ML20129F249

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Sanitized Info in Response to Request for Addl Info Re Severe Accident Review of GESSAR-II.Portions Withheld (Ref 10CFR2.790)
ML20129F249
Person / Time
Site: 05000447
Issue date: 04/20/1984
From:
GENERAL ELECTRIC CO.
To:
Shared Package
ML20127A304 List:
References
FOIA-84-175, FOIA-84-A-66 NUDOCS 8506060719
Download: ML20129F249 (45)
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Text

GENERAL ELECTRid DDADD. v.C..TA..DV INEAD#M. 4..n. cq>t?

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@ErrioM 1.

Review of Table 3-25, p.81, of Reference 1 indicated that only a limited number of cmponerts are included in the GESS,AR analysis. BNL codpiled a similar list of critical components based on previous seismic event PRAs and on a review of the internal event PRA system fault trees. This list "

is presented in Table 1.1 and it only contains components that are not ad-dressed in Table 3-25 of the GESSAR report. A discussion should be provided to establish why these components are excluded from the analysis.

If they are believed to have large capacity factors, a discussion should be included to explain why the GESSAR components would exhibit such capacities in light of previous analyses and the basis of assurance that the plant to be built would consist of components that are being characterized in the GESSAR analysis.

REsNenasc rne sai canal eompanan+ ust crasu.t.t) has been ievieues bt/ GE and /)as bet:n +he subjhef of a number of /ccen/ mechdys intbNing 8dl, the N/2Cand GE. GG offers s%c fc//Ontihy comirksnfo:

  • The. 06n&ibehen h cae attmage Segawcef of s%c d>Houiny components ens hiisiko' h t/nsirm/wd asacadfaf satW) ntnot7en sfu/u.c on/y,4iAct #1eir aeismic frof/ihh.t am hijh:

Corr >penenf Aoish)iy(6a. sis) 6tsnid Apid) 3.99 (bdrax4 M4)

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Exc/usten of tfie Condonaste dibna7e rank,i:e. Ossuiring sitibst, probabi/if c//.o /ns no.S$n'idcont eMzt on rMt evaluated cwe damoog &cgancy.

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GENERAL ELECTRIC

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PROPRIETARY INFORMKfl0N QuesTiod 2.

One of the components that appears in Table 1.1 is instrume'nt panels.

It is obvious that instrumentation in general is' vital to the operation as well as the safe shutdown of the plant. Failure of instrument panels

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could lead to the loss of system function. Similarly, failure of various sensors, such as level, or pressure, depending on the failure modes and the number 'f failures may also result in loss of system functions.

Provide additional information to address the failure of instrumentation due to seismic events and its effect upon system performance.

RGsRwsE The dafruirw1/shbn n'riportant b the Amc/hninj ofdefy epijiirwns u con;oa:nz/ of stxrnsmiffea /xakdon hafwirmt ntek$ in die confchmeri baUdshy, pipidg 2t1 i+%e &sfwmenf izwks, cublihy, md so/tdstate dis /ntment pene/s loca/a/h Mic emko /

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irw1f ston. Tilese cotrytwn/s are awhmek//y yahWidh/ ks/ enve/tyus tJikA exaed ave at:sgn hash yhements.

Expenh AiNh alikaAbo st1sArf oftds/ninwnf mckJ has demonabxt/a:f the dernsan& hixrtdn 4 sfifx/m' danny ific aedmk evenf, bcsf thoc is /k/k im&f on,ne knchdn St/owutg on er.nt. Thus it>s / ass ofsyskm.&nchan is twt expr>ttf due h thsbumenfalida fai/ute portWet 1911f v%e faWure irede does nof pochee a lasfiig effa-f en Mz irishument sexl;. 7he mosf likhly rGJ/at hfged h be stic fa)/at of hafnerwrf /ide pipihg h the nrck.

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@/ssnod 3.

Display instrumentation failure does not necessarily result in system failures. Oftentimes its principle function is to provide the operdtor with confirmatory information.

In some instances, operator actions as prescribed by the procedures require information from display instrumenta-tion. Provide a detailed discussion on the likelihood of common cause display instrumentation failures due to an earthquake and the potential impact upon operator, actions given the occurrence of these failures.

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The dibp/aq /hafruinen/astin needed. f.o monifor p/ont ftnchro'n < h ' sani /or rb r%1t discu.ssed th tru. te.9cetuo rb queshbn 2, except s%f dnsy/ay siikerrxutbn taffar than ewitrot logic h uxd. A:v the some Masons as den ~4 41 du. Mc to yttch, f

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ovesncM 4 The relay chatter phenomenon has not been included in the GESSAR analysis.

The ef fects' of relay chatter can be summarized into three dif ferent '

categories. The first case concerns relays t, hat chatter in an earthquake but do not alter the system state through breaker tri,ps after the seismif '

event.

