ML20129F022
| ML20129F022 | |
| Person / Time | |
|---|---|
| Site: | 05000447 |
| Issue date: | 10/31/1983 |
| From: | GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20127A304 | List: |
| References | |
| FOIA-84-175, FOIA-84-A-66 NUDOCS 8506060661 | |
| Download: ML20129F022 (37) | |
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/.3 PROPRIETARY INFORMATION i
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GESSAR II FIRE AND FLOOD EXTERNAL EVENT ANALYSIS
- 0. Gokcek P.F. Nelson D.A.Hankins K.W.Holtzclaw Approved by: '
A' proved by:
d'4V R.J. McCandless C.D. Sawyer Manager, Availability Manager, Systems Engineering Integration Engineering
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION GESSAR II FIRE AND FLOOD EXTERNAL ETENT ANALYSIS CONTENTS PAGE Executive Summary vi 1.0 Introduction 1-1
1.1 Background
1-1 I~
1.2 Approach 1-3 1.3 References 2.0 Internal Fire Analysis 2-1 se 2-1 2/1 Introduction 2-5 2.2 Fire Hazard Analysis 2.2.1 Critical Fire Location Screening 2-5 2.2.2 Fire Sources 2-7 2.3 Fire Occurrence Frequency 2-10 2.4 Fire Propagation and Suppression Analysis 2-12 2.4.1 Assumptions and Procedures 2-12 2.4.2 Fire Analysis by Location 2-14 2.4.2.1 Control Room 2-14 2.4.2.2 Control Equipment Room 2-15 2.4.2.3 Electric Equipment Room (Control Building) 2-15 2.4.2.4 Cable Tunnel 2-16 2.4.2.5 Auxiliary Building 2-16 2.5 Quantification of Fire-Induced Accident Sequences 2-17 2.6 Release Frequency Analysis 2-18 2.7 Results 2-19 2.8 References 2-20 i
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 3.0 Internal Flood Analysis 3-1 3.1 Introduction 3-1 3.2 Flood Hazard Analysis 3-3 3.2.1 Containment Building 3-4 3.2.2 Drywell 3-5 3.2.3 Auxiliary Building 3-6 3.2.4 Fuel Building 3-7 3.2.5 Radwaste Building 3-8 3.2.6 Control Building 3-9 3.2.7 Diesel Generator Buildings 3-10 3.2.8 Turbine Building' 3-11 3.3 Accident Sequences 3-12 3.4 Release Frequency Analysis 3-13 3.5 Results 3-14 3.6 References 3-15 4.0 Other External Events 4-1 4.1 References 4-2 5.0 Summary and Conclusions 5-1 4
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION GESSAR II FIRE AND FLOOD EXTERNAL EVENT ANALYSIS LIST OF TABLES TABLE TITLE PAGE 2-1 GESSAR II Fire Analysis - Critical Locations 2-22 2-2 Exposure Fire Range 2-23 2-3 Fire Initiation Frequencies for Critical Locations 2-24 2-4 GESSAR II Fire Suppression Systems 2-25 2-5 Results of Event Tree Analysis 2-26 2-6 Release Categories for Fire-Induced Core Damage 2-27 Sequances 3-1 Release Categories for Flood - Induced Core Damage 3-16 Sequences
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION GESSAR II FIRE AND FLOOD EXTERNAL EVENT ANALYSIS LIST OF FIGURES FIGURE TITLE PAGE 2-1 Tasks of GESSAR II Fire Analysis 2-28
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2-2 General Plant Layout
-30 2-3 Location of Major Equipment 2-4 Reactor, Aux. & Fuel Buildings - Floor Plans 2-31 2-5 Reactor, Aux. & Fuel Buildings - Floor Plans 2-32 2-6 Control Building - Floor Plan 2-33 2-7 Accident Sequence Event Tree - Control Room 2-34 2-8 Accident Sequence Event Tree - Control Equipment 2-35 Room 2-9 Accident Sequence Event Tree - Electrical Equipment 2-36 Room (Control Bldg.)
