Site: | 05000447 |
| Issue date: | 10/14/1983 |
| From: | Quirk J GENERAL ELECTRIC CO. |
| To: | Eisenhut D AFFILIATION NOT ASSIGNED, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127A304 | List: |
| References | |
| FOIA-84-175, FOIA-84-A-66 M-C-682, MFN-191-83, NUDOCS 8506060640 | |
| Download: ML20129E954 (10) | |
Text
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4 GENER AL h ELECTRIC NUCLEAR POWER SYSTEMS DMs!ON GENERAL ELECTRIC COMPANY
- 175 CURTNER AVSUE
- SAN JOSE, CAUTORNIA 95125
' M/C 682,~(408) 925-2606 NFN-191-3. #
October 14, 1983
(
U.S. Nuclear-Regulatory Commission Office of Nuclear Reactor Regulation N
Washington,-D.C.
20555 Attention:
Mr. D.G. Eisenhut, Director Divisi.on of Licensing
SUBJECT:
IN THE MATTER OF 238 NUCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORT (GESSAR II)
DOCKET N0. STN 50-447 SUBMITTAL 0FPROPRIETARYINFORMATIONINRESP0,5SETORE00EST
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FOR ADDITIONAL INFORMATION REGARDING SEVERE ACCIDENT REVIEW 0F GESSAR II
Reference:
C.O.- Thomas (NRC) letter to G.G. Sherwood (GE), " Request for Additional Information Regarding Severe Accident Review of GESSAR II," September 2, 1983 The reference letter req;ested additional information regarding the severe accident portion of GE's GESSAR II submittal.
GE's initial responses to all the questions, with the exception of 720.98, 720.99, 720.100 and 720.101, were included in a submittal on September 15, 1983.
Attached please find responses to 720.98, 7,20.99, 720.100 and 720.101.
In addition please find a correction to Table 1 of the responses to question 720.142.
Also attached is a report titled "GESSAR II 3 Diesel Generator Coccon Cause Failure Analysis."
This report is submittd in response to an informal NRC Staff reqdest.
We are requesting that the attached information be withheld from public disclosure and considered as proprietary pursuant to Section 2.790 of 10CFR Part 2.
Very truly yours, h.[ Quirk, Manager R Systems Licensing Nuclear Safety & Licensing Operation 8506060640 841203 Attachments g g g d -66 A
PDR i
cc:
F.J. Miraglia (w/o attachment)
C.O. Thomas (w/o attachment)
D.C. Scaletti (w/o attachment A. Thadani (w/o attachment c/
L.S. Gifford (w/o attachment
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4 e GENERAL ELECTRIC C 0 M P'A N Y 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 is contained in the proprietary responses to questions on 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 dif ficulty in acquiring informa-tion....
Scme 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 informatibn 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 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 advantage, e.g., by optimization or improved marketability; JFQ:r$/A10143 10/14/83
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O 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
'f 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 standar'ds 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 prcmptly furnished with significant or pctentially significant information.
Furnishing the document on a con.fidential 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 prmitting 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 originatintj 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 apprcval of external release of such a document is reviewed by the Section Manager, Project Managr, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or his delegate) and by the Legal Operation for JFQ: rm/A10143 L 10/14/83
L i._
_ 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.
3.~
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 provide additional information on the GESSAR II Probabilistic Risk Assessment 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:
'It was developed with the expen'diture of resources exceeding a.
$500,000.
b.
Public availability of this inftrmation would deprive General Electric of the ability to seek reimbursement, would permit competitors to utilize this information to Generel 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 give them a competitive advantage over General Electric by allowing foreign competitors to produce their containments at lower cost than General Electric.
..p-JJ 10143 1
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, i-nformation, and belief.
-Executed at San Jose, California, this d day of Oc}ose.e.,1983.
