ML18139C302
| ML18139C302 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/04/1983 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8304130496 | |
| Download: ML18139C302 (5) | |
Text
~PR 4 1983 Docket Nos. 50-280 and 50-281 Mr. vJ. L. Stewart Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond~ Virgfoia 23261
Dear Mr. Stewart:
DISTRIBU.
N.
Docket F11e NRC PDR Local PDR.
ORB 1 File D. Eisenhut OELD E. L. Jordan D. Neighbors C. Parrish ORAB EQB NSIC J. M. Taylor ACRS (10)
J. Heltemes
SUBJECT:
CLARIFICATION OF ENVIRONMENTAL QUALIFICATION SAFETY EVALUATION REPORT On January 26, 1983, the rmc staff issued a Safety Evaluation (SE) for Surry Power Station, Unit Nos. land 2 on the environmental qualification of safety-related electrical eqipment.
The SE was based on Technical Evaluation Reports (TERs) prepared by our contractor, Franklin Research Center.
Appendix D of the above TER provides a technical review of your statements regarding the justification for continued operation (JCO) that was submitted in the 90-day response to an earlier staff safety evaluation (published in mid-1981).
Appendix Dis not necessarily applicable to the deficiencies identified in the referenced TER.
It is our understanding that you reviewed 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 was to address equipment items in NRC Categories I.B, II.A and IV (note that Category IV was not mentioned in the previous SER) for which justification for continued operation was not previously submitted to the NRC or Franklin. Guidelines for justification for continued operation are provided in paragraph (i) of 10 CFR 50.49.
Your thirty (30) day response was submitted to NRC on March 9, 1983, and you are requested to review your response in accordance with this clarification and notify the NRC of any changes.
Any changes to your response are due withinn thirty (30) days of receipt of this* letter.
Category I I. B items of the SER were addressed by your 1 etters dated February 23, March 1, and March 9, 1983.
Our letter dated March 25, 1983, provided our safety evaluation of the II.B items.
The ninety {90) clay 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 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 I
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NRCFORM318(10-B0)NRCM0240 OFFICIAL RECORD COPY USGP0:1961-335-960
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- ,i Mr. W. APR 4 1983 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 infonn 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 MRC 1s 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 guideline is enclosed.
Enclosure:
Proprietary Review Information cc w/enclosure:
See next page Sincerely, Original signed by; So Ao Varga Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing
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Mr. W. L. Stewart Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager P. o. Box 315
$urry, Virginia 23883 Donald J. Burke, Resident Inspecto~
Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166 Route 1 Surry, Virginia 23883 Mr. J. H. Ferguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Rtchmond, Virginia 23261
. James P. O'Reilly Regional Administrator - Region II
- u. s*. Nuclear Regulatory-Commission*
101 Marietta Street, Suife 3100 Atlanta~ Georgia 30303 e
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PROPRIETARY REVIEW 1'GUIDELINES It is the po'licy of the Nuclear Regulatory Commission that the records of the agency are available for inspection and copying in the NRC Public
~cum2nt Room, except for mcitters that are exempt from public.disclosure pursuant to the :1ine* exemptions of the Freedom of*Infonnation Act.
(See 10 C.F.R. 2.790)
Recently, the NRC ha*s had *its con-tra*ctor, Frankl in Research Center ( FRC),
prepare Technical Evaluation Reports. for all 10 -cm Part 50 licensees.
These reports evalua;? and comment upon the references cited by the licensee as evidence of qualification in accordance i!iith the doc"Clmentatfori reference i_n_structi ons ~s:tabl i shed tiy IE Bulletin 79..,QlB.
In a typical evaluation, FRC generates a report of approximately 75{) 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
- c.;e \\*
- it.h the le3end "Pro~rietary *Information".
FRC has used this marking in a liberal manner and has not fully investigated the licensee's claim to detennine whether portion~ of pr~prietary reports that they reproduced or me:.tioned were in fact "proprietary".
A report t;ypically contains 15 to 25 pages that are marked "Propri,etary Infonn-ation".-
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 co.ntaining proprie-fary information. and those having. the pro.-
prietary informatic11 re;nov~d.
The NRC now seeks the assistaRce of. ricens*ees
~in reviewing thi proprietary versions of the FRC reports to determine whether still mor3 informatign 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 carty owner 6f the reference report, which has been cl aimed to be proprietary, a copy of tflose pages from the FRC report that relates to its test report.
The.third party owner can quickly revi.ew these pages and determine whether the infonnation*claimed to be proprietary must still be so categorized.
All reviewers should be aware of the NRC 1s policy, as specified in SECY-81-119, that sunmary data on Equipment Qualification testing will not be treated as proprietary by the NRC.
If the review identifies no data that requires protectio.n, the NRC should be notified and.that portion of the repor*t-.xlill _be placed in the-Public DJcument Room.
If, ho1-1ever, the licensee.ldentifies to the NRC portions.
that are still claimed to require proprietary protection, then compliance
~~:t be ~ade with the requ~re~ents for withholding under*lO C.F.R. 2.790.
- This can be accompl ;*shed in two ways:
(1) If the reference proprietary r~port has previously been submitted to the NRC pursuant to 10 C.F.R. 2.790 and the rrnc has r.;ade a determination that portions a*re proprietary, then
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e e those same portions can -be.protected again simply by notifying the N_Rc-that this mat.er*ic.:l i~. cqvered in the NRC's acceptance letter of a given date.
If the reference proprietary report has ne.:t previously bee:i stibmitted to the NRC p*.1rs1.1ant to 10 C.F.R. 2.790, then the licensee and the proprietary owner
~Jst at this time make such an application and request for withholding from p:..iblic disclosure.
The i,~C recognizes that this proprieta~y revie1-,, places an administrative'.
burde!'l upon its licensees and any third party owners.
However, it is the-pJiic/ of the rrnc ta. make.all non~-pr:oprietary information public, and the only way to protect the owner of proprietary information is to insure that the Franklin J'.'eports have been *appropriately scrutinized.
The NRC will grant extensions of time for*these revi~ws if necessary, on
- a case-by-c-a-5 basis~
-If-you have any further questions reg*arding this revie~, please contact either Edward Shomaker, DELO, at 492-8653 o~
Neal Abrams, Patent Counsel, at 492-8662.
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