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See also: [[see also::IR 05000244/1978024]]


=Text=
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{{#Wiki_filter:f aee'I ROCHESTER GAS AND ELECTRIC CORIoORATION
{{#Wiki_filter:EA Ie I~~ 4 aee f
E A Ie I~~4 o 89 EAST AVENUE, ROCHESTER, N.Y.14649 LEON 0, WHITE, JR.VICE RRESIOENT TEI EPNovE*RER cooc TIe 5'Er 2700 December 29, 1978 Mr.Eldon j.Brunner, Chief Reactor Operations
        'I ROCHESTER GAS AND ELECTRIC CORIoORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649 LEON 0, WHITE, JR.                                                                         TEI EPNovE VICE RRESIOENT                                                 *RER cooc TIe 5 'Er                   2700 December 29, 1978 Mr. Eldon       j. Brunner, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
and Nuclear Support Branch U.S.Nuclear Regulatory
 
Commission
==Subject:==
Region I 631 Park Avenue King of Prussia, Pennsylvania
IE Inspection No. 50-244/78-24 R. E. Ginna Nuclear Power Plant,   Unit $ 1 Docket No. 50-244
19406 Subject: IE Inspection
 
No.50-244/78-24
==Dear Mr. Brunner:==
R.E.Ginna Nuclear Power Plant, Unit$1 Docket No.50-244 Dear Mr.Brunner: This letter is in response to your December 6, 1978 letter received December ll, 1978, concerning
 
the inspection
This letter is in response to your December 6, 1978 letter received December         ll, 1978, concerning the inspection conducted at Ginna Station, Corporate Offices and the Andrews St. Building on November 13-16 by Messrs. Markowski, Napuda and Kehoe of your office.
conducted at Ginna Station, Corporate Offices and the Andrews St.Building on November 13-16 by Messrs.Markowski, Napuda and Kehoe of your office.According to your letter, it appeared that one of our activities
According to your letter, it appeared that one of our activities was not conducted in full compliance with NRC requirements, as quoted below.
was not conducted in full compliance
This letter contains information in response to this item.
with NRC requirements, as quoted below.This letter contains information
                "10 CFR 50, Appendix B, Criterion XVII states in part 'Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility.'ection 1 of Supplement IV, Revision 3, to the FSAR (the approved QA Program) states in part, 'The program conforms to the following AEC Regulatory Guides and ANSI Standards... Regulatory Guide 1.88, "Collection, Storage and Maintenance of Nuclear Power Plant Records"...'ection 17 further states in part, 'The records which fall within quality assurance record requirements include those records required by Section 6.10 of the Technical Specifications, the quality assur-ance program... All records associated with the operation... of... systems, and components covered by the quality assurance program are Guide 1.88 endorses ANSI N45.2.9-1974, 'Requirements for included.'egulatory Collection, Storage, and Maintenance of Quality Assurance Records fo, Nuclear Power Plants.'aragraph 5.6 of this standard describes the physical requirements for a single record storage facility.
in response to this item."10 CFR 50, Appendix B, Criterion XVII states in part'Consistent
V9020800go
with applicable
 
regulatory
      ~ ~
requirements, the applicant shall establish requirements
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concerning
  )'~
record retention, such as duration, location, and assigned responsibility.'ection
 
