ML17329A470

Updated QA Program Description for Cook Nuclear Plant

ML17329A470
Person / Time
Site:	Cook
Issue date:	04/21/1992
From:	Will Smith AMERICAN ELECTRIC POWER CO., INC.
To:
Shared Package
ML17329A469	List: ML17329A468 ML17329A470
References
NUDOCS 9204270449
Download: ML17329A470 (181)

Text

DONALD C.

COOK NUCLEAR PLANT COOK NUCLEAR PLANT UNIT NUMBERS 1 AND 2 DOCKET NOS. 50-135 AND 50-316 LICENSE NOS.

DPR-58 AND DPR-74 UPDATED EQUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE COOK NUCLEAR PLANT JULY,:I992 Concurred by:

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AEPSC Vice Presi t Nuclear Operations Approved by :

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Section 1.7 EQUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE COOK NUCLEAR PLANT TABLE OF CONTENTS Table of Contents Titie Statement of Policy for the Donald C.

Cook Nuclear Plant guality Assurance Program

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1.7-1 1.7.1 1.7.2 1.7.3 1.7.4 1.7.5 1.7.6 1.7.7 1.7.8 1.7.9 1.7.10 1.7.11 1.7.12 1.7.13 1.7.14 1.7.15 1.7.16 1.7.17 1.7.18 1.7.19 Appendix A Appendix B

1.7-4 Organization guali ty Assurance Program Design Control Procurement Document Control

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Instructions, Procedures, and Drawings Document Control Control of Purchased Items and Services Identification and Control of Items Control of Special Processes Inspection Test Control Control of Neasuring and Test Equipment Handling, Storage and Shipping Inspection, Test and Operating Status Nonconforming Items Corrective Action guality Assurance Records Audits e

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Fire Protection gA Program

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Regulatory and Safety Guide/ANSI Standards AEPSC/IN Exceptions to Operating Phase Standards and Regulatory Guides

American Electric Power Service Corporation 1 Riverside Plaza Columbus, OH 43215 614 223 1000 Z

AMERICAN ELECTRIC POWER STATEHENT OF POLICY FOR THE DONALD C.

COOK NUCLEAR PLANT EQUALITY ASSURANCE PROGRAM POLICY American Electric Power Company Inc.,

recognizes the fundamental importance of controlling the

design, modification, and operation of Indiana Michigan Power Company's Donald C.

Cook Nuclear Plant (Cook Nuclear Plant) by implementing a planned and documented guality Assurance

Program, including guality

Control, that complies with applicable regulations,

codes, and standards.

The guality Assurance Program has been established to control activities affecting safety-related functions of structures,

systems, and components in the Cook Nuclear Plant.

The guality Assurance Program supports the goal of maintaining the safety and reliability of the Cook Nuclear Plant at the highest level through a systematic program designed to assure that safety-related items are conducted in compliance with the applicable regulations,

codes, standards, and established corporate policies and practices.

As Chai:rman',.if-;;:%i,:;:;:Bojrd and Chief Executive Officer of American Electric Power C'ompany, I'nc.,"I maintain the ultimate responsibility for the guality Assurance Program associated with the Cook Nuclear Plant.

I have delegated functional responsibility for the guality Assurance Program to the. American Electric Power Service Corporation (AEPSC) Senior Executive Vice President-Engineering and Construction.

He has, with my approval, delegated further responsibilities as outlined in this statement.

IMPLEMENTATION The AEPSC Director-guality Assurance, under the direction of the AEPSC Senior Executive Vice President-Engineering and Construction, has been assigned the overall responsibility for specifying the guality Assurance program requirements for the Cook Nuclear Plant and verifying their implementation.

The AEPSC Senior Executive Vice President-Engineering and Construction has given the AEPSC Director-guali ty Assurance authority to stop work on any activity affecting safety-related items that does not meet applicable administrative, technical, and/or regulatory Revised:

2/19/92 1.7-1

July, 1992

Statement of Policy for the Donald C.

Cook Nuclear Plant Quality Assurance Program Page 2

requirements.

The AEPSC Director-Quality Assurance does not have the authority to stop unit operations, but shall notify appropriate plant and/or corporate management of conditions not meeting the aforementioned criteria and recommend that unit operations be terminated.

The AEPSC Vice President-Nuclear Operations, under the direction of the AEPSC Senior Executive Vice President-Engineering and Construction, has been delegated responsibility for effectively implementing the Quality Assurance Program.

The AEPSC Vice President-Nuclear Operations is the Manager of Nuclear Operations.

All other AEPSC divisions and departments, except Quality Assurance, having a supporting role for the Cook Nuclear Plant are functionally responsible to the Manager of Nuclear Operations.

The Plant

Manager, under the direction of the AEPSC Vice President-Nuclear Operations, is delegated the responsibility for establishing the Cook Nuclear Plant Quality Control Program and implementing the Quality Assurance Program at the Cook Nuclear Plant.

The AEPSC Director-Quality Assurance is responsible for providing technical direction to the Plant Manager for matters relating to the Quality Assurance Program at the Cook Nuclear Plant.

The AEPSC Director-Quality Assurance is also responsible for maintaining a Quality Assurance Section at the Cook Nuclear Plant to perform required reviews, audits, and survei llances, and to provide technical liaison services to the Plant Manager.

The implementation of the Quality Assurance Program is described in the AEPSC General Procedures (GPs) and subtier department/division

. procedures, Plant Manager's Instructions (PHIs),

and subtier Department Head Instructions and Procedures, which in total document the requirements.for implementation of the Program.

Each AEPSC and Cook Nuclear Plant organization involved in activi ties affecting safety-related functions of structures,

systems, and components in the Cook Nuclear Plant has the responsibility to implement the applicable policies and requirements of the Quality Assurance Program.

This responsibility includes being familiar with, and complying with, the requirements of the applicable Quality Assurance Program requirements.

Revised:

2/19/92

July, 1992

Statement of Policy for the Donald C.

Cook Nuclear Plant equality Assurance Program Page 3

COMPLIANCE The AEPSC Director-equality Assurance shall monitor compliance with the establ i shed gual ity Assurance Program.

Audit programs shal l be established to ensure that AEPSC and Cook Nuclear Plant activities comply with established program requirements, identify deficiencies or noncompliances and obtain effective and timely corrective actions.

Employees engaged in activities affecting safety-related functions of structures,

systems, and components in the Cook Nuclear Plant who believe that the equality Assurance Program is not being complied with, or that a deficiency in quality exists, should notify their supervisor, the AEPSC Director-equality

'Assurance, and/or the Plant Manager.

If the notification does not in the employee's opinion receive prompt or appropriate attention, the employee should contact successively higher levels of management.

Employees reporting such conditions shall not be discriminated against by companies of the American Electric Power System.

Discrimination includes discharge or other actions relative to compensation, terms, conditions, or privileges of employment.

R. E. Disbrow Chairman of the Board and Chief Executive Officer American Electric Power Company, Inc.

Revised:

2/19/92 1.7-3

July, 1992

1.7.1 ORGANIZATION 1.7.1.1 SCOPE American Electric Power Service Corporation (AEPSC) is responsible for establishing and implementing the Quality Assurance (QA) Program for the operational phase of the Donald C.