2-10 Accident Sequence Event Tree - Cable Tunnel 2-37 2-11 Accident Sequence Event Tree - Electrical Equipment 2-38 Room (Auxiliary Bldg.)
2-12 Accident Sequence Event Tree - Zone 1 Corridor 2-39 2-13 Failure of Reactor Emergency (Shutdown) Core Cooling 2-40 with all Safety Systems Available e
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION GESSAR II FIRE AND FLOOD EXTERNAL EVENT ANALYSIS LISTOFFIdVRES(Continued)
FIGURE TITLE
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PAGE 2-14 Failure of Reactor Emergency (Shutdown) Core Cooling with Division 1 and 4 Power Unavailable 2-41 2-15 Failure of Reactor Emergency (Shutdown) Core Cooling with Division 2 and 3 Power Unavailable 2-42 3-1 Ac61 dent Sequence Event Tree - Diesel Generator Building 3-17 3-2 Accident Sequence Event Tree - Turbine Building 3-18 3-3 Reactor Plan 3-19 d
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v GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION EXECUTIVE
SUMMARY
===.
Background===
The purpose of this submittal is to provide an analysis of the capability of the GESSAR II design to accomodate fire and flood evtSts which may pose threats as initiators of core damage sequences.
This submittal is provided to meet the intent of the NRC draft Policy Statement on Severe Accidents which requires the considerat-ion of external events for standard plant certification.
Fire and Flood Analysis The GE assessment of fire-and-flood-initiated core damage frequency and offsite risk employed deterministic evaluations of fires and floods as bases for hazard analysis.
Estimates were made of occurrence frequencies and accident sequences were developed and analyzed to establish contributions to core damage frequency.
Fission product release fractions were computed for evaluation of the impact on offsite consequences.
vi
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION Results The core damage frequency and plant risk for GESSAR II attributable to internal fire-initiated events were 7.5 x 10-8/yr and 2.6 x 10-7/yr, respectively.
The core damage frequency and plant risk
- for flood-initiated events were 6.4 x 10/yr and 1.7 x 10 /yr. respectively.
-8 Conclusions The GESSAR II plant design provides substantial capacity to protect against fire-and-flood-initiated accident sequences.
The calculated core damage frequencies for fires and floods are very small fractions (2% and 0.1% respec-tively) of those calculated for internal events.
Fire and flood initiators are insignificant contributors to plant risk.
- The term plant risk used throughout this report has units of mean latent fatalities per reactor year.
l vii l
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION
1.0 INTRODUCTION
This section provides the background and describes the approach utilized in the GESSAR II analysis of fires and floods and the consideration of other external events.
1.1 Backaround In March, 1982, a Probabilistic Risk Assessment (PRA) of the BWR/6 Mark III Standard Plant de' sign was provided to the NRC to aid in the NRC staff evalu-ation of that design relative to severe accident issues.
The PRA did not
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consider the effects of external events, such as earthquakes, fires or floods in the evaluation of plant risk.
The capability of the GESSAR II design to accommodate seismic events was subsequently considered and documented in Refer-ence 1.
This report considers additional external events to meet the intent of the NRC draft policy statement on severe accidents, which includes the consider-ation of seismic and other external events as requirements for standard plant certification (2)
The impact of fire occuring inside the plant and flooding from sources internal to the plant are evaluated in this report.
As evidenced by the nature of these events, the term " external" relative to these events does not refer to the physical location relative to the plant, but is intended to indicate the potential for plant systems to be affected by some event external to the affected systems.
1-1
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GENEPAL ELECTRIC COMPANY PROPnIETARY INFORMATION It should be noted that only internal fires and floods were evaluated in detail in this report.
The basis.for the selection of these events is, discussed in Section 4.0.
Floods and fires occuring external to the plant were not con-sidered in this evaluation.
In order to perform a meaningful analysis of these external events, site specific characteristics dealing with external fire hazards and potential flood sources are required.
These events can be con-sidered on a site-unique basis depending on the requirements for considering such events in the final version of the NRC Severe Accident Policy Statement.
The GESSAR II design does, however, provide design features relevant to miti-gating the consequences of external fires and floods.
