ML17325A893

Steam Generator Repair QA Program

ML17325A893
Person / Time
Site:	Cook
Issue date:	07/31/1988
From:	INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17325A894	List: ML17325A893 ML17326B419
References
NUDOCS 8808230123
Download: ML17325A893 (60)

Text

COOK NUCLEAR PLANT UNIT NUMBER 2 DOCKET NUMBER 50-3]6 LICENSE NUMBER DPR-74 STEAM GENERATOR REPAIR QUALITY ASSURANCE PROGRAM Prepared by the AEPSC ality Assurance Department REVIBIED BY:

Section Manager - Nuclear Safety and Licensing APPROVED BY:

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p gqe8 AEPSC Director - Qual ity Assurance Controlled Copy No.

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STEAM GENERATOR REPAIR EQUALITY ASSURANCE PROGRAM FOR THE COOK NUCLEAR PLANT UNIT NO.

2 TABLE OF CONTENTS Section 1

2 3

5 6

7 8

9 10 11 12 13 14 15 16 17 18 Titie Table of Contents......................................

Cook Nuclear Plant Unit Steam Generator Repair Project (SGRP) guality Assurance Program Policy.

0rganszation.....,.....................................

guality Assurance Program..............................

esign Control..................-.......................

D Procurement Document Control...........................

Instructions, Procedures, and Drawings.................

Document Control.......................................

C Control of Purchased Items and Services................

Identification and Control of.Items....................

Contr'ol of Special Processes...........................

nspection.............................................

I est Control...........................................

T Control of Measuring and Test Equipment......

Handling, Storage, and Shipping..............

Inspection, Test, and Operating Status.......

Nonconforming Items.................."........

Corr ective Action.......................................

guality Assurance Records..............................

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A cations the SGRP roject..........................................

P Figure No.

1 Project SGR Oroanization.......

Figure No.

2 Corporate SGR Organization.....

Figure No.

3 Site SGR gA Organization.......

Appendix B (SGRP)

Additional AEPSC/IEM Exceptions/Clarifi to Standards and Regulatory Guides for

~Pa e

8 1

2-12 12-17 18-19 19-22 22-23 23-25 26-29 29-30 31-33 33-35 35-36 36-38 38-40 40-42 42-43 43-45 45-46 46-50 51 52 53 54-55

July, 1988

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I p 1

Revised 06/03/88 Cook Nuclear Plant Unit 2 Steam Generator Re air Pro'ect SGRP UALITY ASSURANCE PROGRAM POLICY The American Electric Power Service Corporation (AEPSC) and Indiana Michigan Power Company (I&M) Steam Generator Repair guality Assurance

Program, as described in the Steam Generator Repair Report, and the "Updated Ouality Assurance Program Description for the Donald C.

Cook Nuclear Plant," referred to as the QAPD, plus SGRP supplements thereto, shall be applicable to activ-ities affecting the quality of safety-related structures,

systems, and components (items).

The implementation of the SGR QA Program may be accomplished by AEPSC and/or I&M, or delegated in whole or in part to other AEP System companies, or to outside parties.

However, AEPSC and/or I&M retain full responsibility for all activities affecting safety-related items.

The performance of the delegated organization shall be evaluated by AEPSC gA Department audits, and/or surveil-lances conducted on a frequency commensurate

.with the scope and importance of assigned work.

The engineering and design associated with SGRP safety-related items shall be accomplished in accordance with the established AEPSC gA Program, or by contractors whose gA program has been reviewed and approved by the AEPSC gA Department.

On-site contractors shall establish and implement SGRP specific gA programs for their scope of work on safety-related items.

These programs and implementing procedures shall be reviewed and approved prior to start of work, by the AEPSC OA Department as a minimum.

The SGR OA Program shall assure satisfactory completion of work related to safety-related items prior to their release back to plant management.

Date:

A' c o P. A. Barrett AEPSC Director - guality Assurance

July, 1988

SECTION I ORGANIZATION 1.1 SCOPE American Electric Power Service Corporation (AEPSC) and Indiana Michigan Power Company

( I&M) are responsible for establishing and implementing the Steam Generator Repair (SGR) guality Assurance (gA) Program for the Cook Nuclear Plant Unit No. 2.

An AEPSC project management organization (Figure No. l) has been established to manage and direct the SGR Project.

Although authority for development and execution of various portions of the program have been delegated to others, such as contractors, agents or consultants, AEPSClI&M retains overall responsibility.

AEPSCII&M evaluates such activities based on the status of safety importance.

This evaluation is initiated early enough to assure effective quality assurance during the performance of the delegated 'activity.

This section of the SGR gA Program identifies the organizational structures, responsibilities,

~ authorities and duties for Steam Generator Repair Project (SGRP) activities affecting the quality of safety-related items.

I:.2 IMPLEMENTATION 1'.2.1 Source of Authorit The Chairman of the Board and Chief Executive Officer of AEPSC and I&M is responsible for the safe accomplishment of SGRP activities at the Cook Nuclear Plant.

Authority and responsibility for effectively implementing the SGR gA Program are delegated through the AEPSC Senior Executive Vice President

- Engineering and Construction, to the AEPSC Vice President-Nuclear Operations, the AEPSC Assistant Vice President - Project Management, the AEPSC Assistant Vice President - Plant Construction and the AEPSC SGR Engineering Manager.

July, 1988

1.2.2 Res onsibilit for Attainin SGRP ual it Ob ectives The AEPSC Chairman of the Board and Chief Executive Officer has delegated the functional responsibility of the SGR gA Program to the AEPSC Senior Executive Vice President

- Engineering and Construction.

The AEPSC Director - Quality Assurance, under the direction of the AEPSC Senior Executive Vice President - Engineering and Construction, is responsible for specifying SGR gA Program requirements and verifying their implementation.

The AEPSC Vice President - Nuclear Operations, the AEPSC Assistant Vice President - Project Management, the Assistant Vice President - Plant Construction and the AEPSC SGR Engineering Manager under the direction of the AEPSC Senior Executive Vice President - Engineering and Construction, are responsible for effectively implementing the SGR gA Program.

e The Plant Manager, under the direction of the AEPSC Vice President-Nuclear Operations, is responsible for support of, and interface with the SGRP organization at the Cook Nuclear Plant during the SGRP through the Assistant Plant Manager - Technical Support.

SGRP management/supervisory personnel are responsible to plan, coordinate, and administrate those day-to-day verification activities of the SGR gA Program for which they are responsible.

The AEPSC Nuclear Safety and Design Review Committee (NSDRC) shall perform reviews and audits of SGRP activities.

1.2.3 American Electric Power Service Cor oration The responsibility for administrative and technical direction of the SGR Program is assigned to AEPSC.

AEPSC also provides management and techno-logical services for the various portions of the SGR Project.

w3w

July, 1988

1.2.4 SGRP Or anization The Chairman of the Board and Chief Executive Officer is ultimately responsible for the SGR gA Program.

This responsibility has been functionally delegated to the AEPSC Senior Executive Vice President-Engineering and Construction.

The AEPSC Senior Executive Vice President

- Engineering and Construction has further delegated SGR responsibilities which are administered through the following (Figure No. 2):

AEPSC Director - guality Assurance AEPSC Vice President

- Nuclear Operations'EPSC Assistant Vice President - Plant Construction AEPSC Assistant Vice President - Project Management AEPSC SGR Engineering Manager guali t Assurance De artment The AEPSC Director - guality Assurance is responsible for the SGR guality Assurance organization.

The SGR guality Assurance organization consists of the SGR guality Assurance Section (Site) (Figure No. 3) and is supple-

mented, as required, by the existing AEPSC gA organization (Audits and Procurement, gA Engineering, Administrative Staff and Site gA).

