IA-88-322, Submits Input to Plan for Implementing Recommendations from Facility Rept Review Group Project Rept.Definitive & Documented Regulatory Position Does Not Exist on Controls During Transfer Between Organizations Re Shipping Records

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Submits Input to Plan for Implementing Recommendations from Facility Rept Review Group Project Rept.Definitive & Documented Regulatory Position Does Not Exist on Controls During Transfer Between Organizations Re Shipping Records
ML20207A693
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/14/1988
From: Roe J
Office of Nuclear Reactor Regulation
To: Hebdon F
Office of Nuclear Reactor Regulation
Shared Package
ML20206E778 List:
References
FOIA-88-322 NUDOCS 8802100151
Download: ML20207A693 (3)
v • d • e


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MEMORANDUM FOR: F. J. Hebdon, Chief 504 Irspection Licensing, & Research Integration Branch p

  • Office of Nuclear Reactor Regulation , p b , [. .

FROM: Jack W. Roe, Director , ,3 m s y m py _7 e Division of Licensee Performance end Quality Evaluation C25C W C Q U' ?

Office of Nuclear Reactor Regulation - uco lo Cew 99cc.

SUBJECT:

DLPQ INPUT TO THE PLAN FOR IMPLEMENTING RECOMMENDATIONS FROM THE COMANCHE PEAK REPORT REVIEW GROUP (CPRRG) REPORT DLPQ has res,nonsibility for resolving five of the explicit recomendations

contained in the Comanche Peak Report Review Group's (CPRRG) Report. OLPQ has reviewed the CPRRG report and has made the following determinations (recomendations are denoted by reference ID number).
1. ID 04 - ANSI N45.2.9 is silent on shipping records. A definitive and documented regulatory position does not exist on controls during transfer between organizations.

NRC position - IMC 9900 "Technical Guidance," on ANSI N45.2.9, addresses QA record storage facilities but does not address the shipment of QA records.

Reasonable protection should be afforded to lifetime QA records during shipping or transfer. Reasonable, in reference to QA record protection during shipping or transfer, means taking into consideration the type of records and their importance to safety, the distance they are being shipped, the time required to ship them, the actual container in which the records are placed, the mode of transportation, and personnel who are responsible for transporting the records. Records should be inventoried to maintain accountability. All variables considered, prudent judgment on the part of l the licensee and by the inspector should be employed in detennining what is an acceptable means of shipping records.  :

D More prescriptive guidance for the shipping of QA record is not .ecessary.

2. ID 05 - Clarify agency guidance: IE MC 9900 guidance was misinterpreted on applicability of 10 CFR 50 Appendix B criteria to the requirements of 10 CFR 50.55(e).

NRC position - IMC 9900, on 10 CFR 50.55(e), requires that means to assure i prompt notification 6nd adequate reporting of contruction deficiencies under 10 CFR 50.55(e) should be an integral part of each licensee's QA program.

Contact:

y ' R. P. 490-9693 Correia, NRRN a

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F. J. Hebdon Maintenance and retrievability of the licer. sees' records of identified deficiencies reported under the requitements of 10 CFR 50.55(e) and their implementing procedures is importcnt. So long as they exist, it is not critical under which heading, Appendix B or 50.55(e), the licensee's 10 CFR 50.55(e) implementing procedures and records of deficiencies are found, o- Clarification should be made in IMC 9900, b 3. ID 64 - The philosophical position as stated by Re ion IV (tnat although aprocedurerequiredconcretemixerbladeinspe:tions,ktdidnotrequire documentation of such inspections) requires careful consideration.

NRC position - 10 CFR Part 50, Appendix B, Criterion XVII, "Quality Assurance Records," requires that sufficient records be maintained to furnish evidence of activities affecting quality including the results of inspections.

Criterion X, "Inspections," requires a program for inspection of activities affecting quality to be executed to verify conformance with instructions, procedures, and drawirigs.

No change to the current NRC policy or guidance is necessary.

4. ID 65 - Consideration should be given to the Technical Review Team (TRT) rp p sition that "permanent" records removed from storage for use or revision revert to an "in-process" status.

p? p NRC position - For the purposes of N45.2.9. a document is considered a QA

[g[ record (either lifetime or non-permanent) when the document has been completed. Any time a QA record is handled for review, revision, shipping,

/ or use, reasonable care should be taken to ensure that the record will not be damaged, lost, or destroyed. Reasonable care in handling QA records could include placing a duplicate of the record in the permanent storage locatton; training individuals on the importance of how QA records should be har.dleti; what should be done to avoid misplacement, destruction or damage to them (e.g. no food, drink, or smoking materials in the vicinity of the records);

placing the records in appropriate locations such as metal file cabinets when not being used; and mininizing the time the records are away from their storage location.

No change to the current NRC policy or guidance is necessary. -

5. _10 07 - No guidance exists on the time permitted to retrieve a document that is required to be retrievable. . ,

NRC position - Time pennitted to retrieve a document should be derived from several factors, all based on reasonable judgments made by the licensee and the inspector. These factors are the record's importance-to-safety with con-sideration given to the situation at hand (i.e. during normal plant operations, in accident or emergency conditions, during an outage, an investigation, or an inspection) when the request is made to retrieve a record. Also, the location of the document (at or away from the location of

F. J. Hebdon the requester), and the size of the record (i.e. number of pages or volumes) ,

should be considered. The licensee and the inspector should agree upon a reasonable time required to retrieve a particular record.

l No change to the current NRC policy or guidance is necessary.

Please contact me if we can be of further assistance in these matters.

f 1 Jac W. Roe,Directorf Divi ion of Licensee Ie,,rformance an Quality Evaluation '

Office of Nuclear Reactor Regulation i

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