ML19326C613
| ML19326C613 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/01/1976 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19326C599 | List: |
| References | |
| NUDOCS 8004230713 | |
| Download: ML19326C613 (2) | |
Text
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ARKANSAS POWER & LIGHT COMPANY 97H S LOUISlAN A STAEETS. LITTLE AOCK. A AKANSAS 72203.(5013 371-.1000 March 1, 1976 Reactor Construction and Operations Branch United States Nuclear Regulatory Commission Office of Inspection and Enforcement k
Region IV 611 Ryan Plaza Drive, Suite 1000 Arlin};on, Texas 76012 i
Attention:
Mr. G. L. Madsen t
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Subject:
Arkansas Power S Light Company
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Arkansas Nuclear One-Unit 1 Docket No. 50-313 License No. DPR-51 i
IE Inspection Report No. 50-313/75-15 Gentlemen:
The fe' lowing provides responses to items in and IB of non-compliance which were identified as infractions in the subject report.
Responses to items 2, 3, and 4 of the report were provided in our letter of February 5, 1976.
While we are providing responses to all items noted as items of non-compliance, we do not always agree that de were not in complisace with applicable regulations.
The replies to such items state AP5L's position on the item and our justification for our interpretation or position.
Where we agree that we were in non-compliance, we will provide responses delineating the actions taken to achieve compliance and to avoid further non-compliance, and the expected date of full compliance.
lA Infraction C:ntrary to the requiremer s of ICCFR50 Appendix B Criterion 10 and A?5L Quality Assurance Manual-Operations, the inspector found durina the review of approximately 100 Job Orders associated with Q-listed items that form QC-2's had not been prepared and that there were no d::umented inspections.
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Response
(1). A: system is being developed to insure inspections of quality-related activities classified as Lev ~el 1, 2 or 3 as defined in APSL's. Administrative Procedure 1005.01, Section 5.5.3.
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(2)
These inspections will be conducted by persons other than
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these directly performing the work and who have met the g,7 qualification requirements as specified in APGL's Quality
~4 Control Procedure 1004.20. All qualified inspection personnel
-will be so designated cn a list of qualified inspectors approved by the Quality Control Engineer per APGL Quality Assurance Manual-Operations, Section 10, varagraph 10.4.1.3.
These inspections will be documented on an approved form and upon completion will be reviewed by the QCE and retained in the plant files as part of the Job Order.
(3)
This inspection program will be in complete operation by May 1, 1976.
1B Infraction contrary to the requirements of 10CFR50 Appendix B-Criterion 10 and A'5L yeality Assurance Manual-Operations, the licensee could not provide documentation of the inspection (QC-2) for preventive maintenance or the.preoperational baseline inservice inspection program, with the exception of the automatic ultrasonic exanination.
Response
(1)
The program as outlined in response to item 1A is also designed to correct deficiencies in the area of preventive maintenance inspection.
It is our contention that the preoperational baseline inservice inspection program should not be considered an item of non-compliance due to the lack of documented AP5L QC inspection.
This inspection was performed on a sub-contract basis by a vendor having an approved quality assurance program and in addition was witnessed and approved by a licensed boiler vessel code inspector.
(2)
The QCE will provide surveillance on our inspection program to insure correct and complete impicmentation.
h'e contend that no further action is required on the preoperational baseline inservice inspection program.
(3)
Full i.glementation of our inspection program is expected by May 1, 1976.
V ry truly yours
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