The SGR guality Assurance organization is organizationally independent and is responsible for the following:

Verify the implementation of the SGR gA Program through scheduled audits and survei llances.

Identify quality problems.

Initiate, recommend, or provide solutions through designated channels.

Verify implementation of solutions, as appropriate.

Prepare, issue and maintain SGR gA Program documents, as required.

July, 1988

Review SGR engineering,

design, procurement, installation and oper-ational documents for incorporation of, and compliance with appli-cable quality assurance requirements to the extent specified by the AEPSC management approved SGR gA Program.

Assure proper gA orientation, training, certification and qualifica-tion of non-AEPSC QA personnel supporting the SGRP on-site.

Identify noncompliances of the established SGR gA Program to the responsible organizations for corrective actions and report significant occurrences that jeopardize quality to SGR Project and senior AEPSC management, and plant management when required.

Follow up on corrective actions during and after disposition implementation.

Review the disposition of conditions adverse to quality to assure that action taken will preclude recurrence.

Review SGRP originated noncompliance, nonconformances, deviations, etc.

Haintain cognizance of industry and governmental quality assurance requirements such that the SGR gA Program is compatible with requirements,'as necessary.

Recommend for revision to, or improvements in the established SGR gA Program to SGR Project and senior AEPSC management.

Issue "Stop Mor k" orders when significant conditions adverse to safety-related items are identified, to prevent unsafe conditions from occurring and/or continuing.

Provide SGR Project and AEPSC management, when deemed necessary, with periodic reports concerning the status, adequacy and implementation of the SGR gA Program.

Prepare and conduct special verification and/or surveillance programs on SGRP activities, as required or requested.

Routine attendance and participation in daily SGRP work schedule and status meetings.

Provide adequate gA coverage relative to SGRP procedural and inspection controls, acceptance criteria, and SGRP gA staffing and qualification of personnel to carry out SGR gA assignments.

July, 1988

Review and approve reports generated by AEPSC SGR gA and assure that all required actions which result from adverse findings are adequately identified, dispositioned and implemented.

Review the Repair Contractor quality assurance program manual(s),

including subsequent revisions, to verify conformance with the SGR gA Program.

Review and approve Repair Contractor procedures, and subsequent revisions to verify conformance with SGR gA Program.

Review Nuclear Regulatory Commission (NRC) reports and ensure through the SGRP audit/surveillance program that adequate corrective and preventive actions are taken for adverse findings.

Assure that SGR work packages are reviewed initially for possible inclusion of AEPSC gA hold points and for surveillance/audit scheduling, and upon work completion for completeness of documentation.

Provide support to the SGRP management organization on matters related to quality assurance.

Participate in NRC inspections when required or requested.

Attend SGRP and NRC meetings and conferences when requested or as deemed necessary.

Assure that personnel certification packages for SGRP Repair Contractor inspection and examination personnel requiring certification are reviewed for conformance with the SGR gA Program.

Adhere to SGRP security, ALARA and radiological control work and contamination control practices.

0

~kd kdd The AEPSC guality Assurance Department is responsible for ensuring that activities affecting the quality of safety-related items are performed in a manner that meets applicable administrative, technical, and regulatory requirements.

In order to carry out this responsibility, the AEPSC Senior Executive Vice President - Engineering and Construction has July, 1988

given the AEPSC Director - Quality Assurance, the authority to stop work on any activity affecting the quality of safety-related items that does not meet the aforementioned requirements.

Stop work authority has been further delegated by the AEPSC Director - Quality Assurance to the AEPSC SGR Quality Assurance Supervisor.

Nuclear 0 erations Division The AEPSC Vice President

- Nuclear Operations provides functional direction and technical support to the SGRP and is responsible for the following SGRP support functions:

Implement the requirements of the SGR QA Program.

Formulate policies and practices relative to safety, licensing (Steam Generator Repair Reports, Technical. Specification issues, etc.), security, fuel management, radwaste and radiological protection support.

Provide technical and managerial guidance, direction, support and interface to ensure safe SGRP activities.

Provide technical support to all other AEPSC engineering divisions/department on engineering matters pertaining to the SGR project.

Provide overall administration of the SGRP health physics

program, including the necessary interface with the plant health physics program and ensure Repair Contractor compliance with the approved health physics program.

The Plant Manager is responsible for the following:

Provide an SGR Project Engineer (administratively responsible to the Plant Manager through the Assistant Plant Manager - Technical Support, providing technical liaison between plant operations and the SGRP organization).

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July, 1988

Overall responsibility for activities scheduled up to turnover to the SGRP.

Start-up and acceptance testing.

9 En ineerin and Desi n

The AEPSC engineering and design organizations provide SGRP engineering and design support and interface to the SGR Engineering Manager (AEPSC) through their respective AEPSC organization.

SGRP support functions of the SGR Engineering Manager include the following:

Implement the requirements of the SGR gA Program.

Ensure the proper flow of engineering information between the AEPSC organizations for the SGRP.

Arrange interorganizational meetings to ensure proper representation of involved engineering and design disciplines.

Ensure that engineering and design is performed in the most timely and efficient manner using the latest and most reliable information available.

Mork with AEPSC organizational representatives to develop engineering and design input for SGRP scheduling and provide such information to the Project Manager for inclusion into licensing and repair activities work schedules.

Assist, as required, in the establishment of the licensing and repair activities work schedules.

Keep informed of pertinent SGRP activities to ensure that schedules can be met, interface with the Project Manager for advisement of major schedule deviations, and assist in the resolution of these deviations, as required.

Coordinate conferences, as necessary, among vendors when appropriate. July, 1988

Coordinate AEPSC engineering and design requirements and comments in the preparation and issuance of SGRP technical and administrative procedures, specifications, initial and acceptance criteria and special test and operating procedures and instructions.

Coordinate and participate in SGRP activities associated with the preparation of Environmental Impact Statements, permit applications, and other documentation required for installation and operation of the repaired steam generators.

Coordinate engineering input for the development of cost estimates, project schedules, and other required data from the various AEPSC sources.

Assist in significant SGRP prestart-up and start-up events.

Assist in preparation of SGRP completion punch lists and close out of list items.

Participate in special

studies, projects, activities, or other

duties, as assigned.

Plant Construction Division 1

The AEPSC Assistant Vice President - Plant Construction provides technical SGRP support functions through the Construction Contracts Section.

The Construction Contracts Section is responsible for the following:

Implement the requirements of the SGR gA Program.

Scope, bid and make recommendations relative to SGRP contracts.

Contract administration of the Repair Contractor throughout the SGR project.

Pro 'ect Mana ement Division The AEPSC Assistant Vice President - Project Management is responsible for the direction and management of the SGR Project through the Project Manager and the Site Project Manager. July, 1988

The Project Management Division is responsible for the following:

Overall management and direction of the implementation of training and indoctrination, administrative, engineering, procurement, construction, health physics and ALARA activities associated with the SGRP in accordance with the SGR gA Program.

This includes project controls, construction contracts, radiation support, engineering and design, and site management.

Ensure development and implementation of the Repair Contractor's training, indoctrination and qualification programs for the SGRP.

Ensure proper flow of engineering/design information between SGRP organizations.

Arrange interorganizational conferences to ensure proper interface between involved engineering/design disciplines and Cook Nuclear Plant organizations.

Coordinate conferences, as necessary, among suppliers when appropriate.

Coordinate AEPSC engineering/design requirements and comments in the preparation and issuance of SGRP technical and administrative procedures, specifications, initial test and acceptance

criteria, and special test and operating procedures and instructions.