These are discussed in Sections 3.4 and 9.5 of Reference 3.
1.2 Approach The assessment of internal fire and flood-initiated core damage frequency and offsite risk followed the general approaches suggested in the PRA Proce-dures Guide (4)
-The detailed procedures are covered in Section 2.1 (Internal Fires) and 3.1 (Internal Floods) of this* report.
Heavy reliance in both analyses is placed on the deterministic evaluation contained in GESSAR II(3),
The evaluations contained in section 9.5 and 3.4 of GESSAR II constitute the basis for fire and flood hazard analyses as defined in the Procedures Guide.
Using the hazard analyses as a basis, estimates of occurrence frequencies were established and accident sequences were developed.
The contributions to core damage frequency were estimated by a fault tree / event tree methodology 4
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1-2 L
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION similar to that employed in the internal event PRA.
The accident sequences were analysed in terms of their characteristics which would be important to fission product transport.
Fission product release fractions were computed for evaluation of the impact on offsite consequences.
Results of the impact on core damage'and risk attributable to internal fires is contained in Section 2.7 and that associated with internal floods is presented in Section 3.5.
1.3 References -
1.
J.F. Quirk (GE) letter to D.G. Eisenhut (NRC), "In the Matter of 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II) Docket No. STN50-447-Submittal of Proprietary Information
- Gessar II Seismic Event Analysis in Support of the Severe Accident Review of GESSAR II," September 21, 1983.
2.
Proposed Commission Policy Statement on Severe Accidents, Federal Register Volume 48, No. 72, April 13, 1983.
3.
238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II) Docket No. STN 50-447.
4.
"PRA Procedures Guide," U.S. Nuclear Regulatory Commission, NUREG/
CR-2300, January 1983.
1-3
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 2.0 INTERNAL FIRE ANALYSIS 2.1 Introduction' The objective of the GESSAR II Fire analysis was to estim6te the core damage frequency and plant risk due to internal fires.
The approach employed in this analysis is consistent with the PRA Procedures Guide (1) and recent probabilistic risk analyses that addressed internal fires.
The analysis of internal fires for the GESSAR II design required the performance of the following tasks:
Analysis of fire hazard Estimate of fire occurrence frequency
+
Analysis of fire propagation and suppression Quantification of fire-induced accident sequences
+
Evaluation of release frequency
+
Figure 2-1 provides a schematic representation of the tasks and there inter-relationships in the fire analysis.
The analysis of fire hazards involved a review of the overall plant and equipment layout preparatory to screening various buildings, rooms and areas to define critical locations.
The screening process identified six critical fire locations.
Following identification of the critical locations, a more' detailed evaluation by location of fire sources and fire frequency was performed.
In evaluating the frequency of the occur-rence of fires, the most recent data was utilized, and a fire frequency for 2-1
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION each critical location was established.
These values provided the initiation probabilitjes for the event trees characterizing the fire sequences for the critical locations.
Section 2.3 provides a description of the evaluation of fire frequencies.
In Section 2.4 an analysis of fire propagation and sup-pression is presented.
For each critical location, the analysis assumptions, probabilities of propagation and suppression, analysis bases and results are presented.
Section 2.5 provides the quantification of the fire-induced accident sequences and the core damage contribution for each location.
From the quantification, the total fire contribution to core damage frequency is obtained.
An evaluation of release frequency is included in Section 2.6.
This evaluation links the fire event sequences to the internal event probabilistic risk assessment to quantify fire-induced release categories and probabilities and to define fire-induced plant risk.
Utilization of NRC Staff Guidance In the course of establishing a basis for the GESSAR external event analyses, an internal NRC memo concerning suggestions for the analysis of fire events (2) was provided to GE.
That memo described areas of the plant which should be considered as well as suggestions of analysis approaches.
The GE screening analysis to define areas of concern for potential fires defined essentially the same areas as those suggested by the NRC.
In a subsequent GE-NRC managment meeting held in Bethesda on Ju'ly 19, 1983 GE personnel questioned the NRC staff on the availability of data to extend the state-of-the-art which was seemingly being requested in some areas of the NRC memo.