Its impact upon the availability of a system is considered to be minimal. The second case concerns relays that chatter in an earthquake resulting in breaker trips; however, resets of these breakers are located in the control room and can be actuated by the operator to restore a sys-tem. A successful system operation in this case is predicated on the re-cognition by the operator that the system is tripped off line and on the manual reset action of the operator. Lastly, in the event that relays chatter resulting in breaker isolations, resetting of relays may have to be done at local panels away from the control room. Moreover, prior to resetting, careful diagnostic procedures will have to be followed to en-sure that indeed no faulted conditions exist. For instance, the in-plant electric circuit will be under this category.

Information should be provided by GE to address (1) the effects of relay chatter upon the availability of all the GESSAR safety systems and (2) the modeling of subsequent operator action to recover breaker isolations.

Arsmasso The Gess42 Ecc3 4-kns am conhcIled by soth' mi2it:

lyth md ont thua nd awAmhVe,b m/ay ch2Her effeeds. Only

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Gossnod 5.

In the two GESSAR reports, Refs. I and 2, it appears that no consideration was given to the modeling of the increased stress on the operator as a re-sult of an earthquake. Subsequent to the onset of a reactor transient or_

an ATWS, a number of operator actions have been assumed in the GESSAR seismic event trees, provide a discussion to justify why the same human failure probabilities as those used in the internal events PRA were used in light of a seismic event.

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Cuened 4.

In the development of the GESSAR seismic event tree, the 3 diesel common mode failure is modeled explicitly, Figure 4*1.(1) How is the 2 diesel common mode failure (divisions 1 and 2) modeled in the analysis?

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GuE$ nod 7.

It appears that the hardware dependences between the LPCI and the RHR sys-tems are not considered. Provide a discussion on the treatment of de-pendence between the low pressure core injection and the RHR. systems and

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how it is modeled in the event tree.

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GENERAL ELECTRIC PROPRIETARY INFORMATION oussnoo 8.

In the January meeting with GE,.BNL questioned the definition of the EDG and ESCB functions specifically with respect to their NOT-event de-finition.

It appears that the NOT-event definitions of these functions i_n.

Figure 4.1 is not consistent with the definitions provided in Figures 4.4 and 4.5.(1) GE should furnish a clarification on these event de--

finitions.

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Gt/EJDod 9.

In the seismic ATWS event tree, Figure 4.3,(1) the level control func-tion by the reactor operator is not included; provide a discussion to sup-port its emission.

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aus.sno4> 10. As noted in the BNL review of the GESSAR internal event PRA, GE has as-sumed that in the event of an inadvertent ADS, low pressure ECCS is adequ-ate in mitigating an ATWS if level control is maintained.

It appears that.

a similar assumption is also made in the development-of the ATWS event tree. Explain in detail (1) why is there no degradation in the human re.

liability to control water level, (ii) the procedure that the operator has to follow, and (iii) how much time is available to perform the task.

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' l Gussnw 11. In Figure 4.12, a 50% value is specified for the failure of the shroud support and a 5% value is assigned for the hy.draulic control unit.'

Provide a discussion on how these values are used in the seismic quantification and the basis for their derivation.

I.f an internal GE document or calculation is referenced, a copy is requested for review.

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GENERAL ELECTRIC PROPRIETARY INFORMATION 12.

In the GESSAR seismic fault trees, it is noted that failures of pumps and power divisions are modeled as independent events, that is with no cor-relation. For instance, in Figure 4.11, failure of RHR pumps A and B ar_e considered to be independent basic event. Similarly", the loss of power divisions 1 and 2 are also independent.

'rovide a detailed discussion to show that in the event of an earthquake, these pumps or the different power divisions woul.d not be subjected to common cause failures and that the assumption of independence is adequate and reasonable for the GESSAR analysis.

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The carreta hon in e:Annfs cons.'jk of fWop?rts:

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(bESnod 13. Referen 5

and 2 do not provide sufficient information to perform a complete review of the GESSAR II seismic event analyses.

Because Re-ferences 1 and 2 are generic and do not apply -to a specific site or plant _

(i.e., as compared to past PRAs such as the ones conducted for Zion, Indian Point, and Limerick), the ultimate purpose and intended use of the GE analysis is not clear. Based on a preliminary review, the results do, not envelop hazard and fragility data from PRAs submitted to the USNRC to date. We request that GE state their philosophy concerning how the seismic PRA analysis will be applied to specific plants. The ultimate use of References 1 and 2 should be defined by GE in order for us to de-termine if the intended objectives have been achieved.

R.G 3F b Als E :

The idkas'ed use of +he GESSAR H Jedmk Etenf And/q3i.s k addics. sed th Secbbn I.3 offlie 15paf C 6 e &).

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SENERAL ELECTRIC PROPRIETARY INFORMA110N

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-l QUESTwC 14 Because the structural capacities are apparently high, the problem of de-sign and construction errors becomes very important.

In a practical sense this consideration could dominate the results of the analysis.

Since GE has not generally included the effects of dqsign and con-struction errors in their analysis, they should state why this issue of electrical components also is not addressed. GE should. verify that this is not a problem for GESSAR II.

