ML14184A391
| ML14184A391 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/28/1983 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Utley E Carolina Power & Light Co |
| References | |
| NUDOCS 8305170597 | |
| Download: ML14184A391 (5) | |
Text
DISTRIBN Docket File NRC PDR Local PDR APR 2 8 19Q ORB 1 File D. Eisenhut OELD E. Jordan Docket No. 50-261 G. Requa C. Parrish J. Calvo Mr. E..E. Utley, Executive Vice President NSIC Power Supply and Engineering & Construction J. Taylor Carolina Power and Light Company ACRS (10)
Post Office Box 1551 Raleigh, North Carolina 27602
Dear Mr. Utley:
SUBJECT:
CLARIFICATION OF ENVIRONMENTAL QUALIFICATION SAFETY EVALUATION REPORT By letter dated January 5, 1983, we provided our Safety Evaluation, including our contractor's Technical Evaluation Report (TER) for the Environmental Qualification of Electrical Equipment for H. B. Robinson Unit No. 2. We requested that you either reaffirm or provide justification for continued operation for those items, identified in the TER, as Categories I.B, II.A and II.B within thirty days of receipt of the Safety Evaluation.
Your letter dated February 11, 1983, responded to our request indicating that your previous submittals provided the necessary justification. However, during subsequent discussions with your staff, we concluded that the TER Appendix D conclusions were applicable only while the staff and its contractor were performing the evaluation and, therefore, may require a reassessment based on final conclusions and categorizations of specific items. Based on these discussions, you have reassessed the Category II.B items 16 and 17 and provided justification for continued operation in your letter dated March 4, 1983.
Our SER for Category II.B was issued to you by our letter dated March 29,, 1983.
The thirty day response required by our letter dated January 5, 1983, should have addressed items in NRC Categories I.B, II.A and IV (note that Category IV was not mentioned in the provious SER) for which justification for continued operation was not previously submitted to the NRC or Franklin. Your letter dated February 11, 1983, responded to our thirty day request. However, in the interim the 10 CFR 50.49 guidelines for justifying continued operations was issued. Therefore, since your thirty day response has already been submitted to the NRC, you are requested to review your response In accordance with the 10 CFR 50.49 clarification, including Item IV, and notify the NRC of any changes to your previous submittal.
This information is requested within thirty days of receipt of this letter.
8305170597 830428 PDR ADOCK 05000261 P
PDR OFFICE)
SURNAME NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
APR 2 8 1983 Mr. E. E. Utley
- 2 Upon completion of the plant specific review for all plants, a cross-reference of non-qualified equipment existing in any plant will be conducted by the NRC staff to determine if the same equipment exists on other plants and has been declared qualified. Should the cross-reference indicate that they do exist.in your plant, the staff will contact you to reconfirm the qualification of these items for your plant.
The ninety day response required by the January 5, 1983, SE transmittal letter regarding the schedule for accomplishing proposed corrective actions has been superseded by the requirements of 10 CFF 50.49. Paragraph (g) of the rule requires that by May 20, 1983, licensees identify electrical equipment important to safety, within the scope of the rule, that is already qualified, and submit a schedule for the qualification or replacement of the remaining electrical equipment within the scope of the rule in accordance with the qualification deadline specified in paragraph (g). The submittal required by the rule should specifically indicate whether your previous submittals comply with paragraphs (a) and (b) of 10 CFR 50.49. In addition, you are requested to describe in your submittal the methods used to identify the equipment covered by paragraph 10 CFR 50.49(b)(2) and to establish any qualification programs not previously described for such equipment.
The Technical Evaluation Report contains certain identified information which you have previously claimed to be proprietary. We request that you inform us as indicated in the proprietary review section of the Safety Evaluation whether any portions of the identified pages still require proprietary protection. It should be noted that the NRC's policy on proprietary information, as specified in SECY 81-119, is that summary data on equipment qualification testing will not be treated as proprietary by the NRC. This information shall be submitted within thirty days of receipt of this letter. A general guideline is enclosed.
