ML20235S619

Responds to NRC Re Violations Noted in Insp Rept 50-312/86-22.Corrective Actions:All Instrument Maint Data Records Transferred to Records Mgt & Stored in Onsite rated- Vault Until Filmed

ML20235S619
Person / Time
Site:	Rancho Seco
Issue date:	06/26/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20235S606	List: IR 05000312/1986022 ML20235S619
References
GCA-87-032, GCA-87-32, NUDOCS 8707210719
Download: ML20235S619 (7)

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$)SMUDSACRAMENTO MUNICIPAL UTILITY DISTRICT i j 6201 S Street, P.O. Sc= 15830, Sacramento CA 958521830,(916) 452-3211

. AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-032 JUN 2 619irl i

J. B.. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V, Office of Inspection & Enforcement 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 )

Rancho Seco Nuclear Generating Station  !

License No. DPR-54 i

Response to Notice of Violation (NRC Inspection Report No.

50-312/86-22, Revision 1)

Dear Mr. Martin:

By letter dated August 26, 1986, the Sacramento Municipal Utility District was transmitted a Notice of Violation concerning-the retention of routine and special surveillance and calibration test records. As a result of an internal audit of a warehouse used for document storage and the letter from J. E. Ward (SMUD) to J. B. Martin-(NRC) dated April 24, 1987, the District provides the enclosed updated response to the Notice of Violation.

This letter acknowledges the violation cited and describes the District's intended corrective actions for each specific item listed in the Notice of Violation.

If there are any questions concerning this report, please contact Mr. Ron W. Colonbo at (916) 452-3211, extension 4236.

Sincerely, Ca N 22h nini An rwt T c  %

G Chief' Exec tive Officer, Nuclear $ ,)'o EES E3 Attachment  %

< ) %o cc: A. D'Angelo @

G..Kalman o IMPO

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dh0k050 07074 y ,

l jh_ d RANCHO SECO NUCLEAR GENERATING STATION , 14440 Twin Cities head Herald, CA 95638-9799;(209) 333-2935

," DRAFT 8 DATED Jun3 24, 1987, 9 33 AM

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l ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-22. REVISION 1 NOTICE OF VIOLATION NF.C Violation As a result of the inspection conducted between June 10 and July 25, 1986, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following alleged violation was identified:

10 CFR Part 50, Appendix B, Criterion XVII, " Quality Assurance Records," requires sufficient reccrds shall bc )

maintained to furnish evidence of activities affecting quality such as tests. This criterion further requires the applicant to establish requirements concerning record retention, such as duration, location, and assigned responsibility.

The licensee's Quality Assurance Procedure Number 18, Revision 1, " Quality Assurance Records," requires that

"[t]he provisions of NQA-1, Supplement 17S-1, Requirements for Quality Assurance Records, shall be used for management of plant records."

ANSI /ASME HQA-1, Supplement 17S-1, 4.4.1, " Single Facility,"

requires' that the design and construction of a sir.gle record storage facility shall comply with tha requirement of a minimum two-hour-fire rating, and; 4.4.2 " Alternate Single Facilities: requires that a two-hour fire rated Class b file container meet the requirements of NFPA 232-1975.

Contrary to the above, at the time of the inspection, the records of routine and special surveillance and calibration tests performed during the past two years on safety-related structure, systems and components, as prescribed in the facility's Technical Specifications, were stored in metal file cabinets and on shelves in the Administration Building and the Instrument and Control (I&C) shop. Some of these file cabinets have a fire rating of one hour, while others were not rated. Neither the Administration Building, nor the I&C shop were designed and constructed as record storage facilities'to comply with the requirement of a mininum two-hour-fire rating.

1 This is a Severity Level IV violation.

District Response to Violation

1) Admission or denial of the alleged violation.

The District acknowledges and admits that this item I occurred as stated. I

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2) Reasons for the violation In 1982, the District developed a Records Management system which uses microfilm and a computer data base [

for indexing the Quality Assurance records on film.

This system went into operation in 1982. This system meets all of the stated requirements and uses the dual l storage concept for the microfilm aasters. Of the two l rasters that are produced, one is stored at the site l and one is stored at an off-site facility in Tahoe ,

City, California. At the time the system went into l operation, there was a records backlog on-site of approximately ten years. At the end of August 1986, due to inadequate resource allocation for the process, the backlog had grown to approximately 1.7 million pages of records in the syctem. This backlog represents approximately twelve years worth of records.

Although the Training and Records Building vault was l completed in 1985, Records Management did not begin to f occupy the vault until August 1980. Due to the large (

record systems backlog, many records were stored in the non-rated Administration building vault in hard. copy. I Several boxes cf Instrument Maintenance Dtta i remained in the I&C shop vork area during this time  !

because the non-rated storage vault did not have I adequate space.

3) Corrective actions which have been taken and results achieved.

The subject Instrument Maintenance Data that were located in the I&C Shop work aree during the NRC inspection were transferred to the on-site rated-vault.

They were filmed subsequent to the inspection.

All the Instrument Maintenance Data records were transferred to Records Managemant and stored in the on-site rated-vault until they were filmed. Eight to ten bindere per week of.these records were filmed and returned to the work area subsequent to this violation through December 1986. Now Instrument and Control Testing Data are stored (RE: RSAP-0601) in one-hour-fire rated file cabinets. Copies of the data are kept in binders in the local work area.

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- Surveillance' Procedure (SP) records are transferred l- j from the Technical Support Group to Records Information l

~ Management for filming on a regular basis. .The I associated SP Technical Lead Sheets are prepared . by l Technical Support personnel. Those Technical. Lead l .