Cook Nuclear Plant (Cook Nuclear Plant).

Although authority for.development and execution of various portions of the program may be delegated to others, such as contractors, agents or consultants, AEPSC retains overall responsibility.

AEPSC shall evaluate work delegated to such organizations.

Evaluations shall be based on the status of safety importance of the activity being performed and shall be initiated early enough to assure effective quality assurance during the performance of the delegated activity.

This section of the Quality Assurance Program Description (QAPD) identifies the AEPSC organizational responsibilities for activities affecting the quality of safety-related nuclear power plan it+jt~uNg,

systems, and components, and describes the authority and duties assigned to them.

It addresses responsibilities for both attaining quality objectives and for the functions of establishing the QA Program, and verifying that activities affecting the quality of safety-related items are performed effectively in accordance with QA Program requirements.

1.7. 1. 2 IMPLEMENTATION 1.7.1.2.1 Source of Authorit The,ChN,.rman,.':::,0f,:::the~Board and Chief Executive Officer of American Electric Power

Company, Inc.

(AEP) and AEPSC is responsible for safe operation of the Cook Nuclear Plant.

Authority and responsibility for effectively implementing the QA Program for plant modifications, operations and maintenance are delegated through the AEPSC Senior Executive Vice President Engineering and Construction, to the AEPSC Vice President Nuclear Operations (Manager of Nuclear Operations).

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1.7-4

July, 1992

4)

AEPSC organization managers responsible for Cook Nuclear Plant matters have a commitment to seek and identify problem areas and take corrective action to eliminate unsafe conditions, or to improve trends that will upgrade plant safety and reliability.

5)

The Manager of Nuclear Operations shall ensure that Cook Nuclear Plant personnel are not requested to perform inappropriate work or tasks by corporate personnel, and shall control assignments and requests that have the potential for diverting the attention of the Plant Hanager from the primary responsibility for safe and reliable plant operation.

6)

AEPSC orhgariiiati oij managers having Cook Nuclear Plant support responsibilities, as well as the Plant Nanager and plant organization

managers, shall be familiar with the policy statements from higher management concerning nuclear safety and operational priorities.

They shall be responsible for ensuring that activities under their direction are performed in accordance with these policies.

1.7. 1.2.2 Res onsibilit for Attainin ualit Ob'ectives in AEPSC Nuclear

~Oerati ons The AEp Chasrman io:,."fthgeo'4arand Chief Executive Officer has delegated the functional responsibility of the Ouality Assurance Program to the AEPSC Senior Executive Vice President Engineering and Construction.

The AEPSC Director guality Assurance, under the direction of the AEPSC Senior Executive Vice President Engineering and Construction, is responsible for specifying gA Program requirements and verifying their implementati on.

The AEPSC Vice President Nuclear Operations, under the direction of the AEPSC Senior Executive Vice President Engineering and 1.7-6

July, 1992

Construction, is responsible for effectively implementing 'the gA Program.

The Plant Manager, under the direction of the AEPSC Vice President Nuclear Operations, is responsible for establishing the Cook Nuclear Plant guality Control Program and implementing the gA Program at the Cook Nuclear Plant.

AEPSC has an independent off-site Nuclear Safety and Design Review Committee (NSDRC) which has been established pursuant to the requirements of the Technical Specifications for the Cook Nuclear Plant.

The function of the NSDRC is to oversee the engineering,

design, operation, and maintenance of the Cook Nuclear Plant by performing audits and independent reviews of activities which are specified in the

fa'ii:.1,:it V.;: Te'chnjceal:Siiec'i::fj cali'o'n's'.::,

The Cook Nuclear Plant on-site review group is the Indiana Michigan Power Company (I&M) Plant Nuclear Safety Revi ew Committee (PNSRC).

This committee has also been established pursuant to the requirements of the Cook Nuclear Plant Technical Specifications.

The function of the PNSRC is to review plant operations on a continuing basis and advise the Plant Manager on matters related to nuclear safety.

1.7. 1.2e3 Cor orate Or anization American Electric Power Com an

July, 1992 AEP, the parent holding company, wholly owns the common stock of all AEP System subsidiary (operating) companies.

The major operating companies and generation subsidiaries are shown in Figure 1,7-2.

The Chairmanio'f

the'.

"Board and Chief Executive Officer of AEP is the Chief Executive Officer of AEPSC and all operating companies.

The responsibility for the functional management of the major operating companies is vested in

1. 7-7

the President oF each operating company reporting to the AEPSC President and Chief Operating Officer who reports to the AEPSC Chairman of the t

Board.

American Electric Power Service Cor oration The responsibility for administrative and technical direction of the AEP System and its facilities is delegated to AEPSC.

AEPSC provides management and technological services to the various AEP System companies.

0 eratin Com anies The operating facilities of the AEP System are owned and operated by the respective operating companies.

The responsibility for executing the engineering, design, construction, specialized technical training, and certain operations'upervision is vested in AEPSC, while all, or part, of the administrative functional responsibility is assigned to the operating companies.

In the case of Cook Nuclear Plant, I&M general office staff (headquarters) provides public affairs, accounting, industrial safety direction and procurement support.

The Cook Nuclear Plant is owned and operated by I&M which is part of the AEP System.

1.7. 1.2.4 ualit Assurance Res onsibilit of AEPSC I)

AEPSC provides the technical direction for the Cook Nuclear Plant, and as such makes the final decisions pertinent to safety-related changes in plant design.

Further, AEPSC reviews Nuclear Regulatory Commission (NRC) letters, bulletins, notices, etc., for impact on plant design, and the need for design changes or modifications.

1.7-8

July, 1992

2)

AEPSC furnishes quality assurance, engineering,

design, construction, licensing, NRC correspondence, fuel management and radiological support activities.

3)

AEPSC provides additional service in matters such as supplier qualification, procurement of original equipment and replacement

parts, and the process of dedicating commercial grade items or services to safety-related applications.

'4)

The AEPSC gA Division provides technical direction in quality assurance matters to AEPSC and the Cook Nuclear Plant, and oversees the adequacy, effectiveness and implementation of the gA Program through review and audit activities.

5)

Cognizant Engineer (e.g.,

System Engineer, Equipment Engineer, Lead Engineer, Responsible Engineer, etc.)

The cognizant

engineer, and/or engineer with the other titles noted, is that AEPSC individual who provides the engineering/design expertise for a particular area of responsibility.

This responsibility includes the implementation of the quality assurance and quality control measures for systems, equipment, structures, or functional areas included in that individual's responsibility.

The various titles used for the identification of an individual's responsibility and assignment shall be understood to mean the same as cognizant engineer in the respective areas of responsibility.

uali t Assurance Res onsibi lit of I&M Cook Nuclear Plant IKM's Cook Nuclear Plant staff operates the Cook Nuclear Plant in accordance with licensing requirements, including the Technical Specifications and such other commitments as established by the operating licenses.