RESPCAlSG Thh gaubbn ntas orhihf Included in #6 fwnd3 and dien 1Gund 16 be rikppropbfe by Mie Altle draff.pfibos If h GCh opshion that pmblents of aksji n and cusfruch errors con-not be appropnkfehf heafd kf & exAirbny PtM meMa;hlagej.

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Quesnod 15.

Intergranular stress corrosion cracking has been a problem for GE plants 4

in the past.

Is this problem pertinent to GESSAR II plants, and what ef-fect will this problem have on the seismic capacity of piping?

RGSPCMG OtCouar d changes sinde sh Me tijp c{Ofairikss skel d'/rployed th Me. pijshy At the 66Ks42.22~ ):Wmf, ishytonalar ~ske.U cerrosion is not expeded ob be a/wobkm. Thh was xce9ntied th the GGssAM E CER.

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. 16. What are the capacities of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire walls planned for GESSAR 11 plants? What are their locations with respect to the nearby safety-related equipment?

RespousG 1he ohour 64 watts ;> GExset.27 ee pidair/y anmk unl/s as saokd A1 Appems'h a4 of 6M1M4 E. fhm. *e n/a fipt J 3 Aour nellt. c'esinkd di 99.3.4 of GELMA.2T. 72a4 malk et /noiadf /xa/af 41 die ha?efdgi caridvs aso' ex edauj)ns/ wi,% 6 hs. snenal a6anGr of Min. on en& usW) snee 1

i lays of S/s in. Siccaityparter Joerd as och sk& of Mc The a' n9 rt is oR"A' darr.rc80149S fv a J-kpwnhar.

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-thkkness ef s%e ehtschral nreorbes hoe Asw dexatd ob neeef -tste p'en/ Jaimic xpedemerh.

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GENERAL ELECTRIC PROPRIETARY INFORMATION Questod 17. The best-estimate seismic hazard curve developed by GE was based on an

' enveloping approach.

Iri developing the best-estimate envelope hazard curve, the results of recent utility-sponsore.d studies and a U.S.

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Geological Survey study that evaluated ground shaking hazards for the contiguous U.S. were used. The envelope curve selected by GE is con-sidered to be a best-estimate of the extreme values of the best-estimate curves at potential GESSAR sites.

It should be noted that the sites which are potential locations for a GESSAR facility are not clearly de-fined in either GE report. General Electric Company should state what sites the seismic PRA analysis is applicable to.

RFspoLISE The res/non$c 16 #is gla.sfabn WQ3 frovided til f/?e it;.ytv? x s fo guestibns 720.50 dirough 720. /32 O

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SENERAL ELECTRIC PROPRIETARY INFORMATitM QUESTic*]11 In the approach used to develop the best-estimate hazard curve, the re-sults of four recent PRA studies were used., They are the Indian Point, Zion, Oyster Creek, and Limerick PRAs. The. actual degree to which the U.S. Geological Survey study results were used is not explicitly stated' in Reference 1.

The best-estimate GESSAR hazard curve was then sub-jectively taken as the envelope of the best-estimate curves of the above listed four studies. Further, the GESSAR hazard curve was defined to

' have an effective acceleration truncation value of 0.95g. The basis for the 0.959 acceleration cutoff is not supported. GE should provide a basis for this cutoff value.

RESPOM3E 1

The response k thh gueshon was providet:/ th the resp:n.ses k guesthns 720. ist ana' 720./52.

As nokdth the se.sponse la 120. A52, Geners/ Ektkic has pnbemes'a sensih&iAf analt(st's usMy thc

GENEiAL ELECTRIC PROPRIETARY INFORMATION

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Q uESnod 19. There is no evidence provided in the GESSAR reports to support the state-ment that the GESSAR best'-estimate hazard cur:ve is in fact an upper-bound, or an upper-bound that will not be exceeded by 80 percent of the best-estimate curves at potential GESSAR sites. The arbitrary selection of the four PRA studies used in the GE study, and the subjective manner in which the GESSAR best-estimate hazard curve was selected, raises important questions about the development process and the full meaning of the results. It is not clear, 'in a probabilistic sense what the GESSAR best-estimate curve represents, other than an envelope of the four hazard curves considered in the study. Provide additional discussions in thees areas concerning the GESSAR best estimate hazard curve.

RGS90sJ5E The Naponse tb Mis gaAshin 45 confadsed kr #c x,spn.scs tb gue,$hdns 720. 450 - 120. 15 2 and guex;hbn.s AS, I? and /8 e

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SENERAL ELECTRIC PROPRIETARY lilFORMATION Gutsnod 20.

The study by Okrent(3) does not appear to adequately provide a basis for the seismic hazard uncertainty estimates, The experts were given some data on the seismicity in the region sur. rounding each plant site and asked to provide estimates 'of the annual frequency of_ exceedance of ground shaking at each site. Within this fonnat, it is a difficult task for the experts to rationally and consistently provide probability es-timates for rare events. An alternative approach is to provide each ex-

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pert with the opportunity to break the problem into more tangible parts (i.e., seismic sources, attenuation, etc.) allowing for a more systematic evalution, which is less prone to overlooking significant sources of un-certainty and is more easily perceived by the experts in a probabilistic sense.