Sincerely, original signed by S. A. Varga Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing
Enclosure:
As stated cc w/enclosure:
See next page ORB 1 ORAB 0 0 CIIE
.eOu
"'TA t "s.
SY' sURNAME)
NRC FORM 318 (10-80) NRCMO024o OFFICIAL RECORD CO PY USGPO: 1981-335-960
Mr. E. E. Utley Carolina Power and Light Company cc: G. F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Resident Inspector's Office H. B. Robinson Steam Electric Plant Route 5, Box 266-lA Hartsville, South Carolina 29550 James P. O'Reilly Regional Administrator - Region II U. S. Nuclear Regulatory Commission 101 Marietta Street - Suite 3100 Atlanta, Georgia 30303
0e*9 ENCLOSURE PROPRIETARY REVIEW GUIDELINES It is the policy of the Nuclear Regulatory Commission that the records of the agency are available for inspection and copying in the NRC Public
- t om, except foratters that are exempt from public. disclosure pursuant to the nine exemptions of the Freedom of Information Act.
(See 10 C.F.R. 2.790)
Recently, the NRC has had'its cOntra-ctor, Franklin Research Center (FRC),
prepare Technical Evaluation Reports. for aTl 10 CFR Part 50 licensees.
These reports evaluate and comment upon the references cited by the licensee as evidence of qualification in accordance with the docitmentation reference instructions established by IE Bulletin 79-01B.
In a typical evaluation, FRC generates a report of approximately 750 pages.
Any page which mentions or comments upon a licensee's referenced material that was marked or claimed to be proprietary is marked at the top of the pace with the legend "Proprietary Information".
FRC has used this marking in a liberal manner and has not fully investigated the licensee's claim to determine whether portions of proprietary reports that they reproduced or mentioned were in fact "proprietary".
A report typically contains 15 to 25 pages that are marked "Propri-etary Information". Usually, no more than 4 licensee proprietary referen-ces are so discussed. In order to make any of the reports available to the public, FRC has produced two versions of each: those containing propriefary information and-those having the pro prietary informatioh removed.
The NRC now seeks the assistance of Ticensees in reviewing the proprietaIry versions of the FRC reports to determine whether still more information can be made available to the public.
For this reason, each licensee has been sent the Staff Equipment Qualification SER and a copy of the proprietary version of the FRC TEchnical Evaluation Report.
It is believed that the licensee can review the few pages containing proprietary information in a relatively short period of time. The licensee is to send the third party owner of the reference report, which has been claimed to be proprietary, a copy of those pages from the FRC report that relates to its test report.
The third party owner can quickly review these pages and determine whether the information-claimed to be proprietary must still be so categorized.
All reviewers should be aware of the NRC's policy, as specified in SECY-81-119, that summary data on Equipment Qualification testing will not be treated as proprietary by the NRC.
If the review identifies no data that requires protection, the NRC should be notified and.that portion of the report,.will be placed in the Public Document Room.
If, however, the licensee identifies to the NRC portions that are still claimed to require proprietary protection, then compliance mjst be made with the requirements for withholding under 10 C.F.R. 2.790.
This can be accomplished in two ways: (1) If the reference proprietary report has previously been submitted to the NRC pursuant to 10 C.F.R. 2.790 and the NRC has made a determination that portions are proprietary, then
S
-2 those same portions can be.protected again simply by notifying the NRC that this naterial is covered in the NRCs acceptance letter of a given date.
If the reference proprietary report has not previously been submitted to the N.C pu-sIant to 10 C.F.R. 2.790, then the licensee and the proprietary owner must at this time make such an application and request for withholding from pubtic disc7csure.
The NRC recognizes that this proprietary review places an administrative burden Upon its licensees and any third party owners.
However, it is the policy of the NRC ta make.al.1 non-proprietary information public, and the only way to protect the owner of proprietary information is to insure that the Franklin reports have been appropriately scrutinized.
The NRC will grant extensions of time for these reviews if necessary, on a case-by-c-ase basis. If-you have any further questions regarding this review, please contact either Edward Shomaker, OELD, at 492-8653 or Neal Abrams, Patent Counsel, at 492-8662.
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