Specifically, GE questioned the capability to define distributions of the capability of fire suppression or confinement features, e.g. defining 2-2
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION the probability of a three hour wall to inhibit propagation for three hours.
GE was directed to discuss tne availability of such information with personnel from Brookhaven National Labo'"atory who were involved in related NRC programs.
On July 20, 1983 such a meeting took place at Brookhaven with Dr. John Boccio(3)
At that meeting it was clarified that BNL was embarking on a program to obtain such information, however the current data does not currently support that level of analysis refinement.
Consequently, the GE analysis herein is consistent with the current state-of-the-art fire evaluations.
GESSAR II Plant Features The GESSAR II BWR 6 Standard Plant design incorporates numerous features which minimize the impact of fires on overall plant risk.
These features are discussed in detail in the deterministic fire hazard analysis presented in GESSAR II(4), and are describel briefly in this section.
Divisioral separation of cabling is maintained throughout the plant.
Each quadrant of the fuel and auxiliary buildings contains one of the four electrical divisions which are separated by three hour fire resistant metal stud gypsum walls. When division cabling from two divisions is run in adjacent areas, the two divisions are separated by a three-hour fire resistant metal stud gypsum walls, and the cables are contained in conduit.
When cabinets contain cabling from two divisions, separation is provided by a metallic barrier.
A twenty foot separation is the minimum cable spacing in the containment building.
i 2-3 l
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T GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION There is no cable spreading room in the GESSAR II Standard Plant design similar to that commonly employed in other light water reactor plants.
This reduces to a negligable value the probability of common mode fire-initiated events resulting in the disabling of redundant divisions.
The quantities of readily-available combustible materials are limited by routing cables in conduit and in concrete (e.g. in the cable tunnels), use of improved insulation, use of covered cable trays and designing cable-bearing cabinets to reduce the probability of fire propagation.
Suppression systems include automatic sprinklers in the cable tunnels and auxiliary building.
Automatic and manual suppression and alarming systems also aid in the reduction of consequences of fires.
Section 2.4 provides a description of the suppression systems in each. critical location.
2-4
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION j
2.2 Fire Hazard Analysis T6e Fire Hazard Analysis consisted of identificatin of the critical fire-impact locations and estimation of the quantities of combustibles (fire sources) in adjacentlocations.
The fire frequency for each location was determined from the fire occurrence analysis described in Section 2.3.
2.2.1 Critical Fire Location Screening Figure 2-2 shows the plant layout; Figure 2-3 depicts the major equipment located in the critical locations.
Figures 2-4 through 2-6 are drawings of the critical rooms from the GESSAR II fire hazard report (4).
The following items were considered in evaluating the criticality of each fire location:
1.
Fire Frequency 2.
Quantities of Combustible Materials (Fire Loading) 3.
Safety-related Equipment The screening process resulted in the identification of six critical locations, four in the control building and two in the auxiliary building.
The rooms analyzed in detail based on the screening analysis were:
2-5
o GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 1.
Control Room 2.
Control Equipment Room 3.
Electrical Equipment Room (Control Building) 4.
Cable Tunnels 5.-
Zone 1 Electrical Equipment Room (Auxiliary Building) 6.
Zone 1 Corridor Table 2-1 enumerates the characteristics for the six critical locations and also provides the information used in the screening process.
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 2.2.2 Fire Sources Once the critical locations were identified from the screening process, a more detailed evaluation was performed to assess the magnitudes of the fire sources in each critical location.
The fire source ignition potential was identified to be either an exposure fire or self-ignition.
Combustibles are designated as follows:
e 2-7
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 2.7 Results The core damage frequency for fire initiators identified in Section 2.'5 is 7.5x10-8 /yr, or approximately 1.6% of the total core damage frequency from internal events.
The fire-induced plant risk for GESSAR II was defined in
~7 Section 2.6 to be 2.6 x 10 This represents only 1.6% o f the internal event plant risk.
These low values of core damage frequency and risk are not unexpected for the GESSAR II design.
As noted in Section 2.1, the GESSAR !! design incorporates numerous features that minimize the contribution of fire to plant risk.