The Plant Hanager Instruction (PHI) system and subtier instructions and procedures describe the means by which compliance is achieved and responsibilities are assigned, including interfaces with AEPSC.

Figure 1.7-3 indicates the organizational 1.7-9

July, 1992

relationships within the AEP System pertaining to the operation and support of the Cook Nuclear Plant.

1.7. 1.2e5 Or anization AEPSC The Oha1rm'aniotjithaxgoard and Chief Executive Officer is ultimately responsible for the OA Program associated with the Cook Nuclear Plant.

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 responsibilities which are admi.nistered through the following AAEPSC:-,:orgaMz'iti,on management personnel:

AEPSC Director Qual ity Assurance AEPSC Vice President Nuclear Operations AEPSC Vice President Project Management and Construction ualit Assurance Division The AEPSC Director Quality Assurance, reporting to the AEPSC Senior Executive Vice President Engineering and Construction, is responsible for the Quality Assurance Division (QAD).

The QAD consists of the following sections (Figure 1.7-4):

Quality Assurance Engineering Section Nuclear Software Quality Assurance Section Audits and Procurement Section Quality Assurance Support Section Quality Assurance Section (Site)

The QAD is organizationally independent and is responsible to perform the following:

Specify QA Program requirements.

Identify quality problems.

Initiate, recommend, or provide solutions through designated channels.

1.7-10

July, 1992

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Verify implementation of solutions, as appropriate.

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

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

Verify the implementation of computer software quality assurance through reviews, survei llances and audits.

Audit engineering,

design, procurement, construction and operational documents for incorporation of, and compliance with, applicable quality assurance requirements to the extent specified by the AEPSC management-approved gA Program.

Organize and conduct the gA auditor orientation, training, certification and qualification of AEPSC audit personnel.

Provide direction for the collection, storage, maintenance, and retention of quality assurance records.

Haintain, on data

base, a list of suppliers of nuclear (N) items and services, plus other selected categories of suppliers.

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

Follow up on corrective actions identified by gA during and after disposition implementation.

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

Conduct in-process gA audits or survei llances at supplier's facilities, as required.

Assist and advise other AEP/AEPSC groups in matters related to the gA Program.

Conduct audits as directed by the NSDRC.

Review AEPSC investigated Problem Reports and associated corrective and preventive action recommendations.

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

1.7-11

July, 1992

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

Audit dedication plans for commercial grade items and services.

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

Provide AEPSC management with periodic reports concerning the

status, adequacy and implementation of the gA Program.

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

Routinely attend, and participate in, daily plant work schedule and status meetings.

Provide adequate gA coverage relative to procedural and inspection

controls, acceptance criteria, and gA staffing and qualification of personnel to carry out gA assignments.

Determine the acceptability of vendors to supply products and services for safety related applications.

Am lification of S ecific Res onsibilities ualification of the AEPSC Director ualit Assurance The AEPSC Director guality Assurance shall possess the fol 1 owing posi tion requirements:

Bachelor's degree in engineering, scientific, or related discipline.

Ten (10) years experience in one of, or a combination of, the following areas:

engineering,

design, construction, operations, maintenance of fossil or 1

nuclear power generation facilities'r utility facilities'A, of which at least four (4) years must be experience in nuclear quality assurance related acti vities.

Knowledge of gA regulations, policies, practices and standards.

The same, or higher, organization reporting level as the. highest line manager directly responsible for performing activities affecting the quality of 1.7-12

July, 1992

safety-related

items, such as engineering, procurement, construction and operation, and is sufficiently independent from cost and schedule.

Effective communication channels with other senior management positions.

Responsibility for approval of gA Hanual(s).

Performance of no other duties or responsibilities unrelated to gA that would prevent full attention to gA matters.

Sto Work Orders The AEPSC gAD 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 given the AEPSC Director-guali ty 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 guali ty Assurance to the AEPSC guality Assurance Superintendent (si te).

The AEPSC Director guality Assurance and the AEPSC guality Assurance Superintendent do not have the authority to stop unit operations, but will notify appropriate Cook Nuclear Plant and/or corporate management of conditions which do not meet the a forementi oned criteri a, and recommend that unit operations be terminated.

1.7-13

July, 1992

A Auditor uglification and Certification Pro ram AEPSC has established and maintains a gA auditor training and certification program for all AEPSC gA auditors.

Problem Identification Re ortin and Escalation AEPSC has established mechanisms for the identification, reporting and escalation of problems affecting the quality of safety-related items to a level of management whereby satisfactory resolutions can be obtained.

Nuclear 0 erations The AEPSC Vice President Nuclear Operations (Manager of Nuclear Operations),

reporting to the AEPSC Senior Executive Vice President Engineering and Construction, is responsible for 'AVN,e'iW,,.'.:.opiriti'oui~

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'.foU'oN.n'jg Formulate policies and practices relative to safety, licensing, operation, maintenance, fuel management, and radiological support.

Provide the Plant Manager with the technical and managerial

guidance, direction and support to ensure the safe operation of the plant.

Maintain liaison with the AEPSC Director equality Assurance.

Implement the requirements of the AEPSC gA Program.

Maintain knowledge of the latest safety, licensing, and regulatory requirements,

codes, standards, and federal regulations applicable to the operation of Cook Nuclear Plant.

1.7-14

July, 1992

Accomplish the procurement,

economic, technical, licensing and quality assurance activities dealing with the reactor core and its related fuel assemblies and components.

Prepare bid specifications, evaluate

bids, and negotiate and administer contracts for the procurement of all nuclear fuel and related components and services.

Haintain a special nuclear material accountability system.

Provide analyses to support nuclear steam supply system operation, including reactor physics, fuel economics, fuel mechanical

behavior, core thermal hydraulic and LOCA and non-LOCA transient safety analysis and other analysis activities as requested, furnish plant Technical Specification changes and other licensing work, and participate in NRC and NSDRC meetings as required by these analyses.

Perform reactor core operation follow-up activities and other reactor core technical support activities as requested, and arrange for support from the fuel fabricator, when needed.

Contract for, and provide'technical support for, disposal of both high level and low level radioactive waste.

Coordinate the development of neutronics and thermal hydraulic safety codes and conduct safety analyses.

Conduct studies of the Cook Nuclear Plant licensing bases to determine the optimal changes,.to support unit operations at a

lower primary pressure and temperature.

Coordinate NOD computer code development, and provide the interface control for NOD with the AEPSC Information System Department and Cook Nuclear Plant.

Obtain and maintain the NRC Operating License and Technical Specifications for the Cook Nuclear Plant.

Act as the communication link between the NRC, AEPSC, and the, plant staff.

Perform and coordinate efforts involved in gathering information, performing calculations and generic studies; preparing criteria,

reports, and responses; reviewing items affecting safety; and interpreting regulations.

1.7-15

July, 1992

Review, coordinate, and resolve all matters pertaining to nuclear safety between Cook Nuclear Plant and AEPSC.