Coordinate and participate in SGRP activities associated with the preparation of Environmental Impact Statements, permit applications, and other documentation required for installing and operating the repaired steam generators.

Participate in special

studies, projects, activities, etc.,

as requested or assigned.

Ensure proper implementation of SGR Project Procedures and work packages in accordance with project programs and directives.

Coordinate, between AEPSC and Cook Nuclear Plant, work involving pre-outage activities, mobilization, training, support facilities, and replacement activities.

0'10-Duly, 1988

Establish, with Cook Nuclear Plant management, the use of facilities and/or locations for warehousing/storage,

radwaste, decontamination, installation, turnover, start-up, etc.

Review the SGRP turnover program to ensure that systems, components, structures and equipment are returned to the control of Cook Nuclear Plant management in an acceptable condition and that SGRP gA records are transferred to the plant for retention.

Participate with interface with Federal (NRC), State (Michigan) and local authorities when obtaining permits, reviews, audits, meetings, etc.,

concerning the SGRP and ensure notification to responsible organizations when action is required.

Manage and control all Repair Contractor site activities.

Ensure proper Repair Contractor planning is accomplished through

'etai'1 work package preparation and scheduling activities.

Coordinate the review and approval of Repair Contractor procedures and work packages in accordance with established requirements.

Ensure that an adequate material control program is established for the site, and that all materials and equipment are properly maintained by the Repair Contractor.

Ensure that a proper receipt inspection program is implemented and documented by the Repair Contractor.

Establish a craft training program, approve Repair Contractor program procedures, and ensure compliance with program training requirements.

Review and concur with planned construction

methods, crew sizes, tooling, usage of consumables, safety planning, and durations of scheduled activities.

Develop a program for the acceptance of the buildings, structures, facilities, and plant systems from the operating plant groups, and their corresponding turnover at the completion of SGRP activities which addresses the following: July, 1988

inter aces with all the existing plant procedures and instructions; provides for ongoing maintenance of permanent plant equipment in accordance with the appropriate requirements for equipment/

plant under the control of the Repair Contractor.

Provide functional coordination and control of all site SGRP administration and control activities.

Coordinate the review, evaluation, and processing of all Repair Contractor purchase orders.

Direct activities concerning the storage, movement and subsequent disposal of radioactive waste.

9 SECTION 2

UALITY ASSURANCE PROGRAM

" 2.1 SCOPE Policies that define and establish the Cook Nuclear Plant Unit No.

2 SGR gA Program are summarized in the individual sections of this document, which supplements the "Updated guality Assurance Program Description for the Donald C.

Cook Nuclear Plant" (referred to as the gAPD).

The program shall be implemented through procedures and instructions responsive to provisions of the SGR gA Program, and wi 11 be implemented during the Steam Generator Repair Project.

guality assurance controls apply to SGRP activities affecting the quality of safety-related items to an extent based on the importance of those items to safety.

Such SGRP activities are performed under controlled conditions, including the use of appropriate equipment, environmental conditions, assignment of qualified personnel, and assurance that all applicable prerequisites have been met.

SGRP gA Program status,

scope, adequacy, and compliance with 10CFR50, Appendix 8, shall be regularly reviewed by AEPSC management through

reports, meetings, and review of audit and surveillance results. July, 1988

The implementation of the SGR gA Program may be accomplished by AEPSC and(or Indiana Michigan Power Company (IEM) or delegated in whole or in part to other AEP System companies or outside parties.

However, AEPSC and/or I8M retain full responsibility for all SGRP activities affecting safety-related items.

The performance of the delegated organization is evaluated by audit or su< vei llances on a frequency commensurate with their scope and importance of assigned work.

2.2 2.2.1 IMPLEMENTATION The AEPSC Director - guality Assurance has stated in a signed, formal "SGRP gA Program Policy", that it is the corporate policy to comply with the provisions of the SGR QA Program.

The policy makes this SGR gA Program and the associated implementing procedures mandatory, and requires compliance by all responsible organizations and individuals.

2.2.2 The SGR gA Program at AEPSC and the plant consist of controls exercised by a SGRP management organization responsible for attaining quality objectives, and by organizations responsible for assurance functions.

The SGR gA Program is reviewed by the Plant Nuclear and Safety Committee (PNSRC).

The SGR gA Program effectiveness is continually assessed through management review of various reports, NSDRC audits, AEPSC gA audits and surveillances, NSDRC review of AEPSC gA audits, and may also be reviewed by independent outside parties as deemed necessary by management. July, 1988

The SGR QA Program is intended to apply throughout the SGRP.

The SGR QA Program applies to activities affecting the quality of safety-related items and related consumables during the SGRP.

Safety-related items are identified in the Facility Data Base

, AEPSC Specifications and other documents which are developed and maintained for the plant.

lt As deemed necessary by the AEPSC Director - Quality Assurance, the Project Manager or the Plant Manager, applicable portions of the SGR QA Program controls may be applied to nonsafety-related activities associated with the SGRP to ensure that commitments are met.

2.2.3 g7

'u The SGR QA Program parallels the format of the

QAPO, as applicable, and supplements the QAPO by stating SGRP policy, and describing how the SGRP controls are implemented.

Changes to the SGR QA Program are submitted to the NRC with the annual submittal of the QAPD.

Changes made. to the SGR QA Program that reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implemen-tation.

The submittal of these described changes shall be made in accordance with the requirements of 10CFR50.54.

'2.2.4 Documents used for implementing the provisions of the SGR QA Program include the following:

SGR Project Procedures (PPs) which establish the policy for compliance with specified criteria, and assign responsibility to the various organ-

izations, as required, for implementation.

The SGR PPs are reviewed by AEPSC Quality Assurance for concurrence that they satisfactorily implement regulatory requirements and commitments. July, 1988

PPs are supplemented, as applicable, by existing AEPSC General Procedures (GPs)/organizational procedures and Cook Nuclear Plant procedures.

The Repair Contractor performs work on-site under it's own quality assurance program (gA manual and procedures),

which is reviewed by AEPSC gA for compliance and consistency with the applicable requirements of the SGR gA Program and the contract, and is approved by AEPSC gA prior to the start of work.

The Repair Contractor is responsible for assuring proper training, indoctrination, qualification and certification of its personnel, as applicable.

2.2.5 Provisions of the SGR gA Program apply to SGRP activities affecting the quality of safety-related items.

Appendix A to the gAPD lists the Regulatory/Safety Guides and ANSI Standards that identify AEPSC's commit-ment.

Imposition of these guides/standards on SGRP suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be supplied.

Appendix 8 of the gAPD describes necessary exceptions and clarifications to the requirements of those documents.

Appendix 8 (SGRP)to the SGR gA Program describes the necessary additional exceptions and clarifications to the requirements for the SGRP.

2.2.6 Activities affecting safety-related items are accomplished under controlled conditions.

Preparations for such activities include consideration of the following:

a) b)

c)

Assigned personnel are qualified.

Work has been planned to applicable engineering and/or Technical Specifications.

Specified equipment and/or tools are available. July, 1988

d) e)

f) g)

h}

Materials and items are in an acceptable status.

Systems or structures on which work is to be performed are in the proper condition for the task.

Proper instructions/procedures for the work are available for use.

Items and facilities that could be damaged by -the work have been protected, as required.

Provisions have been made for special controls, processes, tests and verification methods.

