ML20133A309
| ML20133A309 | |
| Person / Time | |
|---|---|
| Site: | 05000447 |
| Issue date: | 04/19/1985 |
| From: | Rubin M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20133A243 | List: |
| References | |
| FOIA-84-175, FOIA-84-A-66 84-2833, NUDOCS 8507200058 | |
| Download: ML20133A309 (23) | |
Text
(
.a UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
)
UNION OF CONCERNED SCIENTISTS,
)
)
Plaintiff,
)
)
v.
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Civil Action
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No. 84-2833 UNITED STATES NUCLEAR REGULATORY
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COfDiISSION and UNITED STATES
),
OF AMERICA,
)
)
Defendants,
)
)
and
)
)
GENERAL ELECTRIC COMPANY,
)
)
Intervenor.
)
)
DECLARATION OF MARK P. RUBIN I, Mark Rubin, declare:
1.
I previously submitted declarations on Febru-ary 1, 1985 and February 5, 1985.
The purpoFe of this declaration is to update the previous declarations to address matters raised in the Union of Concerned Scientists' Motion for Summary Judgment.
I have also revised the attached indices of withheld and released material to reflect'recent releases by the General Electric Company and to correct errors in the original indices.
8507200058 850503 PDR FOIA CURRAN 84-A-AA PDR
2 2.
UCS specified ten categories of information it believes can be released without causing GE competitive injury.
These categories, identified in paragraph twenty-two of Steven C. Sholly's March 18, 1985 declaration contain virtually all the significant results of the PRA.
These results include the outputs of the fault trees and event trees and identify the most significant branches of the
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i event trees.
The ten categories also include assumptions used by GE to obtain its results (category a) and divulge the elements of the methodology GE used in grouping the accident release categories (category c).
I evaluated this material as part of my review for Mr. Dircks January 31, 1985 decision and found that its release would cause similar harm to GE's competitive position as the other withheld portions.
3.
I recently reviewed UCS's explanation for its belief that the material can be released without causing GE 1
competitive harm and my opinion remains the same as before.
UCS stated that a competitor could not submit this informa-tion to the NRC without supporting documentation and could not use this information to recreate other proprietary parts of the.GESSAR-II PRA.
Even if these statements were true, the information can assist GE's competitors in other ways.
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t As a thorough set of PRA results, the information would provide guidance to competitors in determining methods of approach in performing BWR/6 PRAs, in such areas as accident sequence construction and containment modeling.
The information also would provide competitors with the means to compare elements of their PRAs with the GESSAR-II PRA.
Competitors also could use the mater,ial to identify where their results differed significantly from GE's results and possibly deduce the methodologies and assumptions GE utilized in obtaining its results.
From this insight, competitors could identify potential inaccuracies or deficiencies in their PRAs and concentrate their efforts on these areas.
Detailed results also would allow competitors to identify and focus their attention on the most risk significant elements arising from a BWR/6 PRA.
All these factors would allow the competitors W -
4 to reduce the effort necessary to produce a PRA.
Therefore, the ten categories of material identified by UCS have commercial value, and their release would cause GE competitive harm.
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I declare under penalty of perjury that the foregoing is true and correct.
Ey.ecuted on this]9 day of April, 1985.
Mark P. Rubin '
~
Office of Nuclear Reactor Reculations U.S.
Nuclear Regulatory Commission
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I ATTACHMENT 1 r
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Index of Material with Commercial Value Document #1:
GESSAR-II Ap(undated) pendix 15.D.3, BWR/6 Probabilistic Risk Assessment Pages Containing Haterial To Be Deleted Description of Deleted Material 9
Assumptions and criteria for event tree fo'rmulation, inputs to event tree construction and'quantification 37 Data base information-Transient Frequencies 39 Data base information-Transient Frequencies 43-46 Analytical inputs to the fault tree construction and quantification; modeling of equipment reliability & availability, multiple failures, human error, interdependencies 48-56 Development of success criteria for mitigation of accidents, and their use in l'
event trees i,
4 9
4
C Pages Containing Material To Be Deleted Description of Deleted Material 58-61 Development of success criteria, and tables of success criteria 62 Inputs to event tree construction, and specification of accident classes 63 Event tree results 64 Event tree 66-68 Event tree quantification results 89-97 Inputs to event tree construction and quantification, analysis of steam explosion and other fission product release paths 101-102 Identification of containment event tree classes 103 Event tree 104 Consolidated release sequences
Pages Containing Material To Be Deleted Description of Deleted Material 105 Containment relesae categories for release sequences 108 Event tree results, assessed frequency of release categories a
157-171 Input data for fault tree and event tree 173-177 quantification 179-194 207-210 Event tree assumptions and inputs to event 224-225 tree construction and quantification 226-227 Event tree results, Accident sequence frequency
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229 Event tree 230 Inputs to event tree construction 231 Event tree results, frequency of accident j
sequences
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232 Inputs to event tree construction 3
I Pages Containing Material To Be Deleted Description of Deleted Material i
233 Event tree l
234-240 Inputs to event tree construction and j
quantification, application of success criteria and accident progression 4
241-243 Event tree 244-248 Inputs to event tree construction and i
