ML17256A750
| ML17256A750 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/31/1983 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| LSO5-83-05-072, LSO5-83-5-72, NUDOCS 8306060296 | |
| Download: ML17256A750 (10) | |
Text
JI Docket No. 50-244 LS05-83-05-072 Mr. John E. Maier, Vice President Electric and Steam Production-Rochester Gas and Electric-Corporati on 89 East Avenue Rochester, New York 14649 May 31, 1983 DISTR IBUT ION Docket NRC PDR Local PDR ORB Reading NSIC DCrutchfiel d HSmith GDick OELD ELJordan JMTaylor ACRS (10)
SEPB Jzwolinski TIppo1 ito
Dear Mr. Haier:
SUBJECT:
CLARIFICATION OF ENVIRONl1ENTAL QUALIFICATION SAFETY EVALUATION REPORT R. E. Ginna Nuclear Power Plant On December 13, 1982, the NRC staff issued a Safety Evaluation (SE) on the environmental qualification of safety-related electrical equipment.
The SE was based on a Technical Evaluation Report (TER) prepared by our contractor, Franklin Research Center (FRC).
Appendix D of the referenced TER provides a technical review of your state-ments regarding the justification for continued operation (JCO) that was submitted in the 90-day response to an earlier staff safety evaluation (pubished in mid-1981).
Appendix D is not necessarily applicable to the deficiencies identified in the enclosed TER.
You should review all JCOs submitted to date to ensure that a JCO exists for all equipment which may not be qualified.
The thirty (30) day response required by the current SE should address equipment items in NRC Categories I.B, II.A and IV ( note the Category IV was not mentioned in the previous SER) for which justification for continued operation was not previously submitted to the NRC or FRC.
Guidelines for justification for continued operation are provided in paragraph (i) of 10 CFR 50.49.
These guidelines should be utilized in developing your justification for continued operation.
Please review your February 1,
1983 response in accordance with this clarification and notify the NRC of any changes.
The due date of these responses as stated in the above referenced SE are revised and are now due within thirty (30) days of receipt of this letter.
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PDR OFFICE lI SUANAMElI DATE 1I
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ter. John E.
I fa fer Hay 31, 1983 Upon completion of the plant specific review for all plants, a cross-reference of non-qualified equipment existing in any plant will he 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.
Sincerely, Original signed by Dennis th.'rutchfield, Chief Operating Reactors Branch ¹5 Division of Licensing
Enclosure:
Proprietary Review Information cc w/enclosure:
See next page
- SEE PREVIOUS TISSUE FOR CONCURRENCE D'B'
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t USQ PO'981-4Y~960 OFFlClAL RECORD COP NRC FORM 318 (10.80) NRCM 0240 The ninety (90) day response required by the above referenced SE transmittal letter regarding the schedule for accomplishing proposed corrective actions has been superseded by the requirements of 10 CFR 50.49.
Paragraph (g) of the rule requires that by tray 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 submfttal required by the rule should specifically indicate whether your previous submittals comply with paragraph (a) and (b) of 10 CFR 50.49.
In addition, you are requested to describe in your submittal the methods u~~.- 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 previous'ly 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 (30) days. of receipt of thfs letter.
A general guideline is enclosed.
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t<r. John E, I1aier The ninety (90) day response required by the above referenced SE transmittal letter regarding the schedule for accomplishing proposed corrective actions has been superseded by the requirements of 10 CFR 50.49.
Paragraph (g) of the rule requires that by IIay 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)(0) 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.
Me 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 (30) days of receipt of this letter.
A general guideine is enclosed.
Sincerely,
Enclosure:
Proprietary Review Information cc w/enclosure:
See next page Dennis hl. Crutchfield, Chief Operating Reactors Branch ¹5 Division of Licensing OFFICE/
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Nr. John E. Naier. Nay 31, 1983 CC Harry H. Voigt, Esquire
- LeBoeuf, Lamb, Leiby and NacRae 1333 Hew Hampshire Avenue, N.