2.2.7 Responsibility and authority for development and implemention of indoctrination and training of SGRP personnel are specifically delegated to the Site Manager and include:

a)

Introductory training in'he description of the SGR gA Program, use of instructions and procedures, personnel requirements for procedural compliance and the items controlled by the SGRP gA Program.

b)

Personnel who perform inspection and examination functions are certified in accordance with requirements of the applicable revisions of Regulatory Guide 1.58, ANSI N45.2.6, the ASME 88PV Code, or SNT-TC-1A.

c)

Audit personnel are certified in accordance with the applicable revisions of Regulatory Guide 1.146 and ANSI N45.2.23.

d)

SGRP personnel assigned duties such as special cleaning processes, welding, etc.,

are qualified in accordance with applicable

codes, standards, regulatory guides and/or procedures. July, 1988

e)

The SGRP training, qualification and certification program includes, as applicable, provisions for retraining, reexamination and recertification to ensure that proficiency is maintained.

f)

SGRP training, qualification, and certification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the personnel involved are performing activities to which the training, qualification and certification is relevant.

g)

SGRP personnel responsible for performing activities that affect safety-related items are instructed as to the purpose, scope and implementation of the SGR gA Program, applicable

manuals, instruc-tions and procedures.

SGRP management/supervisory personnel receive functional training to the level necessary to plan, coordinate and administer the day-to-day verification activities of the SGR

(}A Program for which they are responsible.

Where personnel qualifications or certifications (including requalification or recertification) are required, the activities are performed on a scheduled basis consistent with the applicable code or standard.

SGRP personnel receive training prior to being granted unescorted access to the plant.

This training includes management's policy for implementa-tion of the SGR gA Program, a description of the SGR gA Program, the use of instructions and procedures, and personnel requirements for procedure compliance.

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July, 1988

SECTION 3 DESIGN CONTROL 3.1 SCOPE Work associated with the SGRP is accomplished in accordance with approved design control mechanisms.

Activities to develop design changes are controlled.

0 3.2 IMPLEMENTATION 3.2.1 Design changes associated with the SGRP are controlled by instructions and procedures.

SGRP associated design changes are reviewed as required by 10CFR50.59.

3.2.2 Checks are performed and documented to verify the dimensional accuracy and completeness of design drawings and specifications.

3.2.3 Site implementation of the Request for Change (RFC) is accomplished by the SGRP management organization and the Repair Contractor by means of work packages.

Materials components and equipment used to perform the work must meet the specifications established for the original system, or properly reviewed and approved revisions thereof.

The testing documenta-tion is reviewed where testing after completion is required, by the organization performing the test and, when specified, by the AEPSC lead engineer or cognizant engineer.

further, completed work packages are reviewed by AEPSC SGR gA following installation and testing. July, 1988

3.2.4 Changes to design documents, including field changes, are reviewed, approved and controlled in a manner commensurate with that used for the original design.

Information on approved changes is transmitted to all affected organizations.

3.2.5 Error and deficiencies in, and deviations from approved design documents are identified and dispositioned in accordance with established design control and/or corrective action procedures.

SECTION 4 PROCUREMENT DOCUMENT CONTROL 4.1 SCOPE I

SGRP procurement documents define the characteristics of item(s) and/or se1vices to be procured, identify applicable regulatory and industry codes/standards requirements and specify SGRP supplier quality assurance program requirements to the extent necessary to assure quality.

4.2 IMPLEMENTATION 4.2.1 SGRP procurement control is established by instructions and procedures.

These documents require that purchase documents be sufficiently detailed to ensure that purchased materials, components and services associated with safety-related structures or systems are:

I) purchased to specification and code requirements equivalent to those of the original equipment or service (except when the Code of Federal Regulations requires upgrading) or properly reviewed and approved revisions thereof, July, 1988

2) properly documented to show compliance with the applicable specifica-

tions, codes. and standards, and 3) purchased from vendors or contractors who have been evaluated and deemed qualified as provided for in Section 7

herein.

4 9

SGRP procedures establish the review of procurement documents to determine that:

quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance criteria; procurement documents have been prepared, reviewed and approved in accordance with established SGRP requirements.

The SGRP management organization is responsible for assuring that the applicable gA requirements are set forth in the procurement documents.

The SGRP organization may request assistance of AEPSC cognizant engineers in any procurement activity.

,4.2.2 The Facility Data Base, in conjunction with other sources, is used to determine equipment safety classification.

AEPSC Specifications for the Cook Nuclear Plant (OCC Specifications) establish the item's technical, operational and documentation requirements, codes or standards that items must fulfill,and define the documentation that must accompany the items to the plant.

SGRP management cognizant of the.equipment and its quality assurance requirements review procurement documents to ensure that: correct classification is made; the appropriate AEPSC Specifications for the Cook Nuclear Plant are referenced or are attached; and that the documentation requirements are properly stated. July, 1988

4.2.3 The contents of procurement documents vary according to the item(s) being purchased and its function(s) in the plant.

Provisions of the SGR gA Program are also considered for application to service contractors.

As applicable, procurement documents include:

a)

Scope of work to be performed.

b}

Technical requirements, with applicable drawings, specifications, codes and standards identified by title, document number, revision and date, with any required procedures such as special process instructions identified in such a way as to indicate source and need.

c)

Regulatory, administrative and reporting requirements.

P d}

guality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections.

e)

A requirement for a documented gA Program, subject to gA review and written concurrence prior to the start of work.

f)

A requirement for the supplier to invoke applicable quality require-ments on subtier suppliers.

g)

Provisions for access to supplier and subtier suppliers'acilities and records for inspections, surveillances and audits.

h)

Identification of documentation to be provided by the supplier, the schedule of submittals and documents requiring AEPSC approval. July, 1988

4.2.4 AEPSC gA performs off-line reviews of safety-related procurement docu-ments to assure that applicable gA Program requirements have been implemented.

These reviews are conducted in accordance with AEPSC gA Department and/or SGR Project Procedures.

':4.2.5 Changes to SGRP procurement documents are controlled in a manner commensurate with that used for the original documents.

SECTION 5

INSTRUCTIONS, PROCEDURES, AND DRAWINGS 5.1 SCOPE SGRP activities affecting the quality of safety-related structures, systems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances,.including acceptance criteria for determining if an activity has been satisfactorily completed.

4b 5.2 IMPl EMENTATION 5'.2. 1 SGRP instructions and procedures incorporate:

1) a description of the activity to be accomplished, and 2) appropriate quantitative (such as tolerances and operating limits) and qualitative (such as workmanship and standards) acceptance criteria sufficient to determine that the activity has been satisfactorily accomplished.

Hold points for inspection/

verification are established when required. July, 1988

Instructions and procedures pertaining to the specification of and/or implementation of the SGR gA Program receive multiple reviews for technical adequacy and inclusion of appropriate quality requirements.

SGR Project Procedures and Repair Contractor procedures are reviewed and/or approved by AEPSC gA.

Lower tier documents are reviewed and

approved, as a minimum by management/supervisory personnel trained to the level necessary to plan, coordinate and administer those day-to-day verification activities of the SGR gA Program for which they are responsible.

5.2.2 AEPSC/IN activities relative to the SGRP are outlined by procedures which provide the controls for the implementation of these activities.

The SGRP management organization (on-site) utilizes Project Procedures for SGR QA Program implementation.

5.2.4

~

~

Drawings required for the SGRP are produced, controlled and distributed in accordance with approved procedures.

AEPSC design drawings are produced by the AEPSC Design Division under procedures which direct their development and review.

These procedures specify requirements for inclusion of quantitative and qualitative acceptance criteria.

SGRP drawings are reviewed and approved by the cognizant AEPSC engineering organization.

SECTION 6 DOCUMENT CONTROL 6.1 SCOPE Documents controlling SGRP activities within the scope defined in Section 2 herein are issued and changed according to'stablished procedures.

