ML20034B154
| ML20034B154 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Erin Kennedy SENATE |
| Shared Package | |
| ML20034B136 | List: |
| References | |
| CCS, KENNEDY-900227, NUDOCS 9004260093 | |
| Download: ML20034B154 (3) | |
Text
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QUESTION 14 NRC Inspection Report 50-443/83-18 conducted in t
mid-November 1983, found:
" records not yet turned over (primarily piping) were technically i
acceptable to the extent complete, legible and retrievable although not completely assembled in some cases. Review of these records was not comp,lete."
(a) --What do the authors mean in stating that records "were l
technically acceptable to the extent [they were) complete, j
legible and retrievable?"
i (b) --Does this mean that the inspectors had knowledge that some records were " technically" unacceptable by virtue of i
being not complete, legible and/or retrievable?
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(c) -- If so, how does the existence of " technically" I
i unacceptable records affect conclusions concerning compliance with the record keeping requirements of l
Appendix B?
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l ANSWER.
(a) The quoted excerpt from NRC Inspection Report 50-443/83-18 is part of the conclusion drawn from a documentation review of selected records performed t
by the NRC inspector. The introductory section of the paragraph from which i
the subject quote was taken (i.e.3. Documentation Review) states the following:
E
D y,.
QUESTION 14.(Continued) '
I "The adequacy of the systeht with respect to preparation, review, control, l
storage and retrievability was examined. Records are prepared and main-tained temporarily by the organization responsible for performance of the l
work. Permanent records are maintained on microfilm by YAEC as part of the InformationManagementSystem(IMS).
"The inspector discussed this program with a YAEC representative and l
exavined a draft of a procedure for the records management system. Docu-ments submitted to IMS as permanent plant records are reviewed by the Construction Field QA Group for legibility, content and technical adequacy.
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Submittal and review of records is an ongoing process as portions of the work are completed."
t Furthermore, the following statement appeared in the report immediately before the excerpt quoted in the question:
" Records which had been turned over to IMS were complete, legible, readily retrievable, technically acceptable and had been subject to l
repeated review."
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The inspector who authored the foregoing quoted sections of the inspection report was distinguishing between records which had been turned over to the IMS and records which had not received their final review. The inspector used legibility, retrievability and " to the extent" completeness as his o-
4 OUEST10N14.(Continued) j inspection criteria for the records not yet turned over, because such records, by the fact they are in-process, may require additional docu.
mentation of construction work, inspection results, or design change implementation to make the records complete. Also, as documented by the j
inspector, completed records were subject to repeated reviews as required by the program of controls for permanent plant records. Thus, the in-f process records that were inspected would also be subjected to this review
[
process once they were completed and submitted for turnover. As stated, the inspector's review of documentation for both the completed and the in-process records identified no concerns with the process or the program.
i (b)and(c)
No, this does not mean the inspector knew of unacceptable records. During the construction phase, inspectors are versed in the aspects of 10 CFR 50, Appendix B, as this is the primary basis for prescribing the scope of the 4
quality assurance program.
Criterion XVII requires that quality assurance records in their final form be identifiable and retrievable. The NRC inspects equipment fabrication and installation, including records, at various stages of completion to ensure the process is functioning as l
required.
In this case, the inspector found in-process records to be technically acceptable with regard to three attributes (with which he found no problems) but pointed out his recognition that some assemblage of records in final form remained to be performed.
e