ML20011A039

Forwards marked-up Revised Position on Reg Guide 1.88 Re Storage of Nonpermanent Records,Which Will Be Incorporated in Next FSAR Amend

ML20011A039
Person / Time
Site:	Summer
Issue date:	09/29/1981
From:	Nichols T SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.088, RTR-REGGD-1.088 NUDOCS 8110060385
Download: ML20011A039 (5)

Text

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SOUTH CAROLINA ELECTRIC a GAS COMPANY Post orrics sox 7s4 p.,

CotuMe:A, SOUTH CARouNA 29219 ff)

T. C. NicMots, J R. /\[ h

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e September 29, 1981 [/ j ,

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c 5 u., 2 g 'e , 193I  %

Mr. Harold T.. Denton, Director 88% 'os y 41/

Office of *.4uclear Reactor Regulation N' 4,, . D U. S. Nuc tear Regulatory Commission // f3 w a a ! 9 g icsn , D . C . 20555 N# l th -s

Subject:

Virgil C. Summer Nucicar Station Docket No. 50/395 Records Storage

Dear Mr. Denton:

Ae discussed with Mr. Bill Kane and Mr. Jack Spraul of the NRC, South Can lina Electric and Gas Company provides a markedup copy of a revised position on F.egulatory Guide 1.88 for the Virgil C. Summer Nuclear Station. This should resolve the concern of the Staf f in regards to the storage of non-permanent records. This position will be incorporated in the next FSAR amendment.

Please let us know if you have any questions.

Very truly yours, C4 T. C. Nichols, Jr.

RBC:TCN:lkb Attachment cc: V. C. Summer G. H. Fischer

11. N. Cyrus T. C. Nichols, Jr.

J. C. Ruoff D. A. Nauman W. A. Williams, Jr.

R. B. Clary O. S. Bradham A. R. Koon M. N. Browne B. A. Bursey J. L. Skolds l J. B. Knotts, Jr.

11. E. Yocom hI k l F. L. Lamphere J. B. Cookinham f

NPCF .

File 8110060385 810929 PDR ADOCK 05000395 A PDR l'_

INSERT A During the interim period for which - the SCE&G QA organization maintains records prior to transmittal to the records program (Permanent facility),

the records will be kept in two remote locations in an of fice environment without the need for a storage procedure defining the elements required by Paragraph 5.3. SCE&G justifies this position based on the fact that Paragraph 2.2.2 of ANSI 45.2.9 recognizes that these records are of no value in demonstrating plant acceptability but only establishes that activities were performed; and, based on the fact that these records will be accessible at two office locations stored in prudent office environments.

Note: This position is applicable to these non-permanent records being backfitted within the period from commercial operations to December 1982.

It also applies to a planned quarterly retention of records (for compilation purposes) prio: to turnover of future permanent and non-permanent records to the PRS as they are issued after commercial operations.

INSERT B For SCE&G Quality Assurance organization generated records required by Appendix A, the following program will be implemented dealing with the turnover to the permanent facility, and retention times of non-permanent records as required by Paragraph 3.2.7.

1. SCE&G QA organization generated non-pe manent records are as follows:

QA Procedures QA Plans Vendor Procedures Vendor Survey Reports Vendor Inspection Reports Vendor Audit Reports Surveillance Reports

2. Af ter commerical operation, the records in 1, will be placed within the SCE&G records retention program (permanent facility) as issued.

3. Non-permanent records generated prior to commercial operations will only be placed within the record retention program (permanent facility) if they were generated within 3 years prior to commercial operation. SCE6G justifies this position based on the fact' the Paragraph 2.2.2 ofEANS 45.2.9 recognizes that these records are of no value in demonstrating plant acceptability but only establish that activities were performed; and, based on the fact that SCE&G utilizes these records for 3 years within procurement control programs.

4 s

INSERT B Con't

,l Note:. -Implementation of retrofitting non-permanent records generated within 3 years prior to commercial operation into the SCE&G permanent facility is expected to be completed by December 1982.

INSERT C I

i Vendor QA Manuals - Manuals will not be sent to PRS, however, objective

- evidence (audit and survey reports) that manuals were! reviewed will-be j sent.

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1.88 COLLECTION, STORAGE AND MAINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS (Revision 2; 10/76) 5 The Virgil C. Summer Nuclear Station quality assurance records program complies with the recommendations of this Regula tory Guide with the following exceptions and clarifications:

ANSI-N45.2.9-74 Section Exceptions and Clarifications

5. 3 raseer A I 18

)

5.6 The permanent records room is constructed and 17 located to protect contents from possible destruction by causes such as fire, flooding, insects, rodents and from possible deterioration by a combination of 11 extreme variations in temperature and humidity con-ditions.

5.6 The permanent records room is designed to meet a 4  ! 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> fire rating except for the fire dampers and elec-13 trical penetrations, which are rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

3,2 . 9 Tuster 0 3.2.7 App. A Applicable codes and standards will either be main-tained at the plant site or will be readily accessible from other sources. yy I Msec 7- 0 3.2.7 App. A C,.1, sc ::rd; ^" # #' : 2 lif C i- : -^~r': --- . : pir:? =

ZI23 5 ; -- - -- ~ s s In addition, as discussed with the NRC Staff:

1. The permanent records roon. is equipped with an early warning fire 17 detection and automatic fire suppression system, with electronic supervision at a constantly attended location.

18 3A-130 AMENDMENT at r ^?"1 14(4

2. Records are stored in metal cabinets. No records are stored 17 on the floor. Adequate access and aisle ways are maintained.

3. Work not directly associated with records storage or retrieval is prohibited within the permanent records room. Examples of such 17 l

prohibited activities include but are not limited to: records reproduction, film developing, and fabrication of microfiche cards.

4. Smoking, eating and drinking are prohibited throughout the permane2t records room.

5. Ventilation, tempera ture , and humidity control equipment is protec-ted inside with standard fire dampers where they penetrate fire 17 barriers bounding the storage facility.

6 Some records generated by Nuclear Operations during the operations phase t are needed for varying periods of time at the place of origination for ready reference. These records will be stored temporarily in fire- .

resistant cabinets by~ the originators in areas pre-identified as Records I*

Temporary Storage Facilities until they are transferred to the Permanent )I "

Records Storage Facility. The length of time that records may remain in -

these areas will be defined for each type record in the QA Records Accumulation and Retention Chart. The requirements of ANSI N 45.2.9 regarding accountability and retrievability of these records will be met while the records are in the Records Temporary Storage Facilities Areas.

29 3A-130a AMENDMENT W PBBMWdYP, N '

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