ML20115D639
| ML20115D639 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 10/01/1992 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Mizuno G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| FRN-57FR28645, RULE-PR-72 57FR28645, NUDOCS 9210210069 | |
| Download: ML20115D639 (2) | |
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00CiET NUMBER pqe -gt PROPOSED naJ (6 7 f E,l'1 3 W Ys,_?
92 En -5 P5 SB 4
i October 1, 1992 u.s v g,,
a n1 f
a Mr. Geary Mizuno Office of the General Counsel U. S. Nuclear kegulatory Commission Washington, DC 20555
Dear Mr. Mizuno:
I am writing to correct an inadvertent misstatement in my letter dated September 28, 1992 which provided OCRE's comments on NU-MABC's August 19, 1992 comments on SECY-92-170.
On page 2 of my letter I stated: "It is OCRE's understanding that the Westinghouse AP-600 application which is publicly available from the Public Document Room has all drawings, even the most general plant layouts, and the entire PRA redacted as proprie-taryi" This statement was based on information provided by another source.
I have since performed a cursory review of the AP-600 application myself, and I have found that this statement is not entirely accurate.
While much information has indeed been redacted-as proprietary, the application does contain some draw-ings and a conclusory summary of the PRA methods and results.
The publicly available version of the application is.not com-pletely devoid of this information, as I had been led to be31 eve.
Thus, the discussion in the third full paragraph on page 2 of my September 28 letter may not be applicable.
- However, my review of the /.P-600 application indicated that so-much detailed information has been redacted-as proprietary that the publicly available version will not support the level of independent, critical review of the design necessary to enable the formulation cf meaningful comments or participation in a
hearing.
Therefore, the fundamental positions and conclusions of my September 28 letter remain unchanged.
- Moreover, OCRE is concerned with the copyright notice contained in-the AP-600 application.
This notice states, "With regard to the non-proprietary versions of these reports, the NRC is permit-ted to make the number of copies beyond those necessary for-its internal use which are necessary in order to have one copy avail-able for public viewing in the appropriate docket files in the public document room in Washington, D. C.
and -in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient fc r this purpose.
The 1
9210210069 921001 PDR PR 72 57FR28645 PDR
-. -. -. - ~... -. - -. -. -..
A t
i NRC is not authorized to make copies for the personal use of members of the public who make use of the NRC public document rooms."
If the NRC considers itself bound by these provisions, this will create a significant burden on persons who wish to review the application, especially if such persons do not reside
-near a-public document room.
It also raises a new issue. to consider in the implementation of Part 52: handling of copyright--
ed information, particularly when such information is to be submitted as exhibits in the hearing or as part of written-com-
- ments, While OCRE appreciates the commercial and public policy-reasons for the protection of intellectual property, it appears that the Westinghouse position is.rather extreme and perhaps was established to. discourage public scrutiny of the design and public participation in the design certification proceeding.
Sincerely, M s. !
Susan L. Hiatt
. Director, OCRE Ohio Citizens for Responsible Energy, Inc.
8275 Munson Road Mentor, OH 44060-2406 l
(216) 255-3158' 4
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