The study used in the GE analysis was published in February 1975, and un-doubtedly performed in 1974 In the last ten years, considerable work j

has been done in the area of seismic hazard assessment, including solicitation of expert opinion, geologic and scientific investigation, etc. Consequently, the use of the 1975 Okrent study as a basis for un-certainty estimates is seriously questioned.

It should also be pointed out that the number of experts used in the study (7) was relatively small. Also, the degree to which those who participated in the survey can be considered probabilistic seismic hazard experts for the entire U.S. is questioned. Provide additional information to substantiate the use of that Okrent report (3) in light of these concerns.

RESOcm3SE 1he Chur/ skdy was nie AufidAnnshin A*'allahk a/ &$e Arke heroid atxm'idf estfaiah. As a GE pasedwruf the.,sehinA:

a x.kd/ of duaiusus bekww GC, fde p/td onef 4%eir doissab%ts, it h our undtrsknai'ny //kst tk AltC desa/Arirt au2/piinue addd!ebot cula.1fxia ofnmk /mvia' uAAA adW be diefadd di Hu sk//euhabhu of ;4t daSAC Jesskic Em/ 44. sis.

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Qut.Sncd 21. A preliminary review indicates that the results (Table 2-3, Ref.2) for accelerations less than 0.50g are reasonable in that the uncertai'nty es-timates are consistent with respect to previous site-specific studies and expert opinion surveys. However, at higher acceleration values, which is the region that dominates core melt frequency estimates, the uncertainty values are too small. Provide a discussion on why at higher ac-celerations the uncertainty values are much smaller than in previous studies.

REsMUSE 7)>e cyxen$rinf ret /aeb sehe>C den & hLtdon 1%t; N1kr/Th2bir!

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GENERAL ELECTRIC PROPRIETARY INFORMATION Quesnod 22. The coefficients of variation assumed in. References 1 and 2 for the fragility analysis are generally low compared to past PRA results.

It is stated in the calculations for piping that lower values were used because.

of additional design.consideratiens to be place upon-GESSAR plants.

It is not obvi vJs why this is so.

In fact, because of the nature of GESSAR and the generic analysis performed, the uncertainty should be greater rather than smaller. compared to analyses for specific plants.

It is re-quested that GE provide the bases for the coefficients of variation on the structural capacities assumed in the analysis.

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References 1.

GESSAR II Seismic Event Analysis, General Electric Company, Sept. 1983.

2.

GE'SSAR II Seismic Event Uncertainty Analysis, General Electric Company, December 1983.

Quesnod 23.

In Reference 1, pg.24: References 9, 10, and 14 do not appear to be cor-rect. What are the correct reference numbers?

a.as h ee The correct refence twmko om 7and 12.

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~6ENERAL ELECTRIC PROPRIETARY INFORMATI0li Guf5770AJ 24 In Reference 1. pg.35: What is the basis for the strength margin of 1.3 given at the bottom of the page?

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GENERAL ELECTRIC PROPRIETARY INFORMATION Que5 Foal 25.

In Reference 1,'pg.38: What is the basis of the 1.2 value assumed for F s?

s Resmaise 17)e. factor F is ca/atA1kd fem the sfvmula u

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and fy is t/x. mindnum akely6d ebenf/h.

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SElI K. ELECTRIC PROPRIETARY BFORMAT&g essesnm) 26.

In Reference 1, pg.40: What are the data which substantiate a value of beta equal to 0.2 for inelastic analysis?

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/bwer Plant,' A/uelesr Engmkrig and %n, 39 /980 pp. ais-3aa.

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PROPRIETARY INFORMATION GuESnod 27.

In Reference 1, pg.42: Was the 10 rercent increase cited on this page also assumed for structure capacities? If yes, then were all analyses for the structures performed using the time hi. story analysis method rather than a response spectrum analysis method?

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GENERAL. ELECTRl0 PROPRIETARY INFORMATION QUESUod 28.

In Reference 1, pg.50: The basis for the 30 percent increase for the ef-fect of dynamic yield stress 'as compared to, static yield stress is re-quested. Note that the explanation given in the calculations for piping for this factor is not clear.

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??x. Jopun:end shexa.se a,s &kd is ' mew; apnespdak kr sk:el dibplafthy a dAlhhetykW plafexta (lefewxt.t). Ar shrih/ css steel, an brexo.se of alvat topwr.ent br Me efket efdttnanth yti/d chcas i:s suppnfabk. (ftference.2).

Refexnces :

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EHec/s on 3huckixs 8axd m ffobabt/>&,* Abacas Acss (Extract Afhcbed) 2.

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d, la Figure 3.9. The following strengths can be distinguished. namely: proportional 9 '.

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@Ws.' sat k--4 minute intervais on the ce plateau during testang, la order to obtain *'.

i

-'t '2:

l*

%s. the statie yield semos level during these stops. Das, the loading rate decreases

%-V. to aero and hemos, the yield strength decreases fkomt f,fynsnie to f,starde, Tt-g.' '.:.

j 4-*. Figure 3.9.

