ML19326B736
| ML19326B736 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/11/1977 |
| From: | Rueter D ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19326B724 | List: |
| References | |
| 1-117-7, NUDOCS 8004170568 | |
| Download: ML19326B736 (2) | |
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q H elm N G BUILO ARhANSAU ARKANS AS POWER & LIGHT COMPANY November 11, 1977 1-117-7 2-117-5 Mr. G. L. Madsen, Chief Reactor Operations 6 Nuclear Support Branch United States Nuclear Regulatory Commission Office of Inspection 6 Enforcement Region IV 611 Ryan ?laza Drive, Suite 1000 Arlington, Texas 76012
Subject:
Arkansas Nuclear One - Units 1 6 2 Inspection Report 50-313/77-16 and 50-368/77-21 Response to Infraction (File:
2-0232, 0232)
O
Dear Mr. Madsen:
We have reviewed the subject inspection report and the attached notice of violation.
Items la and Ib are related to the receipt inspection of Unit 2 fuel assemblies.
With regard to items'la and lb it is our position that we have not violated Criterion V of Appendix B to 10CFR50 in performance of ANO-2 fuel receipt inspection. As indicated in your inspection report, the procedure 2503.01 did contain appropriate acceptance criteria.
It is our position that the ANO-2 fuel receipt inspection program does satisfy the APSL Quality Assurance Manual in concept but not in detail. Due to the nature of the nuclear fuel, it does not lend itself to satisfying all the specific requirements of the QA Manual. Therefore, we have developed a network of procedures and instructions to provide assurance that all appli-cable require.ents are fulfilled.
Provided below is our response to the specific areas of concern of viola-tions la and Ib of the subject inspection report:
la - (1) Procedure 1502.05 (Control and Accountability of Special Nuclear Material) identifies those individuals responsible for performing the inspection operations.
p (2) Procedure 2503.01 will be revised by December 15,1977 to
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specifically reflect the method of inspection examination.
(3) Procedure 2503.01 will be revised by December 15,1977 to identify required special inspection tools and equipment.
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~ ' ~ Mr. G. L. Madsen November 11, 1977 V
lb - It is not the intent of Section 10.4 of our QA Manual that the QC Engineer determines the qualification of the Nuclear Engineer and Reactor Engineers and authorizes them to perform their assigned duties.
Section 10.4 of the QA Manual was satisfied in the sense that a qualified and certified QC inspector did perform an independent inspection of the ANO-2 fuel receipt inspection process.
In summary, there is ambiguity as to the detail applicability of the QA Manual for the receipt of special nuclear material.
It is our position that the receipt, inspection, storage and shipment of all radioactive materials including special nuclear material and nuclear fuel are not subject to the specific requirements of the QA Manual because of the peculiar nature and special requirements for handling of these materials.
Separate procedures which comply with 10CFR50 and other applicable regula-tions are used for these operations. Therefore, we are reviewing this situation in order to provide a clearer representation of our quality requirements with regard to radioactive materials.
i It is anticipated that our affirmative action with regard to infraction Ib will be completed by February 1,1978.
With regard to item Ic, Startup Field Report 532 has been written to correct the noted valve numbering problem and ensure that the correct "as-built" condition is reflected on the appropriate drawings.
Concerning item Id, all identified release exceptiens have been added to the punchlist.
In addition, a training session has been conducted reinstruc-ting the Startup Engineers on the proper correlation between the Release Exceptions and Punchlist. Each engineer has made an audit of his system to correlate the two.
It is our opinion that except for those items identified above as still requiring completion, we are now in full compliance.
s Very truly yours, 1
'f M 4
Donald A. Rueter Director, Technical and Environmental Services DAR:DNB:aw l
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