1 of Supplement
77OCH  f7ER GAS AhIO ELEC7RIC CORP.                                         SHEE7 NO. 2 DA7E     December 29, 1978 Mr. Eldon J. Brunner, Chief "Contrary to the above, as of November 16, 1978, the following single type records were stored in the indicated locations which did not meet the described single record storage facility physical feature require-ments.
IV, Revision 3, to the FSAR (the approved QA Program)states in part,'The program conforms to the following AEC Regulatory
Original radiographs of safety related systems such as Reactor Coolant, Safety Injection and Chemical-Volume Control, dating to 1968, stored in cardboard filing boxes (Nos. 51, 52, 53, 57, and 58) at the Andrews Building.
Guides and ANSI Standards...
Operations Recorder Charts (no copies/duplicates available) stored in steel filing cabinets in a vacant office at the station Warehouse Building."
Regulatory
Since the inspection the radiographs have been removed from the cardboard filing boxes and placed in fire rated (Class 350-1 hr) cabinets.
Guide 1.88,"Collection, Storage and Maintenance
Fire rated cabinets (Class 150-1 hr), better suited for the protection of radiographs, have been purchased and will be utilized for the storage of the radiographs upon their receipt in early January. The radiograph cabi-nets will be located at the Jefferson Road Record Vault which has a four hour fire rating and is equipped with temperature and humidity control.
of Nuclear Power Plant Records"...'ection
Upon completion of their relocation by mid-January, the radiographs will be afforded the necessary protection for a single record storage facility having physical requirements comparable to those specified in paragraphs
17 further states in part,'The records which fall within quality assurance record requirements
: 5. 6 of ANSI N45. 2. 9-1974.
include those records required by Section 6.10 of the Technical Specifications, the quality assur-ance program...
Due to the space limitation at the jefferson Road Record Vault, a new record storage room is being designed and constructed to accommodate the remaining nonduplicate records. This new storage room will meet the physical requirements for a single records storage facility prescribed by ANSI Standard N45.2.9 and/or suitable fire protection alternatives provided by NRC Regulatory Guide 1.88. Pending completion of the new storage room, the fire rated (Class 350-1 hr) filing cabinets which contain the Operations Recorder Charts are being transferred from the Warehouse building to a vacant room at the Andrews St. facility. The vacant room is both more suitable than the warehouse location and remote from the existing storage for duplicate records. This interim storage location is in a fire resistive reinforced con-crete building, has a sprinkler system and is free of combustibles other than the protected records. The surrounding area has been recently vacated, con-tains a minimum of combustibles and is also protected by a sprinkler system.
All records associated
With the exception of meeting the four hour fire rating, the interim storage location has the features essential for the protection of the records from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents and from possible deterioration by a combination of extreme varia-tions in temperature and humidity. Completion and occupancy of the new four hour records storage room is expected by June 1980.
with the operation...
 
of...systems, and components
~ ~
covered by the quality assurance program are included.'egulatory
(
Guide 1.88 endorses ANSI N45.2.9-1974,'Requirements
 
for Collection, Storage, and Maintenance
R OCHESTER GAS AND ELECTRIC CORP.                                           SHEET NO. 3 DATE   December 29, 1978
of Quality Assurance Records fo, Nuclear Power Plants.'aragraph
      'Mr. Eldon J., Brunner, Chief Corrective steps being taken to avoid further items of noncompli-ance are threefold:
5.6 of this standard describes the physical requirements
: 1. Clarification has been provided in the QA Manual and will be provided in the Ginna Procedure QC1701 of the likelihood that some records are unable to be duplicated and the preferred requirements and location for their storage.
for a single record storage facility.V9020800go  
: 2. Ginna and Engineering records processing personnel will be reindoctrinated in record storage and preservation require-ments.
~~4 r~)'~  
: 3. Ginna Station records personnel have initiated an investigation to determine the existence of additional records which are not presently duplicated and which will require processing similar to the recorder charts. In addition, this investigation will determine if all required operating records are being processed for record retention.
7 7OCH f 7ER GAS AhIO ELEC7RIC CORP.DA7E December 29, 1978 Mr.Eldon J.Brunner, Chief SHEE7 NO.2"Contrary to the above, as of November 16, 1978, the following single type records were stored in the indicated locations which did not meet the described single record storage facility physical feature require-ments.Original radiographs
Completton of ttems (1) and (2) above is expected by yebruary 28, 1979. Completion of item (3) is expected by june 30, 1979..As indicated earlier, June 1980 is the expected date when full compliance will be achieved for the storage of all nonduplicate records.
of safety related systems such as Reactor Coolant, Safety Injection and Chemical-Volume
The inspection report contains no information that is considered proprietary.
Control, dating to 1968, stored in cardboard filing boxes (Nos.51, 52, 53, 57, and 58)at the Andrews Building.Operations
Very truly yours, gP4k..
Recorder Charts (no copies/duplicates
L. D. Wh te, Jr.
available)
 