quantification 249-251 Event trees 252-256 Inputs to event tree construction and quantification and accident progression 257-262 Event tree 263-269 Inputs to event tree construction 270-273 Event tree 274 Inputs to event tree construction 4
Pages Containing Material To Be Deleted Description of Deleted Material 72.c15 Event s,
V9-276 Inputs to event tree construction 277 Event tree 4
278 Inputs to event tree construction 279 Event tree 280-283 Inputs to event tree construction 284 Event tree 285-288 Inputs to event tree construction 289 Event tree 290-296 Inputs to event tree construction 298-300 List of Accident classes and containment event trees 302-312 Event tree 5
o 1
Pages Containing Material To Be i
Deleted Description of Deleted Material 313-324 Input to Corral and CRAC computer codes-332-333 Fault trees 335 System fault trees and system unavailabilities 336-514 Fault. trees 530-547 Description and application of computer codes used for assessment of containment event trees 549-560 Analysis of phenomena used as inputs to quantify and construct containment event trees, results of containment analysis 562-574 Analysis of fission product release from 576-590 the core and consequence analysis 596-600 Analysis of phenomena used as inputs to quantify and construct containment event trees, containment structural analysis 6
Pages Containing Material To Be Deleted Description of Deleted Material 602-603 Pressure limits for containment structure 606-624 Containment stress analysis r
626-633 1
635, 637-679 702-708 Assessment of vessel steam explosion 715-733 738-750, 753 Results of relevant experimental work on steam explosion d'
754-766 /'
Interpretation of experimental results, f
,s' fuel-water interaction
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-.x 774-781 Evaluation of Sandia steam explosion experiments 789-799 Assessment of containment hydrogen 803-808 detonation i
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Document #2:
12/3/82 Submittal of Proprietary infonnation for review of 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II)
Pages Containing Material To Be Deleted Description of Deleted Material --
568, 569, 574, 583 Assessment of fission product transport and deposition e
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Document #3:
Revised Appendices C and D to the GESSAR II PRA (undated)
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Pages Containing Material To Be Deleted Description of Deleted Material Appendix C Sequence Event tree and supporting 207-210, 225-228, analysis 230-233, 234A-276, 277a-279, 280a-282, 283a-302, 304-305, 307a-328 Appendix D Fault tree, inputs to fault tree 335-344 construction and quantification, includes 346-514/24 data base information i
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Document #5:
9/21/83 Letter to D.G. Eisenhut from J.F. Quirk re:
GESSAR II Seismic Event Analysis Pages Containing Materials To Be Deleted Description of Deleted Material 22-24, 26-27 Fragility development which is an input to 28-30, 31-52 fault tree quantification 9
57-81 Fragility development 85, 86, 87 Development of seismic event trees and 90-95 fault trees, methodology for their construction and quantificatior.; inputs for event tree and fault tree construction and quantification; and results96-100 Seismic event trees 101-108 Seismic fault trees 118-128 f5thodologyandanalysisofphysical phenomena to assess failure modes and fission product release pathways used to I
Pages Containing Materials To Be Deleted Description of Deleted Material quantify containment event trees and release sequences s
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B 2
Document #7:
11/7/83 Letter to D.G. Eisenhut from J.F. Quirk re:
GESSAR 11 Fire and Flood External Event Analysis Pages Containing Material To Be Deleted Description of Deleted Material 2-6, 2-8, through 2-10, Analysis of fire hazards which provide 2-13 through 2-18, inputs to construction and quantification 2-22 through 2-27 of fire initi,ated accident sequence event trees 2-34 through 2-42 Event' trees 3-4 through 3-13 Flood hazard analysis which provides inputs to construction and quantification of event trees, includes release frequency analysis 3-16 through 3-18 Release category assignment and event tree
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Document #8:
11/17/83 Letter to D.G. Eisenhut from J.F. Quirk re:
GESSAR II Internal Event PRA Uncertainty Analysis Pages Containing Material To Be Deleted Description of Deleted Material 4 through 12 Description of analytical approach and inputs to uncertainty analysis, includes data from eve,nt and fault trees 16 Results to uncertainty analysis 19 Results of analysis, cumulative core damage frequency by event release sequences A-1 through A-2 Uncertainty Analysis, Equations and data A-4 through A-9 base A-11 through A-14 A-16 through A-19 A-21 through A-36 i.-
Document #10:
12/29/83 Letter to D.G. Eisenhut from J.F. Quirk re:
6ESSAR II Seismic Event Uncertainty Analysis Pages Containing Material To Be Deleted Description of Deletions 4, 5, 8, 11, 12 Assumptions which were used as input to the analysis and description of methodology, including results Appendix A 1-8 Assumptions, inputs and methodology used to quantify the PRA uncertainty Appendix B 1-3 Assumptions, inputs and methodology used to quantify the PRA uncertainty l
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Document fl9: 7/16/82 Letter to R. Frahm from K.W. Holtzclaw re: 238 Nuclear Island Probabilistic Risk Assessment Report Pages Containing Materials To Be Deleted Description of Deleted Material 568, 569, 574, 583 Assessment of fission product transport and deposition a-e
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h 3
i ATTACHMENT 2
Index of materia'i claimed as proprietary, which staff review has shown to have insufficient basis.
Document il 9, 37, 38, 45, 66, 101, 104, 178, 223, 224, 329-331, 334, 527, 528, 529, 530, 562, 680, 685-695, 752 Document #2 588, 589 Document #3 224, 225, 333, 334 Document f5 9, 12, 13, 15, 19-20, 84-87 Document #7 2-7, 2-10, 2-12, 2-14 through 2-18 Document #8 3, 14 Document #10 2, 3, 9, 11 Document #19 589
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APPENDIX D 1
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