Documents such as instructions, procedures and drawings, including 23~

July, 1988

changes

thereto, are reviewed for adequacy, approved for release by authorized personnel and are distributed and used at the location where a

prescribed activity is performed.

Changes to controlled documents are reviewed and approved by the same organizations that performed the original review and approval, or by other qualified, responsible organizations specifically designated in accordance with the procedures governing these documents.

Obsolete or superseded documents are controlled to prevent inadvertent use.

6.2 IMPLEMENTATION 6.2.1 The review, approval, issuance and change of documents are controlled by:

a)

Establishment of criteria to ensure that adequate technical and quality requirements are incorporated.

b)

Identification of the organization responsible for review, approval, issue and maintenance.

c)

Review of changes to documents by the organization that performed the initial review and approval, or by the organization designated in accordance with the procedure governing the review and approval of specific types of documents.

SGRP procedures and instructions are reviewed and/or approved by AEPSC gA for compliance with established project requirements.

6.2.2 Documents required for the SGRP are issued and controlled so that: July, 1988

a)

The documents are available prior to commencing work.

b)

Obsolete documents are replaced by current documents in a timely manner.

6.2.3 Master lists or equivalent controls are used to identify the current revision of instructions, procedures, specifications and drawings.

These control documents are updated and distributed to designated personnel who are responsible for maintaining current copies of the applicable documents.

The distribution of controlled documents is performed under procedures requiring receipt acknowledgement and in accordance with established distribution lists.

6.2.4 In the event a marked-up drawing is required to reflect an as-built configuration, the mark-up is prepared by the Repair Contractor and the original drawings are revised by the AEPSC Design Division to incorporate the as-built configuration.

Revised drawings are reviewed and approved by the cognizant AEPSC'engineering organization.

6.2.5 Documents prepared for use in training or for interested parties are appropriately marked to indicate that they are for information only, and cannot be used to operate or maintain the facility, or to conduct SGRP activities affecting the quality of safety-related items.

Unless a

document is identified as "controlled" it is to be automatically assumed the document is for information only. July, 1988

SECTION 7

CONTROL OF PURCHASEO ITEMS AND SERVICES

7. I SCOPE Activities that implement approved SGRP procurement requests for items and services are controlled to assure conformance with procurement document requirements.

Controls include:

a system of supplier evaluation and selection; source inspection, surveillance and audit; acceptance of items and documentation upon delivery; and per iodic assessment of supplier performance.

Objective evidence that demonstrates conformance with specified SGRP procurement document requirements is available to the Cook Nuclear Plant site prior to use of items or services, 3

,7. 2 IMPLEMENTATION 7.2.1 SGRP suppliers are qualified by performing a, documented evaluation of their capability to provide items or services required.

Items and services designated as safety-related are purchased from suppliers whose QA programs have been reviewed and accepted in accordance with established requirements.

AEPSC is a member of CASE and performs audits for submittal to the CASE Register as well as the Qualified Supplier List (QSL).

The CASE Register provides a pre-screened list of potential suppliers with acceptable QA programs.

An evaluation is made if there is an interest in a CASE listed supplier to consider the scope of the qualification audit and the identity of the sponsoring licensee which are stated in 'the Register.

Additional program surveys will be conducted, as necessary, to meet requirements.

Acceptance is not complete until it has been determined that the supplier has an acceptable QA program and can fulfill the technical requirements of the item or service that is being procured. July, 1988

7.2.2 For items that are not unique to a nuclear power plant ("Commercial Grade" ) where requirements cannot be imposed in a practical manner at time of procurement, programs for dedication and upgrading to safety-related standards are established and accomplished by the AEPSC cognizant engineer prior to the item being accepted for safety-related use.

7.2.3 In-process surveillance of suppliers'ctivities during fabrication, inspection, testing and shipment of items is performed when deemed necessary, depending upon supplier qualification status, complexity and importance to safety of the item being furnished, and/or previous supplier history.

This surveillance is performed by the cognizant engineering department, responsible plant department, SGRP Repair Contractor, or AEPSC gA, or any combination thereof.

Spare and replacement parts are procured in such a manner that their performance and quality are at least equivalent to those of the parts that will be replaced.

a)

Specifications and codes referenced in procurement documents.for spare or replacement items are at least equivalent to those for the original items or to properly reviewed and approved revisions.

b)

Parts intended as spares or replacement for "off-the-shelf" items, or other items for which quality requirements were not originally specified, are evaluated for performance at least equivalent to the original.

27>>

July, 1988

c)

Where quality requirements for the original items cannot be deter-mined, requirements and controls are established by engineering evaluation performed by qualified individuals.

The evaluation assures there is no adverse effect on interfaces, interchangeability, safety, fit, form, function, or compliance with applicable regulatory or code requirements.

Evaluation results are documented.

d)

Any additional or modified design criteria, imposed after previous procurement of the item(s), are identified and incorporated.

7.2.5 SGRP procedures for receipt inspection of safety-related items address the program for inspection of incoming items including a review of the documentation required under the procurement.

Receipt inspection personnel are qualified and certified in accordance with the requirements of ANSI N45.2.6.

7Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..2.6 Items received at the site for the SGRP are tagged or identified and placed in a designated, controlled area until receipt inspected.

During receipt inspection, designated material characteristics and attributes are checked, and documentation is checked against the procurement documents.

If found acceptable the item is released and placed in a designated storage area.

Item traceability to procurement documents and to end use is maintained through applicable documents.

Nonconforming items, or missing or questionable documentation results in items being placed on "hold" and identified to control further processing.

If the nonconformance cannot be cleared, the item is either

scrapped, returned to the supplier, or dispositioned through engineering analysis. July, 1988

7,2.7

~

~

SGRP suppliers are required to furnish the following records:

a)

Applicable drawings and related engineering documentation that identify the purchased item and the specific procurement require-ments (e.g.,

codes, standards and specifications) met by the item.

b)

Documentation identifying any procurement requirements that have not been met.

c)

A description of those nonconformances from the procurement require-ments dispositioned "use-as-is" or "repair".

d) guali ty records as specified in the procurement requirements.

SECTION 8 IDENTIFICATION AND CONTROL OF ITEMS 8.1 SCOPE Items required for the SGRP are identified and controlled to prevent their inadvertent use.

Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items.

8.2 IMPLEMENTATION 8.2.1 Controls are established that provide for the identification and control of items. July, 1988

8.2.2 Items are identified by physically marking the item or its container, and by maintaining records traceable to the item.

The method of identi-fication is such that the quality of the item is not degraded.

3 8.2.3 Items are traceable to applicable drawings, specifications or other pertinent documents to ensure that only correct and acceptable items are used.

Verification of traceabi lity is performed and documented prior to release for fabrication, assembly, or installation.

8.2.4 Requirements for the identification by use of heat number, part number, or serial number are included in the specifications and/or purchase order.

8.2.5 Incorrect or defective items are controlled to prevent their inadvertent use and/or integration with items which have been accepted for use.

All safety-related items are appropriately tagged or 'identified (stamped, marked, etc.) to provide easy identification as to the items'sage status.

Records are maintained for the issue of items, to provide traceabi lity from storage to end use in the plant.

8";2.6 When materials are subdivided, appropriate identification numbers are transferred to each section of the material, or traceability is main-tained through documentation. July, 1988

SECTION 9 CONTROL OF SPECIAL PROCESSES 9.1 SCOPE Special processes utilized for the SGRP are controlled and are accomplished by qualified personnel using approved procedures and equipment in accordance with applicable

codes, standards, specifications, criteria and other special requirements.

9.2 IMPLEMENTATION 9.2.1 SGRP processes subject to special process controls are those for which full verification or characterization by direct inspection is impossible or impractical.