stored in steel filing cabinets in a vacant office at the station Warehouse Building." Since the inspection
  ~ , X~
the radiographs
(
have been removed from the cardboard filing boxes and placed in fire rated (Class 350-1 hr)cabinets.Fire rated cabinets (Class 150-1 hr), better suited for the protection
s~}}
of radiographs, have been purchased and will be utilized for the storage of the radiographs
upon their receipt in early January.The radiograph
cabi-nets will be located at the Jefferson Road Record Vault which has a four hour fire rating and is equipped with temperature
and humidity control.Upon completion
of their relocation
by mid-January, the radiographs
will be afforded the necessary protection
for a single record storage facility having physical requirements
comparable
to those specified in paragraphs
5.6 of ANSI N45.2.9-1974.Due to the space limitation
at the jefferson Road Record Vault, a new record storage room is being designed and constructed
to accommodate
the remaining nonduplicate
records.This new storage room will meet the physical requirements
for a single records storage facility prescribed
by ANSI Standard N45.2.9 and/or suitable fire protection
alternatives
provided by NRC Regulatory
Guide 1.88.Pending completion
of the new storage room, the fire rated (Class 350-1 hr)filing cabinets which contain the Operations
Recorder Charts are being transferred
from the Warehouse building to a vacant room at the Andrews St.facility.The vacant room is both more suitable than the warehouse location and remote from the existing storage for duplicate records.This interim storage location is in a fire resistive reinforced
con-crete building, has a sprinkler system and is free of combustibles
other than the protected records.The surrounding
area has been recently vacated, con-tains a minimum of combustibles
and is also protected by a sprinkler system.With the exception of meeting the four hour fire rating, the interim storage location has the features essential for the protection
of the records from possible destruction
by causes such as fire, flooding, tornadoes, insects, rodents and from possible deterioration
by a combination
of extreme varia-tions in temperature
and humidity.Completion
and occupancy of the new four hour records storage room is expected by June 1980.  
~~(  
R OCHESTER GAS AND ELECTRIC CORP.DATE December 29, 1978'Mr.Eldon J., Brunner, Chief SHEET NO.3 Corrective
steps being taken to avoid further items of noncompli-
ance are threefold:
1.Clarification
has been provided in the QA Manual and will be provided in the Ginna Procedure QC1701 of the likelihood
that some records are unable to be duplicated
and the preferred requirements
and location for their storage.2.Ginna and Engineering
records processing
personnel will be reindoctrinated
in record storage and preservation
require-ments.3.Ginna Station records personnel have initiated an investigation
to determine the existence of additional
records which are not presently duplicated
and which will require processing
similar to the recorder charts.In addition, this investigation
will determine if all required operating records are being processed for record retention.
Completton
of ttems (1)and (2)above is expected by yebruary 28, 1979.Completion
of item (3)is expected by june 30, 1979..As indicated earlier, June 1980 is the expected date when full compliance
will be achieved for the storage of all nonduplicate
records.The inspection
report contains no information
that is considered
proprietary.
Very truly yours, gP4k..L.D.Wh te, Jr.  
~, X~(s~
}}

Latest revision as of 21:12, 29 October 2019

Responds to NRC 781206 Ltr Re Violation Noted in IE Insp Rept 50-244/78-24.Corrective Actions:Radiographs Removed from Cardboard Filing Boxes & Placed in Fire Rated Cabinets & Record Storage Room Added for Nonduplicate Records
ML17244A356
Person / Time
Site: Ginna Constellation icon.png
Issue date: 12/29/1978
From: White L
ROCHESTER GAS & ELECTRIC CORP.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17244A355 List:
References
NUDOCS 7902080080
Download: ML17244A356 (6)


Text

EA Ie I~~ 4 aee f

'I ROCHESTER GAS AND ELECTRIC CORIoORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649 LEON 0, WHITE, JR. TEI EPNovE VICE RRESIOENT *RER cooc TIe 5 'Er 2700 December 29, 1978 Mr. Eldon j. Brunner, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Subject:

IE Inspection No. 50-244/78-24 R. E. Ginna Nuclear Power Plant, Unit $ 1 Docket No. 50-244

Dear Mr. Brunner:

This letter is in response to your December 6, 1978 letter received December ll, 1978, concerning the inspection conducted at Ginna Station, Corporate Offices and the Andrews St. Building on November 13-16 by Messrs. Markowski, Napuda and Kehoe of your office.

According to your letter, it appeared that one of our activities was not conducted in full compliance with NRC requirements, as quoted below.

This letter contains information in response to this item.

