ML20072P264
| ML20072P264 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/09/1983 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20072P255 | List: |
| References | |
| LQ8300006, NUDOCS 8304040173 | |
| Download: ML20072P264 (5) | |
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GENERAL OFFICE Nebraska Public Power District "L'ess*e"*Js*Re*O****"
LQA8300006 February 9, 1982
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Mr. G. L. Madsen, Chief i
I Reactor Projects Branch I gg g
U. S. Nuclear Regulatory Commission Region IV
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611 Ryan Plaza Drive g
Suite 1000 Arlingtoa, TX 76011
Subject:
NPPD Response to IE Inspection Report No. 50-298/82-29
Dear Mr. Madsen:
This letter is written in response to your letter dated January 6, 1983 transmitting Inspection Report No. 50-298/82-29. You indicated that some of our activities were in violation of NRC requirements.
A one week extention of response time was requested and granted.
The request for extention was primarily based upon the unavailability of two-hour rated file cabinets which were under consideration for use in Cooper Station's document storage program. Acceptability of these file cabinets was expressed by the Inspector. Details are presented in a document titled " Guidance -
ANSI N45.2.9, Section 5.6, NRC Criteria for Records Storage Facilities" dated July 1, 1980. After it was determined that these cabinets were not available, an extention was requested.
Following is a statement of the violation and our response in accordance with 10CFR2.201.
Statement of Violation Failure to Meet Record Retention Requirements 10 CFR Part 50, Appendix B, Criterion XVII states that records shall be identifiable and retrievable and that, consistent with applicable regula-tory requirements, the applicant shall establish requirements concerning record retention such as duration, location, and assigned responsibility.
The licensee's " Quality Assurance Program for Operation," Revision 8, dated August 20, 1979, Section 2.17. " Quality Assurance Records,"
contains the following requirements:
"The provisions of ANSI N45.2.9-1974, ' Requirement for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants,' shall be used for management, retention, and storage of CNS quality-related records."
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Mr. G. L. Madrin Februmry 9, 1983 Page 2 ANSI N45.2.9-1974 requires temporary and permanent record storage facili-ties that shall protect records from deterioration or destruction by fire and sets forth guidelines, including the optional retention of duplicate records in~ separate, remote storage facilities. ANSI N45.2.9-1974 further requires that records shall be accurately retrievable without undue delay, and in Appendix A delineates categories of required records for design, procurement, manufacturing, installation-construction, preoperational, start-up test phase, and operation phase.
Licensee Procedure QAI-7, " Quality Records Retention Storage and Disposi-tion," Revision 13, implements requirements of ANSI N45.2.9-1974 relative to storage of records.
Contrary to the above, the NRC inspector determined:
1.
On October 26 and 27, 1982, the licensee's site quality assurance records vault and the auxiliary QA records vault did not meet the design requirenents of ANSI N45.2.9-1974, Section 5.6, in that the doors did not have a 4-hour fire rating.
In addition, pipes (roof drain pipes), other than those providing fire protection to the storage facility, were located within the auxiliary QA records vault.
Discussion of Violation Item Number One Prior to the performance of this inspection the licensee was fully aware of the fact that the doors did not have a 4-hour fire rating and that a short section of drain piping existed in the auxiliary records vault. These issues were addressed in the station design change which controlled the construction of the auxiliary vault. The section of ANSI N45.2.9 referenced states "the following features should be considered in its construction...
3.
Structures, doors, frames and hardware should be Class A fire-rated with a recommended four hour minimum rating...
9.
No other pipes....are to be located within the facility."
The above criteria were considered in the records vault construction in question. A four hour door was not incorporated in the design because there is no commercially available " man door" which meets the NFPA four-hour rating.
To meet the four-hour rating, we would have had to install a " vault typeV door which was impractical in these cases due to the structural nodifications which would have been necessary because of the size and weight of this type of door.
Additionally, the combustible loading outside each door is minimal. The com-bustible material in each vault is protected by a sprinkler system; therefore the need for a door with a fire rating greater than three hours is not war-ranted. The issue of the roof drain pipe in the auxiliary records vault was also addressed in the station design change.
It was felt that the drain pipe was of a construction quality equal to or better than the roof which it drains. Further, it does not contain pressurized water or steam khich would increase the possibility of leakage into the room. We felt that this met the intent of ANSI N45.2.9-1974 and was judged acceptable at the time of installation.
Mr. G. L. MadzIn Fabruary 9,1983.
Page 3 The date when full compliance will be achieved for Item Number One We'believe we are presently in full compliance with ANSI N45.2.9-1974 on-these issues.