W.
Sui te 1100 Washington, D.
C.
20036 Nr. Hichael Slade 12 Trailwood Circle Rochester, Hew York 14618 Ezra Bialik Assistant Attorney General Environmental Protection Bureau
'New York State Department of Law 2 World Trade Center Hew York, New York 10047 U. S. Environmental Protection Agency Region II Office ATTN:
Regional Radiation Representative 26 Federal Plaza New York, Hew York 10007 Herbert Grossman, Esq.,
Chairman Atomic Safety and Licensing Board U. S.'uclear Regulatory Commission Washington, D. C.
20555
-Regional Administratoir'uclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Resident Inspector R.
E. Ginna Plant c/o U. S.
HRC
,1503 Lake Road
- Ontario, Hew York 14519 Director, Bureau of Nuclear Operations State of Hew York Energy Office Agency Building 2 Empire State Plaza
- Albany, Hew York 12223
Supervisor of the Town
.of Ontario 107 Ridge Road West
- Ontario, Hew York 14519 Dr.
Emmeth A. Luebke' Atomic Safety and Licensing Board U. S.-Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D. C.
20555
I
- -N CLOS UR:.
PR"."-.=.l= T~RY. R"-.VI"=l'U.'D"-LINES It is th p;licy of the. Nuclear Regulatory Commission that the records of the agency are avail'able for inspection and copying in the NRC Public Ihcument Room, except for matters that are exempt from public disclosure pursuant to the nine exemptions of the-Freedom of-Information Act.
(See 10 C.F.R. 2.790)
- Pecently, the NPC has had its contractor, Franklin Research Center (FRC),
'repare Technical Evaluation Reports. for all 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 documentation 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
~hat was marked or claimed to be proprietary is marked at the top of the page with the legend "Proprietary Information'l.
FRC has used this marking, in a liberal manner and has not fully investigated the licensee's claim to determine whe.her portions of proprietary reports that they reproduced or.
'mentioned 'were in fact "proprietary".
A report typically contains 15 to 25 pages that are marked "Proprietary Information".
- Usually, no more than 4 licensee proprietary references are so discussed.
In order to make any of the reports available.to -the public, FRC has produced two versions of each:
those containing proprietary information and those having the pro-prietary in>ormation removed.
The NRC now seeks the assistance of licensees in reviewing the proprietary 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 gualification SER and a copy of the.proprjetary version of the FRC TEchnical Evaluation Report.
It is believed that the licensee can review the few pages containing proprietary informaiion 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 ii:s test report.
The third party owner can quickly review these pages and determine whether the information-claimed to be proprieta'ry must still be so categorized.
All reviewers should be aware of the NRC's policy, as specified in SECY-81-119, that sumnary data on Equipment gualification testing will not be treated as proprietary by the NRC. If the review identifies no data that requires protection, the HRC should be no ified and hat portion of the report will be placed in the Public Document Room.
If, however, the licensee identifies to the HRC portions that are still claimed to require proprietary protection, then compliance.
must..be made wi.h 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
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1 those s:--,=- portions,ca..
be pro.ectec aoain simply by notifying the tiRC that th'.s mater i~1 i'overed in the t~RC's acceptance letter of a given'date.
the re,erence proprie-.ary report has not previously been submit ed to the NRC pursuant to 10 C.F.R. 2.790, then the licensee and the proprietary owner must a. this time make such an application and request for withholding from public disclosure.
The tiRC 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 to make all non-proprietary information, public, and the only way to'protect the owner of proprietary information is to insure
. that the Franklin reports have Peen appropriately scrutinized.
. The HRC will grant extensions of time for these reviews 1f necessary, on a case-by-case basis.
If you have any further questions regarding this
- review, please contact either Edward Shomaker, OELD, at 492-8653 or lieal Abrams, Patent
- Counsel, at 492-8662.