Such processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement and nondestructive examination.

Special process requirements for Repair Contractor procedures used to perform chemical cleaning, application of protective coat'ings and concrete placement are set forth in AEPSC Specifications (OCCs) and/or directives prepared by the responsible AEPSC cognizant engineer.

These documents are reviewed and approved, as applicable, by AEPSC gA, and management with the necessary technical competence.

Special process requirements for welding, heat treating 'and nondestruc-tive examination (NDE) are established in Repair Contractor procedures.

These procedures are reviewed and approved by the SGRP management organization, and the AEPSC Staff Engineer - Chief Metallurgist (NOE Administrator) via the SGR Engineering Manager. July, 1988

Repair Contractor welding is performed in accordance with procedures which comply with the requirements of applicable codes and standards, and Procedure gualification Records are prepared.

The Meld Procedure gualification Record is reviewed and approved by the AEPSC Staff Engineer

- Chief Metallurgist via the SGR Engineering Manager.

Weld qualification documentation is retained by the Repair Contractor.

3 Welding procedures are qualified by the Repair Contractor.

These procedures and the qualification documentation are reviewed and approved by the SGRP management organization, and the AEPSC Staff Engineer - Chief Metallurgist via the SGR Engineering Manager.

This documentation is retained by the Repair Contractor.

9.2.3 Repair Contractor nondestructive examination personnel are qualified and certified in accordance with the requirements of the contractor's gA Program.

Personnel qualification is kept current by performance of the special process(es) and/or reexamination at specified intervals.

Unsat-t isfactory performance or, where applicable, failure to perform within the designated intervals, requires recertification..

Craft welders are qualified by the Repair Contractor utilizing procedures approved by the SGRP management organization and the AEPSC Staff Engineer

- Chief Metallurgist.

Craft welder qualification records are maintained by the Repair Contractor.

9.2.4 Repair Contractor nondestructive examination personnel are qualified to SNT-TC-1A and records of their qualifications/certifications are maintained at the plant by the Repair Contractor. July, 1988

9.2.5 Special process qualifications are reviewed during AEPSC gA audits and surveillances.

gualification records are maintained by the Repair Contractor.

9.2.6 The documentation resulting from SGRP welding and nondestructive examination is reviewed by appropriate SGRP management organization personnel.

SECTION 10 INSPECTION 10.1 SCOPE SGRP activities affecting the quality of safety-related items are inspected to verify their conformance with requirements.

These inspections are performed by personnel other than those who perform the activity.

Inspections are performed by qualified personnel utilizing written procedures which establish prerequisites and provide documentation for evaluating test and inspection. results.

Direct inspec-tion, process monitoring, or both, are used as necessary.

When applicable, hold points are used to ensure that inspections are accom-plished at the correct points in the sequence of activities.

10. 2 IMPLEMENTATION 10.2.1 Inspections are applied to appropriate activities, such as receiving, civil, structural, mechanical, electrical, etc., to assure conformance to specified SGRP requirements.

w33w

July, 1988

Hold points are provided in the sequence of procedures or work packages to allow for the inspection, witnessing, examination, measurement, or review necessary to assure that the critical or irreversible elements of an activity are being performed as required.

When included in the sequence of a procedure or work package, the activities required by hold points are completed prior to continuing work beyond that point.

10.2.2 Training, qualification and certification programs for Repair Contractor personnel who perform inspections are established, implemented and documented in accordance with 7.2.5 and 10.2.4 herein.

10.2.3

?

Inspection requirements are specified in procedures, instructions, drawings, or checklists as applicable.

They provide for the following as appropriate:

a)

Identification of applicable revisions of required instructions, drawings and specifications.

b)

Identification of characteristics and activities to be inspected.

c)

Inspection methods.

d)

Specification of measuring and test equipment having the necessary accuracy.

e)

Identification of personnel responsible for performing the inspection. July, 1988

f)

Acceptance and rejection criteria.

g)

Recording of the inspection results and the identification of the inspector.

10.2.4 Work activities performed on safety-related items are inspected by Repair Contractor inspection personnel qualified and certified in accordance with the applicable revisions of Regulatory Guide 1.58 and ANSI N45.2.6.

10Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>10" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..2.5 Inspections are performed, documented, and the results evaluated by designated personnel in order to ensure that the results substantiate the acceptability of the item or work.

Evaluation and review results are documented.

SECTION 11 TEST CONTROL 11.1 SCOPE Testing is performed in accordance with SGRP requirements to demonstrate that structures, systems and components will perform satisfactorily when returned to service.

The testing is performed by qualified personnel in accordance with written procedures that incorporate specified require-ments and acceptance criteria.

Test parameters, prerequisites, instrumentation requirements and environmental conditions, are specified in test procedures.

Test results are documented and evaluated. July, 1988

11. 2 IMPLEMENTATION 11.2.1 Tests are performed in accordance with SGR Project or plant procedures and criteria that designate when tests are required.

)

'11.2.2 As required, hold points for witness, or review of tests are provided.

11.2.3 Testing is accomplished after installation, or repair, by test procedures or performance tests which must be satisfactorily 'completed prior to determining the equipment is in an operable status.

All data resulting from these tests is retained at the plant after review by appropriate personnel.

SECTION 12 CONTROL OF MEASURING ANO TEST E UIPMENT 12.1 SCOPE Measuring and testing equipment used in SGRP activities affecting the quality of safety-related

systems, components and structures are properly identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within specified limits.

1'2.2 IMPLEMENTATION 12.2.1

)V The SGRP has established procedures for calibration and control of measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components.

These procedures establish calibration techniques and frequencies, and maintenance and control of the equipment.

O. July, 1988

The effectiveness of the calibration program is periodically assessed through audits and surveillances.

12.2.2 Measuring and test equipment is uniquely identified and is traceable to its calibration source.

12.2.3 A system has been established for attaching or affixing labels to measuring and test equipment to display the date calibrated and the next calibration due date or a control system is used that identifies to potential users any equipment beyond the calibration due date.

12.2.4 Measuring and test equipment is calibrated at specified intervals.

These intervals are based on the frequency of use, stability characteristics and other conditions that could adversely affect the required measurement accuracy.

Calibration standards are traceable to nationally recognized standards, or where such standards do not exist provisions are established to document the basis for calibration.

The primary standards used to calibrate secondary standards

have, except in certain instances, an accuracy of at least four (4) times the required accuracy of the secondary standard.

In those cases where the four (4) times accuracy cannot be achieved, the basis for acceptance is documented.

The secondary standards have an accuracy that assures equipment being calibrated will be within required tolerances.

The basis for acceptance is documented.

&37'uly, 1988

12.2.5 SGRP procedures define the requirements for the control of standards, test equipment and process equipment.

0 12.2.6 When measuring and testing equipment used for inspection and testing is found to be outside of required accuracy limits at the time of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration.

Retests or reinspections are performed on suspect items.

The results of evaluations are documented.

SECTION 13 HANOLING STORAGE ANO SHIPPING

13. 1 SCOPE Activities associated with SGRP activities with the potential for causing contamination or deterioration, by environmental conditions such as temperature or humidity that could adversely affect the ability of an item to perform its safety-related functions and activities necessary to prevent damage or loss are identified and controlled.

These activities are cleaning, packaging, preserving, handling, shipping and storing.

Controls are effected through the use of appropriate procedures and instructions.

13.2 IMPLEMENTATION 13.2.1 SGRP procedures are used to control the cleaning, handling, storing, packaging, preserving and shipping of materials, components and systems in accordance with designated procurement requirements.