Statement of Violation for Items Two and Four 2.
On October 27 and 29, 1982, all licensee offsite environmental monitoring survey records and personnel radiation exposure records, designated as life-of-plant (LOP) records, were stored as single copy records in file cabinets or other storage facilities which were not fire rated as required by ANSI N45.2.9-1974, section 5.6.
4.
On' October 27 and 29, 1982,- health physic data forms (specifically offsite environmental monitoring survey records and personnel exposure records over 2 years old) were still in active files (which were not in fire rated storage) in lieu of being in permanent storage in the CNS vault as required by Licensee Procedure QAI-7, Revision 13, Attachment 4.
Corrective steps which have been taken and results achieved for Items Two and Four The personnel exposure records were stored in non-fire rated file cabinets at the time of inspection. However, the active exposure data is also stored on the station computer. This data stored on the computer is reproduced on magnetic tape. The tape, containing the active exposure data, is stored in an off-site facility. Additional redundancy measures to safeguard computer storage are employed on-site. 'These measures are designed to minimize the possibility of loss of this data. ANSI N45.2.9-1974,
-Section 5.6, paragraph 2 states "a satisfactory alternative to the establish-ing of a records storage facility is maintenance.of duplicate records stored in a' separate remote location". We believe through the measures outlined above we have met the intent of the guidelines established in ANSI N45.2.9.
However, pursuant to our evaluation, and as a result of the inspection efforts, we have determined that further long term corrective action as outlined below is necessary.
In addition, we recognize the need for revision of the storage method specified for these records as in QAI-7.
Corrective steps which will be taken to avoid further violations for Items Two and Four The permanent personnel exposure records will be filmed in accordance with station procedures. QAI-7 will be revised to reflect the changed storage procedure for these records.
The date when full compliance will be achieved for Items Two and Four The permanent personnel exposure records will be filmed and QAI-7 will be revised prior to August 31, 1983.
Mr. G. L. Madun
-Ftbruary 9, 1983 Page 4 Statement of Violation for Item Number Three 3.
On October 27, 1982, certain licensee records, including records requiring retention for the LOP (such as " charts for components that are designed for a limited number of transients") were stored in the site auxiliary QA records storage area on open shelving, bound without covers, and not in containers as required by ANSI N45.2.9-1974, Section 5.4.
, Discussion for Item Number Three During the time of the discussion, the records in question were being processed into storage. The document control technician has since placed the records in binders and stored them on shelving. We interpret ANSI N45.2.9 as not requiring bound documents to be in containers as the violation appears to state.
.The date when full compliance will be achieved for Item Number Three We believe we are presently in full compliance with ANSI N45.2.9-1974 on this issue.
Statement of Violation for Item Number Five 5.
On October 26 and 27, 1982, certain licensee records of relay test results for the years 1972, 1973, 1975, 1976, 1977, 1978, 1979, and 1980 were in active files (not fire rated storage) in the site electric shop in lieu being in permanent storage in the CNS vault as required by Licensee Procedure QAI-7, Revision 13, Attachment 4.
Corrective steps which have been taken and results achieved for Item Number Five The records in question were transferred to permanent storage by 1-31-83.
Corrective Steps which will be taken to avoid further violations for Item Number Five The electrical shop personnel and the document control technician were in-structed to follow QAI-7.
The date when full compliance will be achieved for Item Number Five We believe we are presently in full compliance on this issue.
Statement of Violation for Item Number Six 6.
On October 26, 1982, filming of site engineering department "Special Test Procedures," and "Special Procedures," had not been accomplished as required by Licensee Procedure QAI-7, Revision 13, Attachment 4.
.1 Mr.~G. L. Madsen Februnry 9 1983 Page 5 Corrective steps which have been taken and results achieved for Item Number Six It is a fact that Special Test Procedures and Special Procedures have not been filmed..Since 1979 we have employed duplicate storage methods in regard to Special Test Procedures and Special Procedures. Duplicate storage is permis-sible as an alternative-to filming per Section 3.8 of QAI-7.
Corrective steps which will be taken to avoid further violations for Item Number Six Pursuant to our evaluation, we. intend to film the Special Test Procedures and Special Procedures in accordance with station procedures.
The date when full compliance will be achieved for Item Number Six Special Test Procedures and Special Procedures will be filmed prior to August 31, 1983.
If you have any questions regarding this response, please contact me.
Sincerely, M
. Pilant Division Manager of Licensing and Quality Assurance JMP:LCL:CJG:ss
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