ML20055A902

Forwards marked-up Portion of FSAR Re Use of Const Bldg Vault to Handle,Store & Dispose of Records Associated W/ Const Phase of Plant.Const Bldg Vault Will Be Used as Extension of Permanent Records Room

ML20055A902
Person / Time
Site:	Summer
Issue date:	07/12/1982
From:	Dixon O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8207200107
Download: ML20055A902 (6)

Text

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SOUTH CAROUNA ELccTmc & GAS COMPANY ea. , aa n . .>. ~

Cotuuma. Soute< Canoueen 2921 O O . W . Di s o** . J.

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July 12,1982 Mr. Ilarold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comtission Washington, DC 20555

Subject:

Virgil C. Stmner Nuclear Station Docket No. 50/395 Recordskeeping Dear Mr. Denton On April 26, 1982, the operations staff of the Virgil C. Stmner Nuclear Station asstrnal the respons.bility for handling, storage and disposition of those records associated with the construction rihase of the station. South Carolina Electric and Gas Canpany (SCI %G) has an ongoing program comtitted to receiving, processing, microforming and indexing these records. Certain record types, notably radiographs, as well as processed rolls of microfilm of construction activity records are maintained in a vault located within the current Cbnstruction Administration Building. '1his vault is also used to store hardcopy records which are being prepared for microforming.

Current plans for record processing require use of the Construction Building Vault after the issuance of an operating license. Ebr that purpose SCI %G perfonned an evaluation of this vault against the requirements of Regulatory Guide 1.88 as presented in Appendix 3A of the Virgil C. Stener Final Safety Analysis Report (FSAR). The current regulatory guide position in the FSAR addresses only the Service Building Records Iban. A marked up copy of a proposal change to this position is provided to address both the Service Building Records Hoon and the (bnstruction Building Vault. W e evaluation determined that the Construction Building Vault is similar to the Service Building Permanent Records Iban with the following clarifications and exceptions:

1. ANSI N45.2.9-1974 Section 5.6.2. W e walls and floor are concrete. We vault is inside an existing structure, renoving any requirenent for roof sloping. We introduction of water into the vault in appreciable i

quantities is a rerote possibility due to the enclosure of the vault in the existing Construction Administration Building.

h l 2. FSAR Appendix 3A - page 130 bb, "The Permanent Records Roon is equipped l with an early warning fire detection and autanatic fire suppression system, with electronic supervision at a constantly attended location."

mis statement is applicable to the Service Building Permanent Records Roon. The Construction Building Vault is equipped with an autointic fire 8207200107 820712 PDR ADOCK 05000395 A PDR c 1

Mr. Ilarold R. Denton July 12, 1982 Page 2 suppression systs which meets the requirements of ANSI N45.2.9-1974.

SCE&G considers this adequate protection for the Construction Buildirg Vault.

Mditionally, SQ%G will cmply with section 5.5 of ANSI N45.2.9-1974 (security) with a physical check of the vault by security personnel twice on each shift to ensure against unauthorized entry.

In stumation, SCI %G will utilize the existing Construction Building Vault outlined above as an extension of the Service Building Permanent Records Ibm.

If you have any questions, please let us know.

Ve truly urs, s'

O. W. Dixon, Jr WDS:CWD:glb Attaclinent cc: V. C. Statmer w/o att.

G. H. Fischer w/o att.

II. N. Cyrus T. C. Nichols, Jr. w/o att.

O. W. Dixon, Jr.

M. B. Witaker, Jr.

J. P. O'Reilly H. T. Babb D. A. Natanan C. L. Ligon (NSRC)

W. A. Williams, Jr.

3 R. B. Clary O. S. Bradham A. R. Koon M. N. Browne G. J. Braddick J. L. Skolds J. B. Knotts, Jr.

B. A. Bursey NPCF File 1

( 1.88 COLLECTION, STORACE AND MAINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS (Revision 2; 10/ 76)

The Virgil C. Summer Nuclear Station quality assurance records

/ program complies with the recommendations of this Regulatory Guide with the following exceptions and clarifications:

ANSI-N45.2.9-74 Section Exceptions and Clarifications

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5.3 During the interim period for which the SCE&G QA organization maintains records prior to transmittal totherecordsprogram(Permanentfacilitf),the records will be kept in two remote locations in an office 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 28 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) prior to turnover of future permanent and non-permanent records to the PRS as they are issued after commercial operations. 1 ya %l00y aO N 5.6 Thefpermanent records room te 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 extreme

( 11 variations in temperature and humidity conditions.

3A-130 AMENDMENT 21f bLf, j fRV

y,a $h 'lD ,g @G CW 1 5.6 The7 permanent records room % 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-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 />.

3.2.7 For SCE&G Quality Assurance organization generated r records required by Appendix A, the following program will be implemented dealing with the turnover to the permanent facilit$ and retention times of non-permanent 33 records as required by Paragraph 3.2.7.

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

QA Procedures QA Plans Vendor Procedures Vendor Survey Reports Vendor inspection Reports 28 Vendor Audit Reports Surveillance Reports

2. After commercial operation, the records in 1, will be placed within the SCE&G records retention

' 3 program (permanent facilit/$asissued.

3. Non-permanent records generated prior to com-mercial operations will only be placed within the recordretentionprogram(permanentfacilithif 3]

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( they we 1 ;rm rated within 3 years prior to com-mercial operation. SCE&G justifies this position based on the fact the Paragraph 2.2.2 of ANS 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 I within procurement control programs.

33 3A-130a AMENDMENT.3&

L'O'/::1CR , 1;^1-40W, /Nb

r In addition, as discussed with the NRC Staff:

gaaeoss $*oldI*)

1. Thes permanent records room is equipped with an early warning fire l 17 detection and automatic fire suppression system, with electronic supervision at a constantly attended location. M' U# "'

7 I 13 A g\ tis agW pd t W)S ad ** M ah t M d w ff M Estd# *g3 M '

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

3. Work not directly associat with records storage og rg r g is glg prohibited within theppermanent records rooma Examples of such l 17 j prohibited activities include but are not limited to: records reproduction, film developing, and fabrication of microfiche cards, t<rw 1 Idi=>

4. Smoking, eating and drinking are prohibited throughout the4 permanent 33

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records roomond khc bMbbw b ' 'hg MW Ib l 17

5. Ventilation, temperature, and humidity control equipment is protected inside with standard fire dampers where they penetrate fire barriers boundingthestoragefacilit[ [yy l

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s 33 AMENDMENT tt 3A-130bb .g...;;.; , 3g g yf% /7&

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6. Some records generated by Nuclear Operations during the operations phase 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 Temporary Storage Facilities until they are transferred to the Permanent Records Storage Facilit .' The 33 28

( 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.

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33 3A-130c AMENDMENT -fir tiO"Z:0:n , 1001 vbly,o98L