This includes, but is not limited to: the review of certain plant design changes to ensure that the requirements of 10CFR50.59 are met; the preparation of safety evaluations, or reviews, for any designated subject; the preparation of changes to, and appropriate interpretation of, the plant Technical Specification submittals of license amendments; and the analysis of plant comp'liance with regulatory requirements.

Primary corporate contact for most oral and written communication with the NRC.

Provide support in key areas of expertise, such as nuclear engineering, probabi listic analysis, thermohydraulic analysis, chemical engineering, mechanical engineering, electrical engineering, and technical writing.

Interface with vendors and other outside organizations on matters connected with the nuclear steam supply system and other areas affecting the safe design and operation of nuclear plants.

Participate, as appropriate, in the review of nuclear plant operating experiences, and relate those experiences to the design and safe operation of Cook Nuclear Plant.

Review, evaluate, and respond to NRC requests for information and NRC notifications of regulatory changes resulting in plant modifications or new facilities.

Such responses are generated in accordance with appropriate AEPSC Administrative Procedures.

Develop, specify, and/or review conceptual nuclear safety criteria for Cook Nuclear Plant in accordance with established regulations.

This includes all information contained in the

FSAR, as well as specialized information such as environmental qualification and seismic criteria.

Review and evaluate performance requirements for systems, equipment and materials for compliance with specified safety criteria.

Review, on a conceptual

basis, plant reports and proposed plant safety-related design

changes, to the extent that they are related 1.7-16

July, 1992

to the ultimate safe operation of the plant, for compliance with safety regulations, plant Technical Specifications, the Updated FSAR design basis, and with any other requirements under the Operating License, to determine if there are any unreviewed safety questions as defined in 10CFR50.59.

Perform reviews of Problem Reports and 10CFR21 reviews in accordance with corporate requirements.

Operate the Action Item Tracking System (AIT) for AEPSC internal commitment tracking.

Coordinate design changes for the Cook Nuclear Plant, acting as a

focal point within AEPSC.

This program primarily involves project management responsibilities for scheduling and implementing Request for Changes (RFCs),

and includes extensive interfacing with engineering, design, construction, and Cook Nuclear Plant.

Provide working-level coordination with the Institute of Nuclear Power Operati ons (INPO) i'ii:".,"::the'.ar'%ii>:,ifFENPO.,"::::traiM.rig~gis8'%Toils'g and::,wo'r'ksh'oui:,

This effort includes providing AEPSC access to INPO resources, such as NUCLEAR NETWORK and Nuclear Plant Reliability Data System (NPRDS),

and effectively integrating AEPSC and Cook Nuclear Plant efforts towards utilizing INPO recommendations contained in'operating experience reports to improve Cook Nuclear Plant performance.

Coordinate daily communication with the Cook Nuclear Plant, provide AEPSC management with a daily plant status report, and make presentations to senior management at regularly scheduled construction staff meetings.

Process incoming vendor information.

Coordinate operations within AEPSC that support the Cook Nuclear Plant Facility Data Base (FDB).

Contribute to the annual FSAR updates through reviews of Licensee Event Reports, design changes and the Annual Operating Report.

Radiological, emergency and security planning.

Corporate support of the Cook Nuclear Plant's radiation protection and health physics program, technical eev~'egs and advice on the radiological aspects of design

changes, modifications or capital 1.7-17

July, 1992

7 I

improvements, the ALARA program, the radiation monitoring system, the environmental radiological monitoring and sampling program, dose and shielding analysis, radiochemistry review,

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'of,::,:,';fa'de'ral.:,::'r'~%gal'a'tionva'g and meteorological monitoring.

Cook Nuclear Plant and corporate emergency planning, including procedure development, exercise scheduling, facility procurement and maintenance, and the liaison with off-site emergency planning

groups, such as FEHA and the Hichigan State Police.

Review federal codes and regulations as they relate to the development, implementation, revision and distribution of the Hodified Amended Security Plan (HASP).

Interface with the plant's security department providing support for the security plan, reviewing security facilities, maintaining security document files, and developing the employee fitness for duty/background screening program.

Provide Nuclear General Employee Training (NGET) for AEPSC personnel.

Coordinate the development of training for AEPSC personnel who support the operation and maintenance of Cook Nuclear Plant, ensuring a unified training program meeting annual goals and objectives.

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Prepare responses to the NRC on radiological, emergency planning and security issues.

Serve as technical advisors on plant audits.

Remain cognizant of current decommissioning practices and developments.

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---:::::-::i!i't'---:::.i::-:::::::-'t::.::-'-----Md:;.--':-~Ã':::"::::-0:*:::,f,:::.:-!'IO.:.'-:*-::;:I'L:':i >Ii "ti,",tt, t,:

1.7-21

July, 1992

Oevelop and efficiently implement all site centralized training acti vities.

Administer the centralized facility training complex, simulator, and programs ensuring that program development is consistent with the systematic approach to training, maintain INPO accreditations, regulatory and corporate requirements.

Ensure that human resource activities include employee support programs (i.e., fitness for duty) consistent with INPO/NUNARC guidelines, company policies, and regulatory requirements and standards.

Admi ni ster the NRC approved physical Security Program in compliance with regulatory standards, Nodi Fied Amended Security Plan (HASP), and company policy.

Supervise,

plan, and direct the activities related to the maintenance and installation of all Cook Nuclear Plant equipment, structures,

grounds, and yards.

Prepare and maintain records and reports pertinent to equipment maintenance and regulatory agency requirements.

Administer contracts and schedule outside contractors'ork forces.

EnForce and coordinate Cook Nuclear Plant regulations, procedures,

policies, and objectives to assure safety, efficiency, and continuity in the operation of the Cook Nuclear Plant within the limits of the operating license and the Technical Specifications and formulation of related policies and procedures.

Plan, schedule, and direct activities relating to the operation of the Cook Nuclear Plant and associated switchyards; cooperate in planning and scheduling of work and procedures for refueling and maintenance of the Cook Nuclear Plant; and direct and coordinate fuel loading operations.

Review reports and records, direct general inspection of operating

, conditions of p'lant equipment, and investigate any abnormal conditions, making recommendations for repairs.

Establish and administer equipment clearance procedures consistent with company,

plant, and radiation protection standards; authorize and arrange 1.7-24

July, 1992

S 1

l 4

% Il

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for equipment outages to meet normal or emergency conditions.

Provide the shift operating crews with appropriate procedures and instructions to assist them in operating the Cook Nuclear Plant safely and efficiently.

Approve operator training programs administered by the Cook Nuclear Plant Training Department designed to provide operating personnel with the knowledge and skill required for safe operation of the facility, and for obtaining and holding NRC operator licenses.

Coordinate training programs in plant safety and emergency procedures for Cook Nuclear Plant Operating Department personnel to ensure that each shift group will function properly in the event of injury of personnel, fire, nuclear incident, or civil disorder.

Advance planning and overall conduct of scheduled and forced

outages, including the scheduling and coordination of all plant activities associated with refueling, preventive maintenance, corrective maintenance, equipment overhaul, Technical Specification surveillance, and design change installations.