These include extensive divisional separation, use of automatic and manual fire suppression and alarm systems and a design approach intended to limit the availability of combustible materials, reduce the potential of fire propagation and minimize the probability of common mode fire-initiated failures.
2-19
a GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 2.8 References 1.
"PRA Procedures Guide", U.S. Nuclear Regulatory Commission, NUREG/CR-2300, January 1983.
2.
V. Senaroya (NRC) memorandum to T. Sullivan (NRC), " Guidelines for GESSAR PRA - Fire Events", May 19, 1983.
3.
Meeting at Brookhaven National Laboratory, Attendees:
J. Boccio (BNL),
I. Papazoglou (BNL), D. Yue (NRC), D. Scaletti (NRC), and K. Holtzclaw (GE) July 20, 1983.
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4.
General Electric Company, GESSAR II, 238 Nuclear Island Doc. 22A7007 Rev.
2., Appendix 9A.
5.
Philadelphia Electric Company, Severe Accident Risk Assessment, Limerick Generating Station, Report No. 4161, April 1983.
6.
Azarm, M. A., et al., A Preliminary Review of the Limerick Generating Station Severe Accident Risk Assessment, Volume I:
Core Melt Frequency.
NUREG/CR-BNL-NUREG Draft.
Brookhaven National Laboratory, August 15, 1983.
7.
Commonwealth Edison Co., Zion Probabilistic Risk Safety Study, 1980.
2-20
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 8.
C. F. Baun and Company, TVA STRIDE Orawings, Nos. I-002, Rev.
3., I-003, Rev.
2., E-300, Rev.
7., E-819. Rev.
3., E-818, Rev.
3., E-345, Rev.
7.,
E-327 Rev.
3., K-016. Rev.
6., E-305, R'ev.
7., E-325 Rev. 4.
9.
Siu, N. O., "Probabilistic Models for the Behavior of Compartment Fires,"
NUREG/CR-2269, August 1981.
10.
" Nuclear Power Experience," Division of Petroleum Information Corporation, Denver, Colorado, December 1981.
11.
General Electric Company., 238 Nuclear Island Doc. 22A7007, Rev.
2.,
Appendix 150, Section 3.
BWR/6 Standard Flant Probabilistic Risk Assessment.
12.
Swain,A.D. and Guttmann, H.E., " Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Application," NUREG/CR-1278,
SAND 80-0200, October 1980.
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EVALUATION OF FIRE OCCURRENCE
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FREQUENCY FOR CRITICAL LOCATIONS j
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u ANALYSIS OF FIRE PROPAGATION AND SUPPRESSION Define: - Scenerlos for Locations
- Fire Growth and Suppression
- Times if QUANTIFICATION OF ACCIDENT SEQUENCES Link Component and System Damage to Core Damage States Evaluate Core Damage Probability C
EVALUATION OF RELEASE FREQUENCY Link Fire Events to Internal PRA Events Assess Probability of Release Sequences Evaluate Plant Risk Figure 2-1 Tasks of GESSAR II Fire Analysis 2-28
GEllERAL ELECTRIC C0t1PANY PROPRIETARY INFORMATI0ft DIVISION 2 & 3 Diesel Generator Building Fuel Building Auxiliary Building zone 2 N
Reactor Building
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Zone 1 Division 1 Control Building Diesel Generator Building i
L Figure 2-2: General Plant Layout All walls rated 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers l
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GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 3.0 INTERNAL FLOOD ANALYSIS 3.1 Introduction The objective of the GESSAR II internal flood analysis was to determine the contribution of internal floods to core damage frequency and plant risk.
The internal floods considered in this report result from potential cracking or rupture of pipes or water containers (such as storage tanks).
Flooding could also result from leakage of seals or leakage past glands due to incorrect
. assembly of fluid system components.
It was found, however, that appreciable seal leakage is small compared to the potential leakage from pipe cracks.
The contribution to core damage frequency frcm internal flooding was determined by identifying the possible ways that an internal flood could initiate severe accident sequences.
