ML19296C362

From kanterella
Jump to navigation Jump to search
Requests Review & Determination of Adequacy of Program for Collection,Storage & Maint of QA Records.Automatic Records Mgt Sys Instituted to Satisfy Specific NRC Requirements
ML19296C362
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 02/19/1980
From: Early P
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To: Ippolito T
Office of Nuclear Reactor Regulation
References
JPN-80-10, NUDOCS 8002250691
Download: ML19296C362 (3)


Text

. .

POWER AUTHORITY OF THE STATE OF NEW YORK to COLUMBUS CIRCLE NEW YORK. N. Y. too19 (2121 397-6200 GEORGET BERRY ortnatino oprican TRUSTEES JOHN W. SOSTON JOHN S OYSON

"" " s not e etcTcm cEenoE c.iNoateS JOSEPH R. SC IEDER vlC E CM AIR M AN mCuano u ruYNN go;~,' = Cain aceEaT i uitto m u February 19, 1980 'E"i ",c SINC AH,, e , ,

enEoEmex . Ctanx JPN-80-10 *,,c,";'A ' ' " '""'

"A.".".m'"#.,......,

.. m~..m Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Thomas A. Ippolito, Chief Operating Reactors Branch No. 3 Division of Operating Reactors

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 NRC Document Storage Requirements

References:

1. Director, NRC Region 1 Letter of Aug. 10, 1978 containing the Report on Inspection 50-333/78-14
2. Letter, JAFP-79-319 from John D. Leonard, Jr.

(PASNY) to NRC Region 1 dated June 22, 1979

3. Director, NRC Region 1 Letter of Aug. 20, 1979 Re: Inspection 50-333/78-14
4. Letter, John D. Leonard, Jr. (PASNY) to NRC Region 1 dated September 6, 1979

Dear Sir:

The Authority hereby requests from the NRC Division of Nuclear Reactor Regulation a review and determination of adequacy of our program for collection, storage and maintenance of quality assurance records and the schedule for compliance with ANSI N45.2.9.

System Description

The Authority had instituted an Automated Records Management System (ARMS) to satisfy the specific NRC requirements. This system establishes a computerized data base for plant records and documentation. The system provides for photographing and producing microfiche for video retrieval and encompasses indexing so that any document can be located by document type code, serial number, subject code, system / component I.D., addressee, originator and numerous cross references, such as U.S. NRC Inspection reports, bulletins o, y s 80022gg Q U/

JPN-80-10 and circulars. This comprehensive indexing requires a significant number of trained man-hours to perform. In the 1 year period since the system was put on line, about 43,900 documents have been indexed. It is expected at this rate that it will take a 4 to 5 year period effort to complete.1v index and microfilm the required documentation onto the computer.

Until the incorporation of records and documentation is complete, records will be kept in the Administration Building. This building is of steel and concrete construction and has an installed fire protection system. Efforts are being made to minimize loose papers in the archival storage area.

Radiographs and weld records have now been moved to more secure storage areas and are in fire proof safes. This area has been cleared of all loose papers, boxes, or flammable material on open shelves, thus allowing the Authority to meet the one hour fire rating of NFPA-232.

The Authority has purchased and received 6 additional fire proof safes for storage of strip and roll charts with lifetime storage required designations. These are stored with the radiographs and weld records.

The Authority is also planning a new support building to be built by 1982-83 which will contain a vault meeting ANSI N45.2.9 requirements for storage of documents not suitable for microfilming.

Alternatives A. Expedited Indexing of Records Expediting the computerization of records can be accomplished with additional temporary personnel not trained in plant nomenclatures and system descriptions, but this would result is a high potential for improper indexing and thus the potential for lost documentation.

Alternatively, the Authority could reduce the time frame required to 3 years by undertaking a program of minimal indexing where documents would be indexed by file drawer and folders only. In order to locate a document within the system, a user would be required to review the brief index contained in the ARMS System and then search through the appropriate microfiche (s) on a frame-by-frame basis.

The Authority believes that the benefits of orderly implementatirn of the ARMS System are very significant in that they will prov.Je the required records protection, modernize management methods and facilitate timely records recovery. The Authority interim storage procedures provide a high level of protection.

JPN-80-10 B. Alternative Storage The only other alternative, and one to which we would strenously object, is to build a storage vault for these records which would fully meet the requirements of ANSI N45.2.9. This is a several hundred thousand dollar project in addition to the monies already expended to fulfill the regulatory requirement. The time for engineering and building this vault would approach at least one year considering weather conditions in this area. The primary reason for establishing a computerized ARMS System with duplicate records, in addition to retrievability considerations,was to negate the requirement for building this vault. Documents in such a vault would not be readily retrievable.

Conclusion In light of the above, the Authority request that complete com-pliance with ANSI N45.2.9 not be required until the end of 1984.

Very truly yours, Paul'J. Early Assistant Chief Engineer-Projects