Sheets provide the basis of the index for the records. l The indexing of the records allows their retrievabi)ity. l l f

At the time of the NRC inspection, many of the l Surveillance Procedure records observed in the filing l cabinets in the Administration Building were already l microfilmed. There were. approximately two file l cabinets of Surveillance records in the Administration [

Building awaiting transfer to Records Management for l filming, and these cabinets have a one-hour-fire l rating. That arrangement is adequate ' for the current I plant. situation, for the reasons described below. I Subsequent to receiving the notice of violation, the l District attempted to locate two-hour-fire rated filing I cabinets which would meet NQA-1, Supplement 17S-1. l Numerous sources were contacted, including subscribers l to the " NUCLEAR NETWORK." The District learned that [

file cabinet vendors do not make two-hour-fire rated l file cabinets. The only correctly rated units available l are safe-type vaults equipped with drawers. However, l the floor loading requirements for these safes will not i permit their usage in the various work areas at Rancho l Seco. l At a NIRMA (Nuclear Information Records Management Association) meeting in Denver, during the week of September 8, 1986, a District representative' spoke with representative from numerous other utilities who advised us that they have the same problem as the District and have filed for exemption from NQA-1, Supplement 17S-1.

Quality Assurance (QA) revised QAP-18, on records ]

retention, to describe an exception to the two-hour i fire rated cabinet requirement of NQA-1, Supplement j 17S-1 in the local work areas. In addition, QA defined l the term " record" to clarify what is to be processed by l Records Management. Records Management has also revised I its administrative procedure, RSAP-0601, to conform to j the new QAP. The revised administrative procedure l requires the completion of an index sheet for the i filming process, a Records Management transmittal form, I and interim storage of Quality Records in one-hour-fire ]

rated file cabinets until they can be filmed or placed l in the vault. More than 63, one-hour fire rated file I cabinets were ordered for interivt storage of records in work locations.

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.; l New Quality Records produced after December 1, 1986, are sent with an index sheet and transmittal form to l  ;

Records Management for protection, after completion and l authentication, thereby eliminating the development of l I any further backlog. Prior to storage of recorda in l 1 either the on-site or off-site vaults, all records are l  !

being indexed for retrievability. I One-hundred twenty days will be the maximum period that Quality Records generated, completed, and authenticated I after December 1, 1986, will be maintained in one-hour- i fire rated cabinets prior to protection. l l 1

The . staff of the Records Management organization was l increased to provide for a microfilm operation on two l shifts instead of one. That, along with a directive I issued by the Deputy General Manger, Nuclear concerning l the forwarding of all quality records to the Records l Information Center (RIC) Files has eli:ainated the l growth in the Rancho Seco backlog of unprocessed l quality records. This was concluded from meetings held l with working level Records Mangement Coordinators  !

during June 1987. The District is currently generating l approximately 500,000 new quality records per year and l is microfilming at a rate in excess of 1,300,000 l records per year.  !

The District's Quality Assurance audit of a warehouse l in Sacramento being used to store closed engineering l packages revealed that approximately si boxes of closed l Engineering Packages, and 523 boxes of Purchase Orders l are both kept at that warehouce. This warehouse Goes [

not comply with ANSI /ASME NQA-1, Supplement 17S-1. [

That being the case, the District investigated l potential alternatives with action items as described I in the following section. l With RSAP-0601, the District established formal l j administrative door control to maintain fire integrity i of the T&R building vault, among other requirements and l standards for records management at Rancho Seco. l The Records Management Group located an off-site l storage facility that nearly complied with ANSI /ASME l NQA-1, Supplement 17S. After bringing the off-site vaultj fully up to standard, a contract was signed l establishing a second rated-vault for the District to l use. l

4) Corrective steps which will be taken to avoid further violations.

The remaining records that have not been filmed or i stored in the on-site record storage vault will be l transferred to this facility by September 1, 1987. I

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High - density storage equipment is l scheduled . to'.' be - l installed' incapacity storage the on-siteover rated vault and will increase:thei 40 percent" for an estimated I capacity . of . 5.2 million pages stored in the : vault.

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installation, t h e - 9 1 ;- b o x e s of . engineering l packages this' Records stored in Sacramento Management vault. willi be transferred ' to' l Of the 523 ' ' boxes ! of- l:

Purchase' Orders' stored in Sacramento, 348 have already - I been -retrieved .for protection and processing i'nto the i Records M a n a g e m e n t - s y s t e m'. However, this extra- l capacity necessitates capability for the-vault.

an increased fire suppression l This enhancement would~ allow l the District' to safely store more records in the on- l site rated-vault .while they are awaiting - filming. The l Fire Protection .. Group of the Nuclear. - Engineering 7 l organization.provided recommendations for the. vault i fire suppression system enhancement.

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The District will increase the Halon capacity of the l 4 T&R vault fire suppression system by October 15,.1987. l The on-site fire protection group established an l hourly' fire watch patrol for the T&R building vault for l those times that the room surrounding the vault is I unattended. l The revised QA position on the ' two-hour fire rated l cabinet requirement of NQA-1, Supplement 17S-1 will be l formalized by submitting a revision of ' the QA Plan to l Region V of the NRC. l

5) Date full compliance will be achieved.

The capacity of the on-site record storage vault will l be expanded by July 1987, so that new quality records j can be stored ~ on-site prior to filming. The I corresponding upgrade to the fire protection capability l provided in the vault will be established prior to l October 15, 1987.. l By September 1, 1987, the entire backlog of quality- l records and all current quality records, as they are l.

turned over to Records Management, will be indexed and l protected in accordance with Rancho Seco . procedures, l (pending the vault fire protection system upgrade) and l fully retrievable. l l

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