A flooding hazard analysis was performed to identify critical locations and develop scenerios by which a flood could cause an accident initiating event and/or fail one or more safety system.
I l
The analysis of internal flood hazards is similar to the approach utilized in the analysis of fire hazards described in section 2.0.
The steps involved:
a screening of potential flood locations; assessment of water sources in those locations; an evaluation of the flooding impact on key safety systems; the i
l definition of accident sequences and probabilities; and the evaluation of risk.
1 Each of these steps is described in detail in the following section.
l l
3-1
=-.
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION t
GESSAR II Pls.nt Features a
The GESSAR II plant safety-related systems and components have incorporated the Lfollowing protection measures against potential internal flood damage (these features are described in more detail in GESSAR II(1));
Wall thickness below flood level is more than two feet m;
-Water stops are provided in all construction joints below flood level Watertight doors and equipment hatches are installed below design flood level-Waterproof coating is provided to protect the exterior surface of equipment Administrative procedures are enforced to assure that watertight doors and hatch covers are locked Flooding alarms are provided in all potential flood areas; alarms are enunciated in the control room Floor drains prevent the accumulation of water from pipe or equipment leakage 3-2
f GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 3.2 Flood Hazard Analysis The objective of'the flooding hazard analysis was to estimate the int'ernhl flood frequency and potential flood-induced damage to plant structures, components and systems.
In order to pruvide reasonable assurance that all sources of flooding have been considered, all areas in the plant where flooding was postulated were analyzed.
These areas,shown in Figure 3-3, included:
Containment Building Orywell Auxiliary Building Fuel Building Radwaste Building Control Building Diesel Generator (D/G) Building Turbine Building i
3-3
'o i-GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 3.5 Results The core damage frequency for internal flood-initiated events identified in Section 3.3 is 6.4 x10' /yr., or approximately 0.14% of the total core damage frequency from internal events. The flood induced plant risk for GESSAR II
-8 was defined in Section 3.4 to be 17 x10 /yr.
This represents only 0.1% of the. internal event plant risk.
As in the case of the internal fire analysis, these low values of core damage probability and plant risk are not unexpected.
The relatively low volume internal water sources ano the GESSAR II plant. features identified in Section 3.1 reduce the impact of internal floods.
t 3-14
-._ _ _..m
. m.
p 1
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 3.6 References 1.
238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II) Docket No. STN 50-447.
2.
M. Kazarians, K.N. Fleming, " Internal and External Flood Failure Model," Pickard, Lowe and Garric, Inc.
3.
A.D. Swain and.H.E. Guttman, " Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Applications," NUREG/CR-1278, Sand 80-0200, October 1980.
3-15
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a GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 4.0 OTHER EXTERNAL EVENTS In the PRA Procedures Guide (1), Chapter 10, an extensive list of natural and man-induced external events are proposed for consideration in PRA studies.
In addition, a number of screening criteria are suggested to enable.an analyst to delete specific events from consideration.
The first screen is to review..
information on the site region and plant design to identify external events to be considered. This would tend to postpone for consideration those events which have a strong site component, such as external fires, external floods, winds and tornadoes, pipeline accidents, toxic gases and transportation accidents.
The remaining events can be included in evaluations of internal fires and floods, and earthquakes.
These are the characteristic events considered in current PRAs and which have been evaluated for GESSAR.
It should be noted, however, that through the establishment of a siting envelope for the GESSAR design (2) extensive design capability exists beyond many requirements associated with site-specific parameters.
For example, the plant has been designed to accomodate meteorological extremes in considering extreme winds, tornadoes and local meteorology.
Bounding criteria have also been established for hydrological, seismological and geological conditions.
The result of this approach results in a plant design that exhibits extensive capability when evaluated probabilistically.
Evaluations of wind and tornado loadings and missile protection are provided in GESSAR II, Sections 3.3 and 3.5.
4-1
n
.b GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION Based on the preceeding insights, it was concluded that limiting detailed consideration of external events to seismic, internal fires and internal floods was appropriate.
4.1. References 1.
"PRA Procedures Guide", U.S. Nuclear Regulatory Commission, NUREG/CR-2300, January 1983.
2.