Coordinate all Cook Nuclear Plant activities associated with the initiation, review, approval, engineering,

design, production, examination, inspection, test, turnover, and close out of design changes.

Develop and implement an effective equality Control (gC) Program.

This encompasses, but is not limited to, the planning and directing of quality control activities to assure that industry

codes, NRC regulations, and company instructions and policies regarding quality control for Cook Nuclear Plant are implemented, qua1ified personnel perform the work, and that these activities are properly documented.

Prepare reports of reportable events which are mandated by the NRC and the Technical Specifications.

Direct the activities of contractor gC/nondestructive examination

{NDE) personnel assigned to the Safety and Assessment Department and provide inspections of work performed.

1.7-25

July, 1992

Prepare statistical reports utilized in NRC Appraisal Meetings and Enforcement Conference.

Coordinate the efforts of outside agencies, such as American Nuclear Insurers (ANI), INPO, and third-party inspector programs.

Maintain knowledge of developments and changes in NRC requirements, industry standards and codes, regulatory compliance activities, and quality control disciplines and techniques.

Stop plant operation in the event that conditions are found which are in violation of the Technical Specifications or adverse to quality.

Maintain and renew accreditation of training programs.

qualification and certification of I&H personnel performing inspections or tests of major modifications and non-routine maintenance to the requirements of Regulatory Guide 1.5 and ANSI N45.2.6, except as noted in Appendix B hereto, item 9.

'I qualification and certification of I&H NDE personnel to the requirements of the AEP NDE Manual.

qualification of I&H personnel performing inspection of normal operating activities to ANSI N18. 1.

Proper certification of contractor inspection, test and examination personnel in accordance with Regulatory Guide 1.5, ANSI N45.2.6, ASHE B&PV Code and/or SNT-TC-IA, as applicable.

Perform peer inspections of work completed by I&M personnel by independent persons qualified to ANSI N18.7.

Conduct of the Inservice Inspection (ISI) Program.

Procurement, receiving, quality control receipt inspection,

storage, handling, issue, stock level maintenance, and overall control of stores items.

Provide material service and support in accordance with policies and procedures required by AEP Purchasing and Stores, AEPSC gA,

=and the NRC, which are administered and enforced in a total effort to ensure safety and plant reliability.

Plan and direct engineering and technical

studies, nuclear fuel management, equipment performance, instrument and control maintenance, on-site computer systems, Shift Technical Advisors, 1.7-26

July, 1992

and emergency planning for the Cook Nuclear Plant.

These activities support daily on-site operations in a safe, reliable, and efficient manner in accordance with all corporate policies, applicable laws, regulations,

licenses, and Technical Specification requirements.

Implement station performance testing and moni tor programs to ensure optimum plant efficiency.

Direct programs related to on-site fuel management and reactor core physics testing, and ensure satisfactory completion.

Establish testing and preventive maintenance programs related to station instrumentation, electrical

systems, and computers.

Recommend alternatives to Cook Nuclear Plant operation, technical or emergency procedures, and design of equipment to improve safety of operations and overall plant efficiency.

Implement the corporate Emergency Plan as it pertains to the Cook Nuclear Plant site.

Provide technical and engineering services in the fields of chemistry, radiation protection, ALARA, and environmental in support of the safe operation of the plant and the health and safety of the employees and the public.

plan and schedule the activities of the adf'ation":::::.":Proton 'ioil Pep'eitTse'nt of the Cook Nuclear Plant in support of operations and ann e.w.AS)us suave. hc maintenance.

Establish chemistry, radiochemistry, and health physics criteria which ensure maximum equipment life, and the protection of the health and safety of the workers and the public.

Establish sampling and analysis programs which ensure the chemistry, radiochemistry, and health physics criteria are within the established criteria.

Establish and.direct investigations, responses, and corrective actions when outside the established criteria.

Administer and direct the Cook Nuclear Plant's radioactive waste

. programs, including volume reduction, packaging and shipping.

Administration of the gA Records Program.

Maintain the Cook Nuclear Plant Facility Data Base.

1.7-27

Pro'ect Mana ement and Construction De artment The AEPSC Vice President Project Management and Construction, reporting to the AEPSC Senior Executive Vice President Engineering and Construction, is responsible for the Project Management and Construction Department.

Reporting to the AEPSC Vice President Project Management and Construction are the following:

Site Construction Manager, reporting administratively to the AEPSC Vice President

,Project Management and Construction, and functionally to the Pl'ant.",,,Mani'ger'~~Cook:.".Nu'c'1'e~ar,",::.P,'la'nt':.'he Project Management and Construction Department is responsible for the following:

Administer and implement construction job orders issued by the Cook Nuclear Plant organization for major modifications, replacement and maintenance work with outside contractors.

Administer and monitor contractor's industrial safety programs and performance.

Administer human resources'unctions for site construction organization.

Manage construction labor relations with the International Building and Construction Trades Unions.

Scope, bid, recommend awards and administer construction labor and services contracts.

Plan, organize and control major construction projects, as assigned by the AEPSC Senior Executive Vice President Engineering and Construction.

Maintain cognizance on matters pertaining to the Cook Nuclear Plant and corporate emergency response organization.

Prepare

~@ construction labor estimates.

1.7-28

July, 1992

Provide constructability guidance when requested in support of engineering and design changes.

Participate on the Nuclear Safety Design Review Committee.

Purchasin and Stores De artment (not charted)

The AEPSC Executive Vice President Operations, reporting to the AEPSC President:.'indgCh$ '8'f""Ojerati'nj::::0'fAcei":::,': is responsible for the Purchasing and Stores Department through the AEPSC Vice President Purchasing and Haterials Hanagement.

The Purchasing and Stores Department is responsible for the following:

Procurement of safe't3'.-,.teste'd items from only qualified and approved suppliers.

Provide supervision to Cook Nuclear Plant Purchasing Section.

Provide ordering and stocking descriptions of safety,'.-..".'r'eTdt'ed items and include these descriptions in the Cook Nuclear Plant inventory

catalog, including necessary communications with suppliers, cognizant engineers, the Cook Nuclear Plant Stores Supervisor and other appropriate personnel.

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-'::.'.;:%":""~;.":Coord"na'ti'.;"':,p'r'ocuremen4:;-':act'~ ii'4j;es;-;;.ii;th:,;PEP'";guru'e'Ihip;,:.Ojeyefj~ons';:

~VCr~ 0 iaNÃiaeXVOp~pa~~~t XXV&M'aX<<~XVXVX.Xa~i'anXXXVS<4V xXV ' MMVXSWXX4'Ark'>>AN'VXVXtmeuoea4plraXVXaX+XC'XXa<4C"a A~A'PSG:: uaTTty;;A'ssdTalfce;:;:andCooklN:lihTea'r!Plant:::pe'rsTi5neTv Prepare and issue requests for quotations, contracts, service orders and purchase orders for sa~fe4,.-..::je7iCi;d items.

Establish a system to implement corrective action as described in the AEPSC General Procedures for the Cook Nuclear Plant.

Establish a system of document keeping and transmittal.