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Jp(epri F. Quirk Ghfieral Electric Company
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STATE 0: CALIFORNIA'
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COUNTY.0F. SANTA CLARA
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Subscribed and sworn before me this dday of Oc. tone.e,198,3
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10/14/83
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION s
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QUESTION 720.98:
-In Question 720.79 submitted in October 1982, it was stated that Unresolved Safety Issues (USIs) applicable to GESSAR-II should be evaluated in the PRA.
The response dated February 2,1983, stated that those USIs applicable to the 238 Nuclear Island have been assessed in Appendix IB to GESSAR-II, which was submitted as a portion of Revision 4 to GESSAR-II.
- However, those responses have not addressed the issues from the probabilistic standpoint, i.e., low probability, beyond DBA conditions.
Provide an evaluation of USIs from the probabilistic standpoint for inclusion in GESSAR-II PRA.
RESPONSE
As noted in the above question, Unresolved Safety Issues (USIs) applicable
- to the 238 Nuclear Island have been assessed in Appendix 1B to GESSAR-II, which was submitted as a portion of Revision 4 to GESSAR-II.
We agree that the evaluation can'tained in. Appendix 1B is primarily deterministic,
~however those issues which lend themselves to probabilistic treatment have been addressed in the GESSAR-II PRA, as noted in the following paragraphs.
1.
NRC Task A-1 Waterhammer The principal safety concern regarding waterhammer is that dynamic loadings may cause pipe failures.
It was noted in Section 1B.2.2.3 of GESSAR-II that none of the reported waterhammer events in BWRs have caused major pipe failures.
In the GESSAR-II PRA (Section A.1.2), the pipe break frequencies were derived from the WASH-1400 data base which included dynamic failures, such as those that could have been caused by waterhammer events.
Therefore, waterhammer has been implicitly included in the PRA event frequencies.
2.
NRC Task A-11 Reactor Vessel Materials Toughness Reactor pressure vessel failure rates and their treatment are described in Section A.1.3 of the GESSAR II PRA.
3.
NRC Task A-17 Systems Interaction in Nuclear Power Plants The s'afety concern associated with this issue is the potential adverse effect on the redundancy and independence of safety systems.
Systems interactions are explicitly included in the fault trees and event trees in Appendices C and D in the GESSAR II PRA.
4.
NRC Task A-40 Seismic Design Criteria and NRC Task A-46 Seismic Qualification of Equipment in Operating Plants Seismic issues have been addressed probabilistically in the GESSAR-II Seismic Event Analysis submitted September 21, 1983 on the GES,SAR-II docket.
- Identified as Tasks A-1, A-11, A-17, A-40, A-43 through A-48 in GESSAR-II SER (NUREG-0979).
10/14/83.
E, GENERAL ELECTRIC COMPANY
/
PROPRIETARY TNFORMATION 5.
NRC Task A-43 Containment Emergency Sump Reliabilitj The safety concern regarding this issue is the potential for plugging the ECCS suction strainers by dislogged thermal insulation.
Plugging of strainers is explicitly treated in the fault trees of the core cooling systems.in Appendix D of the GESSAR-II PRA.
6.
NRC Task A-44 Station Blackout Station Blackout is explicitly considered in the loss of offsite power event trees' in Appendix C of the GESSAR-II PRA.
-7.
NRC Task A-45 Shutdown Decay Heat Removal Requirements Task A-45 is designed to assess the need for improving the reliability of decay heat removal systems.
The loss of decay heat removal was
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explicitly evaluated in the GESSAR-II PRA, and the results indicate loss of decay heat removal is not a dominant event.
Consequently, improvements in the decay heat removal function would not significantly reduce overall plant risk, as discussed in the response to Question 720.113.
8.
NRC Task A-47 Safety Implications of Control Systems This i,ssue concerr.s the potential for the increased severity of transients or accidents as a result of control system failures or malfunctions.
The purpose of this unresolved safety issue is to define generic criteria that will be used for p,lant-specific reviews.
Failures in control systems or ccaponents have been included in the system fault trees in Appendix D of the GESSAR-II PRA.
9.