. :, ~.

f'+:fr

.g D'i.,,J.Y Present day steel testing standards (Orest Brania. 35 4360: Part 2: 1969;

- West Germany, DIN 1710 and DIN 50146; U.S.A., ASTM E8-69, etc.), prescribe j

f,, as yic!d strength for steels displaying a yield plateau. "The reason for this g

=

d,p.. D, drd f oCM, 9 D. W M 8'

)

h; *8ppiriapw ytem/*p 'TM'TS *'.M"*.

'ea yo.o m..,i>*. hsuas pac

... f.if u id,.;

j i

yu.-

='

l e

y-e

T~-~

~~

~~

2

=

J y.

)l' 6

v" h

I etq I

s' wwe. smow me vowinAtuas sweets ou rrauctuars s

  • Jaa f

2

[

'l choice is probably historical asd also due to the fact thatf,,is easy to detercane L'

experunentaDy" {3.3].

to acc I

As order of --ai=A*. on the average [3.6},

produi

{

stausta Thiq f,,

But, i trea 3

- 1.25 h ***"

freque prot

..a. s. u..s e.-

s to the win <

(i en i The standarda of Romania, France, Sweden, etc., prescribe as yield strength Y

manuf i

the plateau yield strength f,0.2%, measured under dynamic loading, for a 0.2%

intes offset value.

I.

str :<

ordina For h? h-arade steels, which do not display a distinct yield plateau (neither

.sa effect long enough, cor horuontal) all standards conventionally deAne yield stangth by Figure i

D means of f. 0.7M. measured under dynamic Ioadinf.

(I Generally speaking, yield strength to compression (without buckling) is conven, from :

P**

P'***'

tionally dedned in standards as being equal to tension yield strength. In the U.S.A.,

yield strength to compression (without buckling) is denled exclusively from tests on stub columes, by measuring the stress under dynamic loads corresponding

  • P to a 0.5% offset value.f,0.5%, which represents the average off, on the dynamic
  • 4'*"C yield plateau [3.81 As a rule all testina standards dc6ne tension viefd strenzth under dynamie

}"1,Pos leadine as f_ or /_ Ol'i. for ducule carbon steels and f.0.1% for bish-grade ste-is.

Yielj strength to compression (without buckhng) under dynamic loading is either deaned as equal to tension yield strength (in Europe) or by the valuef,0.5%

'fech c

  • (in the U.S.A.).

i

as em The lack of unifortnity in the defeition of steel yield strength has led to i

if a

the adoption of a standard deanition, irrespective of the steel type (ordinary i g *"

carbon steel or high-grade semel) and of the stress type (tension or compression without bockling). The standard dennation of yield strength for design purposes bil and safety analysis is, Figure 3.9, y

g{

distrib e,,,,

f,0.2x,,-

This dednition was p.at forward by Alpsten [3.3f on behalf of the ASCE-

,b'I' IABSE Committes at the 1972 Congress on Planning and Design of Tall Buildings, G

.."Y re held in Lehigh, U.S.A. This static strength may by determined under dynamic had pre loading by means of the sten testini technicus.

o T

i Idengs,

J impGe s.

sees sc

/

(1) Desertuaise of sensi ylsid smth I

c(loc

( *PT t'

? s, of var

!vww o

.t Steet yield struosth,'as won as coocuete grade, is a typical case of randoar L

i tru cs' variable. '

vannt.

! ss wene The main types of distributions used for the statistical description of steel by sta

! dynom random yield strength are: normal distribution [3.10}, [3.5), [3.18), log. normal depen y r.g ;

distribution [3.17). [3.61 Fisher.Tippett type ! (Gumbel) extreme distribution [3.3]

and a snow,,

and Beta distribution [3.11).

upon

,,,, w l.,,el,g

.(

A

+..

,. sm.

n.

1M%.n.;Q.Q.T.y"..N :

  • 1.ll:.

\\

. c.4y.Q.

.. s. :.

~

.t.

7..

+

l

i.

A I

i

.: 7-

?

NUCLI'Ah. PLANT SEISMIC MARGIN ROBERT L. CLCUD JUNF 8, 1979

}

a

.o i?repareed for Lawrence Livorn. ore Laboratory W

't l

by

~

2 Robert i.. ' C16ud ' Associates '

~

640 Menlo Avennue, suite 8 Menlo Par.4, Ca. 94 025

.g. c, 1

.. / *-

. A.,,y

i.. g..

.e t.,

,' ' h:*. l*. L i.* Q.

_ f.3 ' : < f. ?". t Q~.4 ** ~~ ' ' ' ; }

.5'.',,%'.f,t..Ca

c....

-4

.4.s.. '.

.. (;; c M

  • ,5,,

3

,m

)

i e

172

v y

~

INTRODUCTIO:"

This report contains a discuzrion of recct:t wc rt. c :.

the seismic design precerr in nuelcar plante tPat vpr per-fornc:1 by the h awrence Liverr. ore Laboratery (LLI.).