Establish a system of document control for controlled procedures, instructions and purchasing documents for safety,;:,,rÃafel items.

1.7-29

July, 1992

S

The maintenance and control of selected standard procurement document phrases as identified by the Director Quality Assurance, or designee.

Conduct training sessions involving purchasing personnel and others on an annual

basis, or more frequently, as required, and ascertain that training sessions include complete responsibilities associated with the purchase of safety-related items.

1.7.2 QUALITY ASSURANCE PROGRAM.,

1.7.2.1 SCOPE Policies that define and establish the Cook Nuc'lear Plant'QA Program are summarized in the individual sections of this document.

The program is implemented through procedures and instructions responsive to provisions of the QAPD, and will be carried out for the life of the Cook Nuclear Plant.

Quality assurance controls apply to activities affecting the quality of saFety-related structures, systems and components to an extent based on the importancegof those structures,

systems, components, etc.,

(items) to safety.

Such 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.

Safety-related items are defined as items:

Which are associated with the safe shutdown (hot) of the reactor; or isolation of the reactor; or maintenance of the integrity of the reactor coolant system pressure boundary.

OR Whose failure might cause or increase the severity of a design basis accident as described in the Updated FSAR; or lead to a release of radioactivity in excess of IOCFR100 guidelines.

I.7-30

July, 1992

In general, items are classified as safety-related if they are:

Seismic Class I, or Electrical Class 1E; or associated with the Engineered Safety Features Actuation System (ESFAS); or associated with the Reactor Protection System (RPS).

A special gA Program has been implemented for Fire Protection items (Section 1.7. 19 herein).

The gA Program also includes provision for Radwaste gA in accordance with the requirements of 10CFR71, par t H.

gA Program status,

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

meetings, and review of audit results.

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

However, AEPSC and/or Indiana Michigan Power Company retain full responsibility for all activities affecting safety-related items.

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

1.7.2.2 1.7.2.2.1 IMPLEMENTATION gThi*.:,:,::Clfa'irm~iiiofrth~s:,'go'arid';,:and,",.::Ch'lefhEnec'n'tdsei gfft'cer; of AEP has stated in a signed, formal "Statement of Policy", that it is the corporate policy to comply with the provisions of applicable

codes, standards and regulations pertaining to quality assurance for nuclear power plants as required by the Cook Nuclear Plant operating licenses.

The statement makes this gAPD and the associated implementing procedures and instructions mandatory, and requires compliance by all responsible organizations and individuals.

The statement also identifies the 1.7-31

July, 1992

II II>>

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management positions within the companies vested with responsibility and authority for implementing the program and assuring its effectiveness.

1.7.2.2.2 The gA Program at AEPSC and the Cook Nuclear Plant consist of controls exercised by organizations responsible for attaining quality objectives, and by organi zati ons responsi bl e for assurance functi ons.

The gA Program effectiveness is continually assessed through management review of various reports, NSDRC review of the gA audit program, and shall also be periodically reviewed by independent outside parties as deemed necessary by management.

The gA Program described in this gAPD is intended to apply for the life of the Cook Nuclear Plant.

~ 1

~l,

,'ji The gA Program applies to activities affecting the quality of safety-related structures, components, and related consumables during plant operation, maintenance,

testing, and all design changes.

Safety-related structures, systems and components are identified in the Facility Data Base and other documents which are developed and maintained for the plant.

As deemed necessary by the AEPSC Director guality Assurance, or the Plant Hanager, applicable portions of the gA Program controls will be applied to nonsafety-related activities associated with the implementation of the gA Program to ensure that commitments are met (e.g., off-site records

storage, training services, etc.).

1.7.2.2.3 This gAPD, organized to present the gA Program for the Cook Nuclear Plant in the order of the 1 criteria of 10CFR50, Appendix 8, states AEPSC policy for each of the criteria and describes how the controls 1.7-32

July, 1992

pertinent to each are carried out.

Any changes made to this gAPD that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually.

Any changes made to this gAPD that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation.

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

The program described in this gAPD will not be intentionally changed in any way that would prevent it from meeting the criteria of 10CFR50, Appendix 8 and other applicable operating license requirements.

1.7.2.2.4 Documents used for implementing the provisions of this gAPD include the following:

Plant Manager Instructions (PMIs) establish the policy at the plant for compliance with speci fied criteria, and assign responsibility to the various departments, as required, for impiementation.

Hta'nmt::;:,::Hanag~e'"'r'o'ce'dmu're's:(PHpms)'.",".

Department Head Procedures (DHPs),

and in some cases Department Head Instructions (DHIs), have been prepared to describe the detailed activities required to support safe and effective plant operation as per the PMIs.

The PMIs are reviewed by AEPSC gA for concurrence that they wi 11 satisfactorily implement regulatory requirements and commitments.

INH and:,":::'PIPE are g'4'eviewed by the PNSRC prior to approval by the Plant Manager.

Dgps';.:and:::DHTs!:area.".;."rsevie'vTed!~$ iXth'i'n.::;,th',,;d~e "ar'tmeTT a~i::

rg!~nr.,":: o"'rap'pr'ova~!","

th'e.';:De'p'artm'ent:.::.,He'ad osf,::,:o'rig!'natth'n.:a:::OHPs,::ari'd;:.:DHTs.;.!th'at!!'mlgiit',Wnvol've-":: an giirevj~i'(ad!safety~!q'u'ast'Qoj ~is!defi'nad:::i'ii'.XDCF(NO,"gg::.,at i::."rev'i'cued.-'"bj PN$RC"pii~to',.".;"agp fovaT..; hy.--:,thi."..'::,Gspaitmanvt:,.:Head;,of<'ol iginaiiton.

l. 7-33

July, 1992

AEPSC General Procedures (GPs) are utilized to define corporate policies and requirements for quality assurance, and to implement certain'orporate OA Program requirements.

AEPSC division/department and/or section procedures are also used to implement gA Program requirements.

GPs may also be used to define policies which are nonprocedural in nature.

When contractor s perform work on-site under their own quality assurance

programs, the programs are audited for compliance and consistency with the applicable requirements of the Cook Nuclear Plant's gA Program and the contract, and are approved by AEPSC gA prior to the start of work.

Implementation of on-site contractor 's gA programs, will be audited to assure that the contractor's programs are effective.

~

~

1.7.2.2.5 Provisions of the gA Program for the Cook Nuclear Plant apply to

. activities affecting the quality of saFety-related items.

Appendix A to this gAPD lists the Regulatory/Safety Guides and ANSI Standards that identify AEPSC's commitment.

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

The scope of the program, and the extent to which its controls are applied, are established as follows:

a)

AEPSC uses the criteria specified in the Cook Nuclear Plant Updated FSAR for identifying structures, systems and components to which the gA Program applies.

b)

This identification process results in the Facility Data Base for the Cook Nuclear Plant.

This Facility Data Base is controlled by authorized personnel.

Facility Data Base items are determined by 1.7-34 July; 1992

engineering analysis of the function(s) of plant items in relation to safe operation and shutdown.

c)

The extent to which controls specified in the gA Program are applied to Facility Data Base items is determined for each item considering its relative importance to safety.

