ML19340B762
| ML19340B762 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| TASK-IR, TASK-SE IEB-79-01B, IEB-79-1B, SECY-80-367, NUDOCS 8011120079 | |
| Download: ML19340B762 (4) | |
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UNITED STATES Aucust 6, 1980 NUCLEAR REGULATORY COMMISSION SECY-CO-367 WAsHIN GTON, D. C. 20555
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INFORMATION REPORT FOR:
The Comissioners N
FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation THRU:
Office of the Executive Direc.r for Operations
SUBJECT:
ENVIRONMENTAL QUALIFICATION OF CLASS IE ELECTRICAL EQUIPMENT - RELEASE OF PROPRIETARY QUALIFICATION INFORMATION AND NUCLEAR INDUSTRY CLEARINGHOUSE PURPOSE:
To inform the Comissioners of the results of the staff investigation into the possible release of proprietary qualification data on Class IE electrical equipment for use by licensees and to discuss the establishment of a nuclear industry equipment clearinghouse.
DISCUSSION:
The Comission Memorandum and Order (CLI-80-21) dated May 23, 1980, directed the staff to review, within 45 days, environmental qualification infor-mation in its possession to determine-how much of the information may be released to licensees to aid them in making safety judgments and to forward the results of this review to the Comission.
The staff was further directed to promptly pursue the possibility of the establishment, by the nuclear industry, of a Nuclear Qualified Equipment Clearing-house which would have as its objective the sharing by all parties of environmental qualification infor-mation.
Both Comission directives deal with the concern that information vital to qualification judgments may not be receiving appropriate dissem-ination.
In response to the Comission Memorandum and Order, the staff held meetings with representatives of NSSS vendors, utilities, and component vendors to gain insight into both the problems of proprietary data submittals and the possibility of establishing an industry run clearinghouse.
CONTACT:
Z. R. Rosztoczy NRR:DE:EQB X28035 8011120 G79 x
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The results of these meetings and the ensuing staff positions are discussed below. The bottom line prob-lem vis-a-vis proprietary information is not the lack of sharing of proprietary documents but the lack of viable documentation to prove that equipment in operating plants is qualified to the 3cceptance criteria in the DOR Guidelines.
By way of example, when the Comission issued CLI-80-21 the staff had in its possession only 26 documenta con-cerning the qualification of components and of that number only 10 were claimed te be proprietary.
As of July 1,1980 the staff had 65 documents (of approx-imately 300 referenced in Bulletin 79-01B responses) and approximately 13 were claimed to be proprietary.
- Thus, even if all of these 13 documents were made available to other licensees, this would only be limited help in the resolution of the equipment qualification problems.
Further,a test report is not of itself sufficient to qualify a given component.
A licensee must examine the parameters of a test to see if it envelopes the component in question (such as by model #, type, and installation configuration within the plant) and if it envelopes the specific environmental parameters at the licensee's facil-ity.
Then the licensee still has to certify that the test results are fully applicable and valid for qualifying his specific components.
This process involves the traceability of design, manufacturing processes and materials of construc-tion to the licensee's component.
This certification process is an important and difficult problem facing equipment quali-fication today.
Additionally, based on discussion with the licensees, NSSS vendors and component suppliers, it became apparent that the proprietary test reports, with few exceptions, are available to all licensees, from the originators, either free or for a reasonable fee.
Therefore, the staff concludes that there is no overwhelming public. sed at this time for the Comission to release the proprietary test reports.
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e There is, however, a need to make available "all" test reports to interested utilities.
We found one instance where this is not done.
The General Electric Conpany's policy is to maintain all test reports at their office in San Jose.
While such reports can be inspected at San Jose, the utilities are not permitted to retain these reports.
In ad-dition, the NRC has yet to receive a copy of these reports for review.
Turning to the topic of setting up a clearinghouse for the release of equipment qualification infor-mation, our meetings have revealed that a group of utilities is already implementing an Equipment Qualification Data Bank (EQDB).
Other utilities are welcome to join.
The data bank provides means for sharing summaries of test data information.
Utilities will use the data bank in the process of establishing qualifications for existing equipment as well as for the selection of new equipment.
The data bank is expected to be operational early in 1981.
Thus, it will not provide assistance to the preparations of the current submittals.
Furthermore, the data bank will not resolve the certification problem because it is only a facilitator for deter-mining who has available test data and it does not address the traceability process as outlined above.
Successful operation of the data bank is dependent on the availability of equipment qualification information in the summary form.
We found that all but one supplier publicly released all summary information.
Westinghouse claims that equipment model numbers, which are required to make the summary type information useful, are some-times proprietary.
In the review of the equipment qualification data submitted by licensees, the staff has recognized the need for a sophisticated data handling system.
Such a system has already been developed and entering of the data into the NRC system is in progress.
Distinct l
differences exist between the NRC system and the utility x
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data bank.
Both of them are in a relatively advanced stage.
Combining the two systems at this time would neither accelerate the equipment qualification review nor would it result in significant savings.
Based on the finding, discussed above, the staff has taken the following course of action:
1.
We will not alter the status of valid proprietary submittals on the environmental qualification of electrical equipment.
Summary type information, however will not be withheld from public dis-closure.
2.
We are encouraging industry to make operational its already existing plan for an equipment quali-fication data bank. We will continue to establish our own Equipment Qualification Data Bank.
The staff feels that there are sufficient differences and usages between an NRC and industry run system to justify an independent NRC system.
3.
We will require licensees to maintain at a central location and to submit to NRC for review, upon request, all applicable reports and/or data which substantiates their findings that their equipment is qualified.
Limited access to documents as practiced by the General Electric Company is un-acceptable.
The orders soon to be issued to licensees will articulate our position.
C0 ORDINATION:
This paper was concurred in by the Office of Inspection and Enforcement.
The Office of the Executive Legal Director had no legal objection.
Harold R. Denton, Director 1 Office of Nuclear Reactor Regulation DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS Secretariat
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