These procedures include, but are not limited to, the following functions: July, 1988

a)

Cleaning - to assure that required cleanliness levels are achieved and maintained.

b)

Packaging and preservation

- to provide adequate protection against damage or deterioration.

When necessary, these procedures provide for special environments such as inert gas atmosphere, specific moisture content levels and temperature levels.

c)

Handling - to preclude damage or safety hazards.

d)

Storing - to minimize the possibility of loss,

damage, or deterio-ration of items in storage, including consumables such as chemicals, coatings and lubricants.

]3.2.2 Controls have been established in SGRP procedures for limited shelf life items such as "0" rings, epoxy, lubricants, solvents and chemicals to assure they are correctly identified, stored and controlled to prevent

~shelf life expired materials from being used.

]3.2.3 Packaging and shipping requirements are provided to suppliers in AEPSC Specifications (DCCs) which are a part of the procurement document.

Controls for receipt inspection, damaged items and special handling requirements at the project site are established by SGRP procedures.

Special controls are provided to assure that stainless steel components and materials are handled with approved lifting devices.

]3.2.4 Storage and surveillance requirements have been established to assure segregation of storage.

Special controls have been implemented for critical, high value, or perishable items.

Routine surveillance is July, ]988

conducted on stored material to provide inspection for damage, rotation of stored pumps and motors, inspection for protection of exposed surfaces and cleanliness of the storage area.

SECTION 14 INSPECTION

TEST, AND OPERATING STATUS 14.1 SCOPE Operating status of structures, systems and components affected by the SGRP is indicated by tagging of valves and switches, or by other specified

means, in such a manner as to prevent inadvertent operation.

The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.

14.2 IMPLEMENTATION

'14.2.1 Eg For SGRP design change (RFC) activities, including item fabrication, installation and test, a program exists which specifies the degree of control required for the identification of inspection and test status of structures, systems and components.

14.2.2 Plant system operability status is maintained through the plant's Clearance Permit System.

Another plant program establishes a tagging system for lifted leads, etc.

14.2.3 Physical identification is used to the extent practical to indicate the status of items requiring inspections,

tests, or examinations.

Proce-dures provide for the use of calibration and rejection stickers, tags, July, 1988

stamps and other forms of identification to indicate test and inspection status.

For those items requiring calibration, the program shall provide for physical indication of calibration status by calibration stickers or a control system is used.

14.2.4 Application and removal of inspection and welding stamps, and of such status indicators as

stamps, tags, marking, labels, routing cards, physical barriers, etc., is controlled by SGRP and/or plant procedures.

The inspection status of materials received at the project site is identified in accordance with established instructions and the status is identified.

The inspection status of work in progress is controlled by the use of hold points in procedures

'or work packages.

Repair Contractor personnel inspect activities at various stages and sign off the procedural steps covered by the inspection.

The status of welding is controlled through the use of documentation which identify the inspection and nondestructive examination status of each weld.

14.2.5

Testing, inspection and other operations important to safety are conducted in accordance with properly reviewed and approved procedures or work packages.

Alteration to the sequence of a procedure or work package can only be accomplished by a change which is subject to the same controls as the original review and approval. July, 1988

14.2.6 Nonconforming, inoperable, or malfunctioning structures, systems and components are clearly identified by tags, stickers, stamps, etc.,

and documented to prevent inadvertent use.

SECTION 15 NONCONFORMING ITEMS

15. 1 SCOPE Materials, parts, or components that do not conform to SGRP requirements are controlled in order to prevent their inadvertent use.

Nonconforming'tems are identified, documented, segregated when practical and disposi-tioned.

Affected organizations are notified of:.nonconformances.

15.2 IMPLEMENTATION 15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure; which render the quality unacceptable or indeterminate, are identified as nonconforming, and any further use.is controlled.

Nonconformances are documented and dispositioned, and notification is made to affected organizations.

Authorized personnel disposition, conditionally release and close out nonconformances.

Repair Contractor Nonconformance Reports (NCRs) and SGRP guality Action Requests (gARs) are used to identify nonconforming items. and initiate corrective action.

Systems, components, or materials which require repair or inspection are controlled.

In addition, the various controls identified in Section 14 herein provide for identification, segregation and documentation of nonconforming items. July, 1988

15.2.2 Nonconforming items are identified by marking, tagging, segregating, or by documented administrative controls.

Documentation describes the nonconformance, the disposition of the nonconformance and the inspection requirements.

It also includes signature approval of the disposition.

Nonconformance dispositions are reviewed and approved in accordance with SGRP procedures.

AEPSC gA periodically performs audits and survei llances of the nonconformance program.

15.2.3 Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alterna-tives that have been documented.

Items that have the disposition of "repair" or "use-as-is" require documentation justifying acceptability.

The changes are recorded to denote the as-built condition.

When required by established procedures, tests are conducted on an item after rework, repair or replacement.

15.2.4 Disposition of conditionally released items are closed out before the items are relied upon to perform safety-related functions.

SECTION 16 CORRECTIVE ACTION 16.1 SCOPE Conditions associated with the SGRP which are adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances, are identified promptly and corrected. July, 1988

For significant conditions adverse to quality, the cause of the condition is determined, corrective action is taken to correct the immediate

problem, and preventive action is implemented to prevent recurrence.

In these

cases, the condition, cause and corrective action taken is docu-mented and reported to appropriate SGRP management.

t 16.2 IMPLEMENTATION 16.2.1 Procedures are established that describe the SGRP corrective action programs. 'hese procedures are reviewed and concurred with by AEPSC qA.

16.2.2 Corrective action programs provide the mechanism for SGRP personnel to notify SGRP and plant management, as applicable, of conditions adverse to quality.

Investigations of reported conditions adverse to quality are assigned by SGRP management.

The investigation is used to identify the need for changes to instructions or procedures, the initiation of a design change to correct system or equipment deficiencies, or the initi-ation of job orders to correct minor deficiencies.'orrective Actions identify those actions necessary to prevent recurrence of the reported condition.

Corrective Actions are also used to report violations to

codes, regulations and the Technical Specifications.

Corrective Actions are reviewed by SGRP management for evaluation of actions taken to correct the deficiency and prevent recurrence.

NCRs and gARs provide the mechanism for SGRP personnel to identify noncompliances.

Investigation of reported conditions are assigned to the responsible individual.

NCR and JAR investigation requires the determination of the cause of the condition and identification of immediate action and action taken to prevent recurrence.

44-

July, 1988

The AEPSC gA Department periodically audits the corrective action systems for compliance and effectiveness.

SECTION 17

(}UALITYASSURANCE RECORDS 17.1 SCOPE Records that furnish evidence of SGRP activities affecting the quality of safety-related structures, systems and components are maintained.

They are accurate, complete, legible and are protected against damage, deteri-oration, or loss.

They are identifiable and retrievable.

17.2 IMPLEMENTATION 17.2.1 Documents that furnish evidence of SGRP activities affecting the quality of safety-related items are generated and controlled in accordance with the procedure that governs those activities.

Upon completion, these documents are considered records.

These records include but are not limited to:

a)

Results of reviews, inspections, surveillances,

tests, audits and material analyses.

b) gualification of personnel, procedures and equipment.

c)

SGRP procedures and related inspection results.

d)

Records required by the plant Technical Specifications.

e)

Repair Contractor Nonconformance Reports.

f) guality Action Requests.

g)

Other documentation such as drawings, specifications, procurement documents, calibration procedures and reports.

h)

Radiographs of safety-related items (which are also classified as safety-related items).

45

July, 1988

17.2.2 Instructions and procedures shall establish the requirements for the identification and preparation of records for systems and equipment under the gA Program, and provides the controls for retention of these records.