Such determinations are based on data in such documents as the Cook Nuclear Plant Technical Specifications and the Updated FSAR.

1.7.2.2.6 Activities affecting safety-related items are accomplished under control 1 ed condi tions.

Preparati ons for such acti vities include consideration of the following:

a) b)

c) d)

e) g)

h)

Assigned personnel are qualified.

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

Specified equipment and/or tools are available.

Items are in an acceptable status.

Items on which work is to be performed are in the proper condition for the task.

Proper ipproved 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.

1.7.2.2.7 Responsibility and authority for planning and implementing indoctrination and training of AEPSC and Cook Nuclear Plant staff personnel are specifically designated, as follows:

1.7-35

July, 1992

a)

The training and indoctrination program provides for on-going training and periodic familiarization with the gA Program 'for the Cook Nuclear Plant.

b)

Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.8, ANSI N18. 1, Regulatory Guide 1.58, ANSI N45.2.6, the ASHE B&PV Code, or SNT-TC-IA, as applicable, and with exceptions as noted in Appendix B hereto.

c)

AEPSC gAO auditors are qualified in accordance with Regulatory Guide

1. 146 and ANSI N45.2.23.

d)

Personnel assigned duties such as special cleaning processes, welding, etc.,

are qualified in accordance with applicable

codes, standards, regulatory guides and/or plant procedures.

e)

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

f)

Training, qualification, and certification records including documentation of objectives, waivers/exceptions, 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's relevant.

g)

Personnel responsible for performing activities that affect safety-related items are instructed as to the purpose, scope and implementation of the applicable manuals, instructions and procedures.

Management/supervisory personnel receive functional training to the level necessary to plan, coordinate and administer the day-to-day 1.7-36

July, 1992

verification activities of the gA Program for which they are responsible.

Training of AEPSC and Cook Nuclear Plant personnel is performed

'mploying the following techniques, as applicable:

1) on the job and formal training administered by the department or section the individual works for; 2) formal training conducted by qualified instructors from the Cook Nuclear Plant Training Department or other entities (internal and external to the AEP System);

and 3) formal, INPO accredited training conducted by the Cook Nuclear Plant Training Department.

Records of training sessions for such training are maintained.

Where personnel'ualifications or certi fications are required, these certi fications are performed on a scheduled basis (consistent with the appropriate code or standard).

i Cook Nuclear Plant employees receive introductory training in quality assurance usually within the first two weeks of,employment.

In

addition, AEPSC personnel receive training prior to being allowed unescorted access to the plant.

This training includes management's policy for implementation of the gA Program thr ough Plant Manager and Department Head Instructions and Procedures.

These instructions also include a description of the gA Program, the use of instructions and procedures, personnel requirements for procedure compliance and the systems and components controlled by the gA Program.

1.7.3 DESIGN CONTROL 1.7.3.1 SCOPE Design changes are accomplished in accordance with approved design.

Activities to develop such designs are controlled.

Depending on the type of design

change, these activities include design and field engineering; the performance of physics,

seismic, stress,

thermal, hydraulic and radiation evaluations; update of the FSAR; review of accident analyses; the development and control of associated computer programs; studies of material compatibility; accessibility for inservice 1.7-37

July, 1992

inspection and maintenance; determination of quality standards; and requirement for equipment qualification.

The controls apply to preparation and review of design documents, including the correct translation of applicable regulatory requirements and design bases into

design, procurement and procedural documents.

1.7.3.2 IMPLEMENTATION 1.7.3.2.1 Design changes are controlled by 'procedures and instructions and are reviewed as required by 10CFR50.59

'a'editbe'!Teehe'i'u'a'I!<Sii'e'si'dui.c'e'i'i'oes...

Safety-related design changes are accomplished by one of two separate processes:

Minor Modification (MM), or Request for Change (RFC).

Those that do not alter the intended function of the item and can be determined by judgement to have a minimal overall impact on the item being modified may be implemented via the MN process.

All other safety-related design

changes, that are not appropriate for MM processing, are implemented via the RFC process.

In cases where design changes could be deemed to be within the scope of

'FCs or MMs solely due to possible insignificant adverse seismic

effects, the change may be implemented via the Plant Modification (PM) process.

In the case where safety-related items are involved and the change introduces only insignificant adverse seismic effects, the change may be implemented via the Plant Modification (PM) process.

1.7.3.2.2 Uisi'jnTchiiigi*.'5 are reviewed to determine their impact on nuclear safety and to determine if the proposed changes involve an unreviewed safety question as defined by 10CFR50.59.

If a design change were to involve 1.7-38

July, 1992

f

an unreviewed safety question, it would not be approved for implementation until the required NRC approval was received.

RFCs (except those requiring emergency processing),

MMs and PMs (having only insignificant seismic effect on safety items) are reviewed and approved prior to implementation, as a minimum, by the cognizant AEPSC swecNoii-':ind.'.P1'an't:! Nav'nai'e'i;..'i~~'.TVie':PNSRC".':-:al s'o::i.,'ev'i'ebs"",":,those';,,"BFC's':::.,":.NBA::"'.Mid PHs~-'fo'r~whf~h,".-::~abet'j.'.',"',,evaliiiti.'ins.:;:::~r~'-"dee~ed~iifcves 1061:..R50'.::,59,..:a-d:,",':::.TechnicÃ::..',',Sjeci':fi'cat)'iK;:.:0.".S.,-,'1%6',;:

yNyM:,y'ilaw yv4rNyww'WwiyvyvvvykiY~yww'wive wWyywy'Aa&vSAyiirywrivyywyvyyy~~CXyyywy'y 1.7.3.2.3 For RFCs, the Change Control Board established within AEPSC provides an additional review and approval level.

The Change Control Board is comprised of members of the Engineering,

Design, Nuclear Operations and gA organizations within AEPSC, and is supplemented by other AEPSC organizations or individuals, as required.

The cognizant member of the Change Control Board assigns a lead engineer for each RFC.

The lead engineer is responsible for coordinating the RFC activities within AEPSC and maintaining close interface with )EP$CÃBg we+

vvv Awy' w'v 'wwwv ' '

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%VAN v Enein8erl rjg:::,;:.WUp,ort,".:,l',,r03ecz::.It ngNeet'.ng.

1.7.3.2y4 Proposed RFCs which require emergency processing are originated at the plant, reviewed by the

PNSRC, and approved by the Plant Manager.

Cook Nuclear Plant management then contacts the AEPSC NOD, and other AEPSC management, as required, describes the change requested, and implements y

the change only after receiving verbal AEPSC management authorization to proceed.

These reviews and approvals are documented and become a part of the RFC Packet.

1.7-39

July, 1992

S

When RFCs or HNs involve design interfaces between internal or external design organizations, or across technical disciplines, these interfaces are controlled.

Procedures are used for the review, approval,

release, distribution and revision of documents involving design interfaces to ensure that structures, systems and components are compatible geometrically and functionally with processes and the environment.

Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses.