W.D. Gilbert and J.F. Quirk, " Siting Envelope for Standardized Plants", Nuclear Technology Vol. 25, April 1975.
I, i
i i
L 4-2
..=
F GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION 5.0 SUM 4ARY AND CONCLUSIONS The objective of the analysis of fires and floods and the consideration of other external events was to estimate contributions to GESSAR II tore damage frequency and plant risk.
The study employed GESSAR II deterministic evalu-ations of fires and floods as bases for hazards analyses.
Estimates of occur-rence frequencies were established and accident sequences were developed and analyzed to establish contributions to core damage frequency.
Fission product release fractions were computed for evaluation of the impact on offsite consequences.
The core damage frequency for internal fire initiators is 7.5x10-8 /yr, or approximately1.6% of the total core damage frequency from internal events.
-7 The fire-induced plant risk for GESSAR II was defined to be 2.6x10 /yr., which represents 1.6% of the internal event plant risk.
The core damage frequency for internal flood-initiated events is 6.4x10-9/yr..
or approximately 0.14% of the internal event core damage frequency.
The flood-
-8 induced plant risk was defined as1.7 x10 /yr or 0.1% of the internal event plant risk.
5-1
~y~
r-a. g --
GENERAL ELECTRIC COMPANY PROPRIETARY INFORMATION These small contributions to' core damage and plant risk are not unexpected for GESSAR II.
As noted in Sections 2.1 and 3.1, the GESSAR II design incor-
~
porates numerous features which minimize the contributions of fires and floods to core darage and plant risk.
From the preceeding analyses it was concluded that the GESSAR II plant design:
i 1)
Provides substantial protection to fire-and flood-initiated events 2)
Core damage frequency from fires and floods is a small fraction (approximately 2 %and 0.1%respectively) of internal event core damage frequency 3)
Fire and flood initiators are insignificant contributors to plant risk.
l l
l 5-2
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{
,b GENERAL $ ELECTRIC HUCLEAR POWER systems DMslON GENERAL ELECTRIC COMPANY
- 175 CURTNER AVENUE o SAN JOSE, CAUFORNIA 95125 M/C 682, (408) 925-2606 MFN-211-83 November 17, 1983 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Mr. D.G. Eisenhut, Director Division of Licensing Gentlemen:
SUBJECT:
IN THE MATTER OF 238 NUCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORT (GESSAR II)
DOCKET NO. STN 50-447 SUBMITTAL 0F PROPRIETARY INFORMATION - GESSAR II INTERNAL EVENT PRA UNCERTAINTY ANALYSIS IN SUPPORT OF THE SEVERE ACCIDENT REVIEW 0F GESSAR II The attached report, "GESSAR II Internal Event PRA Uncertainty Analysis,"
is provided in support of previous GE submittals on the GESSAR docket on severe accident issues. This analysis provides the variability in total 1
internally-initiated core damage frequency by propagation of uncertainties through the fault and event trees in order to estimate the frequency of radionuclide release. This analysis was comitted in the response to Question 720.143 on the GESSAR II PRA.
l We are requesting that the attached information be withheld from public disclosure.and considered as proprietary pursuant to Section 2.790 of i
Very truly yours, k, Manager i Systems Licensing Nuclear Safety & Licensing Operation Attachments cc:
F.J. Miraglia (NRC)
A. Thadani (NRC)
C.0. Thomas (NRC)
L.S. Gifford (GE-Bethesda)
D.C. Scaletti (NRC)
l e
G E N E R-A L ELECTRIC COMPANY 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 submittal on the GESSAR II Internal Event PRA Uncertainty 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 iinproper 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 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; 4
7
'O.
t
'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 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 reviay and approval procedures.
Also, until the final document is t ompleted 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 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
o standards enumerated above.
Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential custome~rs 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 information in support of the severe accident portion of GESSAR II contained in Section 15D.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 ower General Electric by allowing foreign competitors to produce their containments at lower cost than General Electric.
e m
s
STATE OF CALIFORNIA
)
COUNTY OF SANTA CLARA
) ss:
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 /f day of di/EM BEA,198J.
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