Th r.

work was done to study the margin ir. the seis.ic des,igr.

Conclusions and recomnendations rel,4tive to the precess.

NRC Regulatory Guides (RGs) and the Standard Revice Flar.

(SKr) arc preserted that are based in part on the LLL reports and in part er. the'rresent writer 's expericr:a.

The first se:tien cor.tairr. a brief referor.re ti th-evolution of seis.ie design, and mer.tior. of the cc.tcg:r-

)

ies of design margin.

General recon..endatior.r are giver, s!

here.

Th6 L:.L reports are discussed in the next sectier.

and some justification is developed for the general recommendations.

Then a short discussio.n is given rela-tive to the seismic performance of power piping in actual earthquakes.

This section arovides additional technical

, c t.

background for the recommendations presented.

, hC.

.. M j.,., n.

.~

. 2

. y,

%,,.k% : 9

';*.: Q..;i.,.. -.:.,.:..

+

'. 5

,4 s e. r h :

  • i,.

d ai

.,..g..

173 n

DrsIGN CRITERII MARGIN The basic conservatism that results fro; the actuci

~

strength of material beine norms 11v richer thar. specifics values is docueentc[ in UCID 379CE.

The avera,dc. TCC t?.nt results f rer thir of f cetuk1T4Tifhir 1tter@a'N relagamaaksasterets.

The role of quality arrurance frc-It would n:t grams is maintaining this FOC is discunsed.

appear unreasonable to expect this TOC to diminish na'ture:-

ly as manufacturing facilities across the counItry and even around the world become mere uniform and delivered merc uniform products.

On the other hand there appear te he few advantages to artificially lowering this traditienal a..d easily understcod source cf censervttirn.

UCID 18100, in a nice piece of werk, shcued that elast:0 floor spectra may be expected to be generally higher.than floor spectra generated from motion containing s:re plastic In particular,' peak responses were lower as war action.

expected.

In some respects this scorervitism is Design criteria Margin and in some respects it is Calculaticnal Margin.

In any event, if other sources of Calculational Margin were eliminated, it would be comforting to know that in an ex'tra severe earthouake the plasticity darpens the floor spectra.

The work reported'in " Elastic-Plastic Seismic Analysis

.S 3.4 of Power Plant Braced Frames" by. Nelson and Murray is an

. ".' y.-

.,-a.,

exploration of another aspect of the plastic reserve

  • strength in nuclear structur'es.

This study is particularly 109

GENERAL ELECTH!C PROPRIETARY INFORMATION Qus3 nod 29.

In Reference 1, pg.50: Justification should be provided wny the damping stargin for structures is app 1'icable to the c.apacities for components and equipment, since at the equipment failure level the supporting structure may be uncracked and still elastic.

f D

F L

G k

- - = = = -

= = -

" %4 m.

l.

G

4 SENERAL ELECTRIC PROPRIETARY INFORMATION

~ ~

RE3mmt 10 Qussnca ao (cour:)

Egushbas (8) and (9) a<e the expw.1sions At oc an'dp th +he repod, except sh +ht., GE wport a paronthesis 4 moisky sh the expmssion kr p.

FurMormat., &cm quahsr.s Ca)and (9) the k//owidg can be obhained:

ac =

'/z in (d'

  • e~" '"b + e' "l' )

< = - { in C f *ji * +lc*)

-i in (,$',.y g.

.L jn ( I* +b* _ 'l 2

g+

s

  1. 4 hIn (ro)

,,p, from qushins (9) ond (M)

$*l2()nhat)=

2 in)$ ~ 2. h in (

f=q Inf*+In(b"l*5')

p i

p.

in.(n=+fe

. <,, )

i p

l l

l og m

,_.___,,_.._-------.w-www--,.,,,_

y r~-_,-e,--_

-.~yy

+,

n_

..ww.,

n--w,.7

-,-w--..-,-

SENERAL ELECTRIC Pit 0PRIETARY INFORMATION GUEsw 30.

In Reference 2 pg.3: The basis for the equations for 4 and / is re-quested.

]

Rasmuse 7/>e m e a n (

) and vadana:.([') ofo /ognworsal didMbahdn ean be uritk)n in knns of /ogadMmit mean (w) and ehtndard dewahan y) as 26/ lows:

-. 41 4=

O)

)$-2 e Y(e Y.L)

(2) c.

froen 9.(i):

/n)$=w+(*

(3) 2/n) = 2a + p*

(4)

$* - zin) - 2a cs)

Emm O),0),(4. ) orxr (5) fr^., e

  • I"l (e
  • I"5 1) h3 4 In}v

~A" gin)vt,

,g g

_g e-2d,

6-*+e*I"h 4 In)5.

e

- ta.

  • z -*l"5,e-*I"h

<r e

( p) e

=In(Ir*e'*I"5+e'*'"5)

-2a v

Q.-fin (fra e'I"l+e'*I"l')

(s) fn m (s)

$* - 2/nh - 2x

/

d 4"/-d)

(9)

SEllERALELECTRC

?ROPRIETARY INFORMATION GuF3710Al 31.