Methods shall be established to provide direction for filing and to provide for the retrievability of the records.

R 17.2.3 Procedures ensure the maintenance of records sufficient to furnish objective evidence that activities affecting quality are in compliance with the established gA Program.

'7.2.4 SGRP documents shall be stored in facilities which comply with the requirements of NUREG-0800 (reference gAPD, Appendix 8, item llc) until they are turned over to the plant for record retention.

When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file.

Nonpermanent records have specified retention times.

Permanent records are maintained for the life of the plant or equipment, as applicable.

'7.2.5 Only authorized personnel may issue corrections or supplements to records.

"SECTION 18'UDITS 18.1 SCOPE A comprehensive system of audits and surveillances of SGRP activities is carried out to provide independent evaluation o'f compliance with, and the effectiveness of the SGRP qA Program, including those elements of the July, 1988

program implemented by the Repair Contractors.

Audits and surveillances are performed in accordance with written procedures and/or checklists by qualified personnel not having direct responsibility in the areas of the audit or surveillance

Audit and survei llances results are documented and are reviewed by management.

Follow-up action is taken where indicated.

18. 2 IMPLEMENTATION 18.2. I AEPSC QA Department Responsibilities The basic responsibility for the assessment of the effectiveness of the SGR QA Program is vested in the AEPSC QA Department.

The AEPSC Quality Assurance Department is primarily responsible for ensuring that proper QA programs are established and, for verification of their implementation.

These responsibilities are discharged in cooperation with the SGRP management organizations, and their staffs.

18.2.2 SGRP audits are performed in accordance with established schedules that reflect the status and importance of safety to the activities being performed.

All project areas where the requirements of 10CFR50, Appendix 8 apply are audited by the AEPSC QA Audits and Procurement, and Site QA Sections.

SGRP survei llances are performed by the SGR QA Section.

Surveillances wi 11 encompass attributes such as:

SGR QA Program activities; site features which are unique to the SGRP; review of early site procurements; indoctrination and training program; interface controls; activities associated with computer codes; security; and radiological safety.

18.2.3 The AEPSC Quality Assurance Department conducts audits and surveillances to verify the adequacy and implementation of the SGR QA Program.

AEPSC July, 1988

gA audit reports for the SGRP are distributed io the NSDRC, Project Manager and Site Project Manager.

Surveillance reports are distributed to affected SGRP organizations and others as deemed necessary.

18.2.4 The AEPSC independent review and audit organization, the Nuclear Safety and Design Review Committee (NSDRC), conducts periodic audits of SGRP activities pursuant to the established criteria of the SGR gA Program.

NSORC audit reports are submitted for review to the Chairman of the NSORC and to the AEPSC Senior Executive Vice President - Engineering and Construction.

18.2.5 Audits and surveillances of SGRP suppliers and the Repair Contractor are scheduled based on the status of safety importance of the activities being performed, and are initiated early enough to assure effective quality assurance during design, procurement, manufacturing, installation, inspection and testing.

The Repair Contractor is required to audit its suppliers in accordance with the criteria established within its quality assurance program.

38.2.5 Regularly scheduled audits are supplemented by "special audits" when significant changes are made in the SGR gA Program, when it is suspected that quality is in jeopardy, or when an independent assessment of program effectiveness is considered necessary. July, 1988

18.2.6 Audits and surveillances include an objective evaluation of practices, procedures, instructions, activities and items related to quality; and review of documents and records to confirm that the SGR gA Program is effective and properly implemented.

18.2.7 Audit procedures and the scope, plans, checklists and results of indivi-dual audits are documented.

Surveillances of SGRP activities are performed in accordance with approved SGRP procedures.

18.2.8 Personnel selected for auditing and surveillance assignments have experience or are given training commensurate with the needs. of the audit and have no direct responsibilities in the areas audited.

18.2.9 Management of the audited or surveillanced organization is identified and is required to take appropriate action to correct observed deficiencies and includes the prevention of recurrence.

Follow-up is performed by the auditing or surveillance organization to ensure that the appropriate actions were taken.

Such follow-up includes reaudits when necessary.

18.2.10 The adequacy of the SGR gA Program is regularly assessed by AEPSC management.

The following activities constitute formal elements of that assessment: July, 1988

a)

Audit and surveillance reports, including follow-up on corrective action accomplishment and effectiveness, are distributed to appropriate levels of management.

0 b)

Individuals independent from the AEPSC equality Assurance organization, but knowledgeable in auditing, surveillances and quality assurance, periodically review the effectiveness of the SGR gA Program. July, 1988

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'GR ENGINEERING MANAGER PROJECT MANAGER AEPSC (COLUMBUS) ooK NU LEAR PLANT ADUWSTIIATIVEAHD FUNCTIOHAL DIRECTIOII TECIIIIICALUAISOH TCCHNICAL SUPPORT FUNCTIOHAL SUPPORt FUNCTIONAL OIRfCTIOH SITE PROJECT MANAGER SGR QUALITY ASSURANCE SUPERVISOR

AEPSC DIRECTOR OUAUlY ASSURANCE AEPSC (COLUMBUS)

COOK NUCLEAR PLANT jgxgQ$gX'AQXX>vox~YA>+X'g~tY X~xQ SOR OUALITYASSURANCE SUPERVISOR RUAI.ITY ASSURANCE ENGINEER(S)

QUAUTY ASSURANCE

.AUDITOR(S)

APPENDIX 8 (SGRP)

ADDITIONAL AEPSC/18M EXCEPTIONS/CLARIFICATIONS TO STANDARDS AND REGULATORY GUIDES FOR THE SGR PROJECT 0

7c.

Table 8 Required In-process Tests "Material Grout Water 5 Ice Re uirement Compressive Strength Compliance with AASHO T26 for effect on:

Compressive str'ength Setting Time Soundness T

h d

ASTM C109 Daily during production.

ASTM C109 Every six (6) months ASTM C191 Every six (6) months ASTM C151 Every six (6) months Aggregate

=

Compliance with requirements for:

Soft fragments ASTM C235 Monthly during production.

Exce tion/Inter retation Daily compressive strength field tests are inappropriate as such testing is a

sophisticated laboratory test utilized for cement ev'aluation.

In lieu of daily tests, pre-packaged non-shrink grouts shall be accepted for use on the basis of manufacturer's certification or compressive strength tests made in the field.

Configuration compressive strength tests shall be made during the first day's production and thereafter on a basis of either once per day or every one-hundred

( 100) bags

used, whichever is least.

Water and ice shall be sampled and tested to ensure either potability or certified to contain not more than 2,000 parts per million of chlorides as Cl, nor more than 1,500 parts per million of sulfates as SO Acceptability of this water or ice shall be per this certification and preclude the ASTMs referenced.

No testing of soft fragments is intended.

Testing per ASTM C235 changed designations to ASTM C851 which was deleted in 1985.

7d.

Section 4.9.3

~R "Tensile Testing Splice samples may be production splices (i.e., those cut directly from in-place reinforcing) or sister splices (i.e., those removable splices made in-place next to production splices and under the same conditions)." July, 1988

Exce tion/Inter retation APPENDIX B (SGRP)

The cadweld inspection and t'esting program which will be implemented during the restoration of the steam generator doghouse enclosures, will be based on ANSI N45.2.5 - 1974, except that sister splices will be substituted for production splice test samples.

This substitution is necessary to account for geometric constraints associated with replacing production splices taken for tensile testing.

A detailed description of the inspection and testing program is contained in Supplement 3 to the "Donald C.

Cook Nuclear Plant Unit No.

2 Steam Generator Repair Report". July, 1988

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