ML19253D034

Forwards Request for Addl Info to Complete Review of QA Program

ML19253D034
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/05/1979
From:	Haass W Office of Nuclear Reactor Regulation
To:	Trimble D ARKANSAS POWER & LIGHT CO.
References
NUDOCS 7912120534
Download: ML19253D034 (3)

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DEC 51979 Mr. David Trimble, Manager Licensing Arkansas Power and Light Company P.O. Box 551 Little Rock, Arkansas 77203

SUBJECT:

Quality Assurance Program Topical Report (APL-TOP-1A)

We have evaluated Arkansas Power and Light Company's Revision 5 to APL-TOP-1A, "Quali ty Assurance Manual-0perations," submitted wi th your June 11, 1979 letter.

Additional infomation, which is contained in the enclosed staff positions, is required from AP&L.

AP&L's response to the enclosure should be submitted as a revision (25 copies of affected page changes) to the original report by January 11, 1980.

AP&L's exception to Section C, 22 of Regulatory Guide 1.123 is considered an open item. A staff position on this subject should be forthcoming in the near future.

If you have any questions regarding this request, we are available for a meeting or conference call with AP&L.

In this case, please contact Jim Conway at (301) 492-7741.

Sincerely,

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.x-O Walter P. Haass, Chief Quality Assurance Branch Division of Project Management

Enclosure:

Staff Positions cc:

L. Humphrey 1541 296 M

7912120 b~3 Y' V

ARKANSAS POWER AND LIGHT COIPA"Y STAFF POSITIONS 421.62 It is a staff position that cognizant QA personnel be involved in reviewing and approving maintenance and surveillance procedures and that QA is involved during the implementation of these pro-cedures.

Clarify section 5.2 to address this position or describe an acceptable alternative.

421.63 Page 1, Item 3 - It is a staff position that a comitment to a (App. A)

Regulatory Guide is a comitment to implement the requirements (indicated by the verb "shall") and the guidelines (indicated by the verb "should") for a particular ANSI Standard unless otherwise stated in the regulatory position of the guide.

Accordingly, AP&L should clarify their intent to implement the guidelines contained in those ANSI Standards endorsed by the following Regulatory Guides:

1. 30, 1. 37, 1. 3 9-Rev. 2, 1.58, 1. 64-Rev. 2,1. 88-Re v. 2, 1. 94-Rev. 1, and 1.ll6-Rev. 0-R, or describe acceptable alternatives to the guide-lines contained therein.

421.64 Page 3 - Your exception to Section 5.2.7 of ANSI N18.7 is not accept-(App. A) able.

It is a staff position that maintenance and modifications including procurement and use of replacement items are to technical requirements equal to or better than those specified on the original i tem or activity.

A reduction in the technical and administrative requirements from the endorsed ANSI Standards should be documented with appropriate rationale for the reduction and approved by author-ized Engineering and QA personnel.

flodify item 1 to address this posi ti on.

421.65 Page 15 - Your exception to Section 4.6 of ANSI N45.2.5 is not (App. A) acceptable.

It is the staff's position that finishes be inspected because of the effect it has in revealing defects in construction and pouring practices.

Modify your exception to address this posi-tion.

421.66 Page 17 - Your exception to Section 5.1 of ANSI N45.2.5 is not (App. A) acceptable.

It is a staff position that in-process testing of grout on a daily basis is necessary. Justification for this position is as follows:

1.

When grout is used in preplaced aggregate concrete, it is not used in " minimal quantities". On the contrary, sometimes the quantity of grout is quite large and when it is used in safety related structures its quality must be ascertained by testing.

2.

Prepackaged grout may be in storage for extended periods of time. During that period, due to ambient humidity, initial setting may take place.

Under these conditions, testing of grout "by lot," which is in storage and used as needed, may not be representative of the material actually used.

Modify Section 5.1 to address this position which is contained in Table B of ANSI N45.2.5-1978.

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.-. 421.67 Page 18 - Your exception to Section 5.2 of ANSI N45.2.5 requires (Appr. A) clarification.

It is the staff's position that the composite of each shipment be tested for chemical composition, pH. and specific gravity in accordance with ASTM C-494.

Clarify your response to address this position.

421.68 Editoral Comment - Show the " Quality Assurance Supervisor" on the organizational chart in Fig.1-3A.

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