In Reference 2. TabIe 2-3: What are the logarithmic standard deviation values corresponding to each coefficient of variation used in the an-alysis?

9. a uno a s E

'T?>e /cyad>%mit. afandard attirahdn ($) of a /qnormal.

dsiMbed2cn con be udNen IE1 krms of Mst. ccef6bint af vanirh6n (V) as foflows :

p=}In(d*2+s)

Usiny this quabbn> -the logon?hmic chidard deviahob o{vanbus ValaEs of V can be wriHea es follow.s:

Coeffr&est af Variaban LeyanMmk Shndard (V)

AviJehod (o) 1.42 t,03l l.47 1.073

2. I.5 1.308 2.36 1.3?2 ee

SENERAL ELECTRIC PROPRIETARY INFORMAT10N Quesnod 32. The calculations for piping provided by GE were reviewed.

It has been shown in past PRAs that the supports are generally weaker than piping.

However, in the GE calculations it is stated that support failure due to seismic loads is precluded since supports have been qualified for more --

severe loads. The basis for not considering failure's of the piping sup-ports is requested. Consideration should be given to supports which are designed essentially to resist only seismic loads. Also, consideration should be given to support hardware which is designed for AISC re-quirements as opposed to ASME criteria (i.e., at the building / support interface).

essoase AllN) the thehasbn of suppef fet/t/K. o.5 aytennby fa 4/4 mode., the qwroic capaciy ofpijiny sysk.s mnge Som 2.19gs k as hijh a.s 1.s9g.s (buco'on Mie, L'rdo ana' Oedth Mrs) & pjes layer Mian toin'ches a a%d&.

D l

l i

l l

9

---.,.-----,.--,.-,.-.-.------._.7 y.--

- -~, -.

?

QUE5110aLS cal /2ccoW6 As/ALVS/A t

dpusS77cd 1)

In the GESSAR Internal Flood Analysis, two water sources were considered; they are potential cracking or rupture'of pipes, and leakaoe fron seal e i

and glands.

Provide the rationale why internal flood due to naintenance of eouinrent was not considered in the analysis. Explain in nore detail how the ef fects of draining the suDDression cool and/or the condensate l

storane tank are evaluated fsr the various potential flood areas.

1 RsweasE 3

L_.. - _

...-- a h' h,

  • h 4y daard Ana4ah Ar.sehis 3.4' of GEss42 a.s.rames r%e /orped pA:nhW wike.axmc for ex/> orte.

Loss of &yp.w&1 Ao/ & is conicker. Av exampk, floody of tAs ECU /awss due rh y/w.wkjaw/&cr k oddested m jy. J./- 7 o/GE2mM.ZT.

I i

f PROPRETARY NF0ludADOR i

L

~

sNERAL ELECTRIC G

PROPRIETARY INFORMATiON Gusanod 2) On n.3-6 of the Internal Flood Analysis, it is stated that the instrumentation of the drywell floor drain leak detection systen-is fed fron an uninterruptable power source.

Provide additional discussion on the "uninterruptable" power source and on how the value of 2x10-3 is de,

rived.

RasAnsisE Rn counkirup/abk y anurre 63 k od' issedponter.

k;y de / ass ofchik pwer, diixlpocaAns WiHbe.soutzu supplyiny /AL.gwer sk Hu. ddsknal'pwwcys/em.s.

b

(

O

SENERAL ELEC7R10 PROPRIETARY INFORMATION i

curenOA> 3)

Industrial data were cited as a basis for assumina certain flood frecuencias in di f ferent pa rts nf the plant.

Indicate the section of the rESSAR SAR fron which the information is derived.

RE3Ma/SE bheekk awe hand fik Assessmed, an:t AfeM.e &

hv.1ubin 3.6 o/ GE5548 7 Mic est' FM fx4:enal Ed A%slysh. The (het/ Jewraw oc etfak.edsh safsn 3.4 of SessAs 1.

l l

l l

OO

UtNEUL ELECTRID FROPRIETARY INFORMATION Cuf5 Mod 4) In the event that there is a pine ructure at elevations above the botton level of the buildinq, water will drain into the botton level througn stairways and cable trays, etc. Discuss why the cascadino of watei from higher elevation which could result in Dotential cmron cause failure of systens at lower levels is not considered in the GESSAR analysis.

R&35tWGC The /kod barord ondynk Ondrinbd h Min a/ of 66ssAt E akY en.sn'ner die snyine/ of a.scedA' rf amt:r fm r>

h.jW eko'a/>iw in o.sw.s.si&.soarces av a ana.. Hornul futdmjn // cad mikjahisu ka/wrs (pinedm mi.wd puds, Roar deina etc.) ram /Ac.pwivWat he ewnpanest radies.

ra,umae., m,nm aaa w is assaus ei m,;o a. s.

b ecegk', & 3.4 -8 Osks& N&iby Ofmest hn ens f

a e s roorn.

l i

t I

l

titNtilAL ELEUTRIC PROPRIETARY INFORMATl0ll Guf5770Al 5)

In the Internal Flood Analysis, fiE evaluated the scenario of floodinq in the diesel cenerator building leading to a manual shutdown.' that is the incact to core danige for a scenario with'the simultaneous occurrence of a loss of offsite power and a flooding event' in one of the diesel cenerator bull di nqs.