"10 CFR 50, Appendix B, Criterion XVII states in part 'Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility.'ection 1 of Supplement IV, Revision 3, to the FSAR (the approved QA Program) states in part, 'The program conforms to the following AEC Regulatory Guides and ANSI Standards... Regulatory Guide 1.88, "Collection, Storage and Maintenance of Nuclear Power Plant Records"...'ection 17 further states in part, 'The records which fall within quality assurance record requirements include those records required by Section 6.10 of the Technical Specifications, the quality assur-ance program... All records associated with the operation... of... systems, and components covered by the quality assurance program are Guide 1.88 endorses ANSI N45.2.9-1974, 'Requirements for included.'egulatory Collection, Storage, and Maintenance of Quality Assurance Records fo, Nuclear Power Plants.'aragraph 5.6 of this standard describes the physical requirements for a single record storage facility.

V9020800go

~ ~

4 r~

)'~

77OCH f7ER GAS AhIO ELEC7RIC CORP. SHEE7 NO. 2 DA7E December 29, 1978 Mr. Eldon J. Brunner, Chief "Contrary to the above, as of November 16, 1978, the following single type records were stored in the indicated locations which did not meet the described single record storage facility physical feature require-ments.

Original radiographs of safety related systems such as Reactor Coolant, Safety Injection and Chemical-Volume Control, dating to 1968, stored in cardboard filing boxes (Nos. 51, 52, 53, 57, and 58) at the Andrews Building.

Operations Recorder Charts (no copies/duplicates available) stored in steel filing cabinets in a vacant office at the station Warehouse Building."

Since the inspection the radiographs have been removed from the cardboard filing boxes and placed in fire rated (Class 350-1 hr) cabinets.

Fire rated cabinets (Class 150-1 hr), better suited for the protection of radiographs, have been purchased and will be utilized for the storage of the radiographs upon their receipt in early January. The radiograph cabi-nets will be located at the Jefferson Road Record Vault which has a four hour fire rating and is equipped with temperature and humidity control.

Upon completion of their relocation by mid-January, the radiographs will be afforded the necessary protection for a single record storage facility having physical requirements comparable to those specified in paragraphs

5. 6 of ANSI N45. 2. 9-1974.

Due to the space limitation at the jefferson Road Record Vault, a new record storage room is being designed and constructed to accommodate the remaining nonduplicate records. This new storage room will meet the physical requirements for a single records storage facility prescribed by ANSI Standard N45.2.9 and/or suitable fire protection alternatives provided by NRC Regulatory Guide 1.88. Pending completion of the new storage room, the fire rated (Class 350-1 hr) filing cabinets which contain the Operations Recorder Charts are being transferred from the Warehouse building to a vacant room at the Andrews St. facility. The vacant room is both more suitable than the warehouse location and remote from the existing storage for duplicate records. This interim storage location is in a fire resistive reinforced con-crete building, has a sprinkler system and is free of combustibles other than the protected records. The surrounding area has been recently vacated, con-tains a minimum of combustibles and is also protected by a sprinkler system.

With the exception of meeting the four hour fire rating, the interim storage location has the features essential for the protection of the records from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents and from possible deterioration by a combination of extreme varia-tions in temperature and humidity. Completion and occupancy of the new four hour records storage room is expected by June 1980.

~ ~

(

R OCHESTER GAS AND ELECTRIC CORP. SHEET NO. 3 DATE December 29, 1978

'Mr. Eldon J., Brunner, Chief Corrective steps being taken to avoid further items of noncompli-ance are threefold:

1. Clarification has been provided in the QA Manual and will be provided in the Ginna Procedure QC1701 of the likelihood that some records are unable to be duplicated and the preferred requirements and location for their storage.
2. Ginna and Engineering records processing personnel will be reindoctrinated in record storage and preservation require-ments.
3. Ginna Station records personnel have initiated an investigation to determine the existence of additional records which are not presently duplicated and which will require processing similar to the recorder charts. In addition, this investigation will determine if all required operating records are being processed for record retention.

Completton of ttems (1) and (2) above is expected by yebruary 28, 1979. Completion of item (3) is expected by june 30, 1979..As indicated earlier, June 1980 is the expected date when full compliance will be achieved for the storage of all nonduplicate records.

The inspection report contains no information that is considered proprietary.

Very truly yours, gP4k..

L. D. Wh te, Jr.

~ , X~

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