Hydrogen Control Measures and Effects of Hydrogen Burns on Safety
. Equipment (Task A-48)
-The safety concern is associated with the' generation and combustion of large quantities of hydrogen that may be produced in a degraded core cooling event.
The GESSAR-II PRA explicitly treats the generation and combustion of hydrogen and the potential effects on equipment in-Appendices F and I of Section 15D.3.
With regard to Task A-39, Safety Relief Valve Hydrodynamic loads, the pressure capability of the GESSAR-II containment design has been shown to exceed the maximum calculated safety relief valve discharge loads.
This mechanistic analysis precludes the need for probabilistic treatment.
4
-10/14/83,
t
' GENERAL ELECTRIC COMPANY-PROPRIETARY INFORMAT10N QUESTION 720.99:
The current GESSAR-II design of the boron injection pathway of the standby liquid control system (SLCS)'is through the lower plenum of the reactor pressure vessel (RPV).
When the RPV water level is below the top of active fuel (TAF) level following an ATWS event, with feedwater pumps tripped off, the boron circulation in-the fuel assemblies may be impaired due to steaming and evaporation occurring at or below the TAF level.
As a result,'the effectiveness of SLCS would also.be impaired.
Evaluate the impact on the failure frequency of SLCS and core damage probability in the GESSAR-II 238 Nuclear Island design.-
RESPONSE
The GESSAR II design of the baron injection pathway is through the High Pressure Core Spray line, not the lower plenum.
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 4
QUESTION 720.100:
In the GESSAR-II PRA,.the frequency and duration have been considered in the-loss of offsite power (LOOP) frequency.
However, there is another property (i.e., the degraded grid or partial failure of electrical contacts) which would cause damage to equipment while AC power is not
. totally l'ost, which have not.been considered.
Such failures actually took place at the Millstone plant.
Evaluate the impact of this failure mode on the LOOP frequency for the GESSAR-II 238 Nuclear Island.
RESPONSE
The question of protection a 8.3.1.1.7(8) gainst degraded voltage is addressed in GESSAR II Sect.
, (page 8.3-19a).
Additionally control circuit fuse sizing wherever specified in the controlling documents is based on protection of the control circuit wiring and is therefore large enough to maintain the circuit under conditions of persistent degraded voltage (i.e., voltage low enough that ac relays may not pick up).
Motor control center control transformer fuses are to be specified by the applicant /AE...This fuse size is to be compatible with inrush currents for MCC contactors so that no fuse failures (blowing) will occur under the degraded voltage conditions that could be postulated to persist-without tripping the bus undervoltage relays.
This capability is easily achieveable and readily verifiable.
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PROPRIETARY INFORMATION t
QUESTION 720.101:
Does offsite power include the output from the main turbine generator, which.is really onsite power of the preferred power kind? What is the relative reliability of the station generator output versus the incoming offsite power?
Could the critical load be carried by the onsite generator or by the station service?
Evaluate the impact of this distinction on the LOOP frequency for the GESSAR-II 238 Nuclear Island.
RESPONSE
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.l The LOOP frequency, as presented in the GESSAR II PRA is correct, for the above reasons.
P 10/13/83
GENERAL ELECTRfC COMPANY PR0RlETARY INFORMATION Rescanse 720.142
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TABLE 1 - ABSORPTION COEFFICIENTS PLANETARY ELLIPSDID SPERICAL 2
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2 IEERTIAL 3-UT'
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5 SEDIMENTA-3 gT 1
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b Vs 4
Ry 3
5 2
1.76 g
BROWNIAN 6/DU
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DU D1PFUSION
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(b 3
1+
4+2 l '-
a
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tan b
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U-Bubble Velocity 2
Fo 2
T-Stokes Characteristic time T=-
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g g-Acceleration due to gravity Pg - Gas V,iscosity
- p - Particle Density a = ellipse major axis
' Particle Radius b,= ellipse min 6r axis l
r l
P C, - Cunningham's. Slip Factor V
Swarm velocity R-sphendel bubble radius h
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