R&5MA/SE h

O ee e

m-

- - - - + -

  • =

" ' ' " " - " ~ ~ " * " ' * " ' * ~ ' ' ' ' ' ~ ' ~ ~ ' ' * "

GENERAL ELECTRIO l

C..:-*

PROPRITARY ZFOTrMATION i

mus3 nod 6)

Provide a discussion of the locations of safety systm components, instru-ment panels, and electrical panels with respect to flood height in the CES-SAR design.

RE$pcAASE

~'

1hh sh4wmehin 4 pswWed for each annn on on efe/a/sk btsis sh dra-hiyr J.4 of G65Ste E.

~

O i

e 0

l

N/

GENER AL $ ELECTRIC NUCLEAR POWER SYSTEMS DMslON GENERAL ELECTR:C COMPANY e 17s CURTNER AVENUE o SAN JOSE, CAUFORNIA 9s19s MFN-047-84 April 20, 1984 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 OF PROPRIETARY INF0FF.ATION IN RESPONSE TO REQUEST FOR ADDITIONAL INFORMATIGh REGARDING SEVERE ACCIDENT REVIEW 0F GESSAR II

Reference:

C.0. Thomas (NRC) letter to G.G. Sherwood (GE), "hequest for Additional Information Regarding Severe Accident g

Review of GESSAR II," January 26, 1984 The reference letter requested additional information regarding the severe accident portion of GE's GESSAR II submittal.

Attached please find final responses to the questions included in the reference letter.

Also attached is a rationale for the treatment of fire and flood event uncertainty analysis.

This information was previously providea on February 1, 1984.

The attached final responses incorporate changes in the draft responses made as a result of a number of GE-NRC meetings to review the draft information.

We are requesting that the attached information be withheld fron public disclosure and considered as proprietary pursuant to Section 2.790 of 10CFR Part 2.

Very truly yours.

F'. "

'rk, Manager je #

B! Systems Licensing Nuclear Safety & Licensing Operation Attachments cc:

F.J. Miraglia (NRC) w/o attach L.S. Gifford (GE) w/o attach I

D.C. Scaletti (NRC) w/o attach R. Villa (GE)

A. Thadant (NRC) w/o attach J.N. Fox (GE)

C C.O. Thomas (NRC) w/o attach

-)

N 73 GENERAL ELECTRIC C0MPANY AF'FIDAVIT 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 proprietary information 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 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 competi-tive 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; KWH:rm/A041911 4/19/84

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, produc-tion 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 m.eeting 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 signifi-cant or potentially significant fnformation.

Furnishing the docu-ment 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 proprie-tary 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 KWH:rm/A041911 4/19/84

9 Operation for technical content, competitive effect and deter-mination of the accuracy of the proprietary designation in accord-ance with the standards enumerated above.

Disclosures outside General Electric are, generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or proprietary agreements.

8.

The 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 infor-mation 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:

It was developed with the expenditure of resources exceeding a.

$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 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 develop an ECCS methodology at lower cost than General Electric.

i KWH:rm/A041911 4/19/84

4 STATE OF CALIFORNIA

) ***

COUNTY OF SANTA CLARA

)

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 $ day of SBE.i \\

, 198 I

Jo,IdahIF. Quirk' Ge%ral Electric Company Subscribed and sworn before me this $ day of hDR_

198

/

o ggg, sg[

A }rl) bw.

KAREN 5. VOGELHUBER g' NOTARY PUBLIC, STATE OF(AALIFORNIA W,'{!.p NOTARY Putuc.CAUFORNIA 0

5ANTA CLARA COUNTY $

$ My Commission Expim Dec. 21,1984 E

bot oco:'soto:e:cm. :.

..we#

1 KWH:rm/A041911 4/19/84

Treatment af FIra and Fland Event unearfaintv in the GE analyses of fire and flood events, no explicit uncertainty analyses were perf reed.

Uncertainty analys'.4 were carried out for the Internal plant events and for the solamic analysis.

It Is GE's belief that the fire and flood analyses are closer to upper bound estimates than best estimates.

As noted In response to NRC staf f questions, conservative evaluations were perf ormed of fire propagation and suppression, evallability of Internal flood. sources and in fire propagation modeling.

Fur-therare, the driving force for fire and flood events (i.e., quantitles of com-bustible materials, evallable water zources, etc.) are better understood than driving forces f or seismic events, leading one to conclude that the uncertain-ties should probably be smaller.

By comparison to the Internal events, the contribution to core densge frecuericy and plant risk associated with fire-and f amod-Initta+=d events is_s_maj_l-

! 4.

I". ' :

Therefore, based on the proceding Information, It is concluded that a detailed, quantitative uncertainty analysis is not warranted.

t

- _ -... -... _..

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