Decisions and problem resolutions involving design interfaces are made by the AEPSC organization having responsibility for engineering direction of the design effort.

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

1.7.3.2.7 RFC design document packages are audited by AEPSC gA to assure that the documents have been prepared, verified, reviewed and approved in accordance with company procedures.

1.7.3.2.8 The extent of, and methods for, design verification are documented.

The extent of design verification performed is a function of the importance of the item to safety, design complexity, degree of standardization, the state-of-the-art, and similarity with previously proven designs.

Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews.

These methods may be used 1.7-40

July, 1992

singly or in combination, depending on the needs for the design under consi derati on.

When design verification is done by evaluating standardized or previously proven designs, the applicability of such designs is confirmed.

Any differences from the proven design are documented and evaluated for the intended application.

qualification testing of prototypes, components, or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated.

This testing is performed before plant equipment installation, where possible, but always before reliance upon the item to perform a safety-related function.

qualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes.

Test requirements, procedures and results are documented.

Results are evaluated to assure that test requirements have been satisfied.

Design changes shown to be necessary through testing are

made, and any necessary retesting or other verification is performed.

Test configurations are clearly documented.

Design reviews are performed by multi-organizational or interdiscipl'inary groups, or by single individuals.

Criteria are established to determine when a formal group review is required, and when review by an individual is sufficient.

Procedures require that minor design changes accomplished by the NM process also receive formal design verification.

Applicable design verification activities shall be completed prior to declaring the design

change, or portion thereof, operational.

1.7.3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications.

These persons are qualified by 1.7-41

July, 1992

appropriate education or experience, but are not directly responsible for the design.

The designer's immediate supervisor may perform the verification, provided that:

1)

The supervisor is the only technically qualified individual.

or 2)

The supervisor has not specified a singular design

approach, ruled out design considerations, nor established the design inputs.

and 3)

The need is individually documented and approved in advance by the supervisor's management.

and 4)

Regularly scheduled gA audits verify conformance to previous items 1 through 3.

Design verification on safety-related design changes shall be completed prior to declaring a design

change, or portions thereof, operational.

1.7.3.2.10 gvwvlww'awv 'two' u 'weave'rug'w ( vww v'h w rwwsw~+'rmwrwurgw'+urus dx w w~.y r wgw%rgEPSCP'g'+vow Ei'ig$ie'ei',.'i.nj(Sup joi'..t'!Project;:"',:;:.E(g$ neer4'aj",":.

Nateri al to per form the desi gn change must meet the specifications established for the original system, or as specified by the lead engineer.

For those design changes where testing after completion is required, the testing documentation is reviewed by the organization performing the test and, when specified, by the AEPSC lead engineer or other cognizant engineer(s).

Further, completed design changes are auditedII'sj'rve'Bfe'd by AEPSC gA following installation and testing.

1.7.3.2.11 Changes to design documents, including field changes, are reviewed, approved and controlled in a manner commensurate with that used for the 1.7-42

July, 1992

J

~

Pl M

original design.

Such changes are evaluated for impact.

Information on approved changes is transmitted to all affected organizations.

1.7.3.2.12 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.

1.7.3.2.13 Established 1) 2)

3) 4)

5) 6)

7) design control procedures provide for:

controlled submission of design

changes, engineering evaluation, review for impact on nuclear safety, audit by AEPSC gA, design modification, AEPSC managerial

review, and approval and record keeping for the implemented design change.

1.7.4 PROCUREMENT DOCUMENT CONTROL 1.7.4.1 SCOPE Procurement documents define the characteristics of item(s) to be procured, identify applicable regulatory and industry codes/standards requirements, and specify supplier gA Program requirements to the extent necessary to assure adequate quality.

1.7.4. 2 IMPLEMENTATION 1.7.4;2.1 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 1.7-43

July, 1992

with safety-related structures or systems are:

1) purchased to specification and code requirements equivalent to those of the original equipment or service (except when the Code of Federal Regulations requires upgrading),

2) properly documented to show compliance with the applicable specifications, codes and standards, and 3) purchased from vendors or contractors who have been evaluated and deemed qualified, or by the c'ommer'ci'N~%grade::dedfiati'on':"..::jiroc'esj::.

Procedures establish the review of procurement documents to determine that:

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

The manager of the originating group, with support of the cognizant AEPSC engineering group, is responsible for assuring that applicable requirements are set forth in procurement documents.

The Cook Nuclear Plant may request assistance of AEPSC cognizant engineers in any procurement activity.

1.7.4.2.2 The Facility Data Base, in conjunction with other sources, is used for equipment safety classification and procurement grade.

AEPSC specifications are used to determine requirements, codes or standards that items must fulfill,and define the documentation that must accompany the item to the plant.

Procurement documents for safetyIrelated items and services are reviewed to ensure that:

correct classification is made; the requirements are properly stated; and that measures have been, or will be, implemented to assure the requirements are met and adequately provided for.

1.7-44

July, 1992

Purchase requisitions for new safetygrelated items are initiated by the cognizant engineering group which establishes initial requirements.

Replacement/spares are purchased to requirements equiva'lent to the original unless upgrading is required by Federal Regulations, or deemed necessary by the cognizant engineering group.

1.7.4.2.3 The contents of procurement documents vary according to the item(s) being purchased and its function(s) in the Cook Nuclear Plant.

Provisions of this gAPD are considered for application to service contractors, also.

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.

Imposition of guides/standards on AEPSC/I&V suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be supplied and upon the degree that AEPSC/I&M relies on suppliers to invoke guides/standards.

AEPSC/I&N recognizes that certain suppliers have acceptable IOCFR50, Appendix B gA programs, even through, the suppliers are not committed to Regulatory Guides or industry standards (e.g.

ANSI N45.2.6.).

In those cases, in which suppliers are not committed to the same guides/standards as AEPSC/I&M, AEPSC/IQl will assure that (I) the supplier's gA program provides adequate gA controls, regardless of the lack of specific commitment, or (2) controls will be invoked directly by AEPSC/IM to assure adequate quality of i::teiis/services received by suppliers.

Wlucc @we c)

Regulatory, admini strati ve and reporting requirements.

d) guality requirements appropriate to the complexity and scope of the work, including necessary tests @ld/or inspections.

I.7-45

/

y

'I

e) g)

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

A requirement for the supplier to invoke applicable quality requirements on subtier suppliers.

Provisions for access to supplier, and subtier suppliers',

facilities and records for inspections, survei llances and audits.

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

1.7.4.2.4 The AEPSC gA Division performs audi ts of procurement documents to assure that gA Program requirements have been met.

These audits are conducted in accordance with AEPSC gA Division procedures.

1.7.4.2.5 Changes to procurement documents are controlled in a manner commensurate with that used for the original documents.

1.7.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.7.5.1 SCOPE 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.

1.7.5. 2 IHPLEHENTATION 1.7.5.2.1

July, 1992 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 1.7-46

activity has been sati sfactori ly accompli shed.

Hold points for inspection are established when required.

Instructions and procedures pertaining to the specification of, and/or implementation of, the gA Program receive multiple reviews for technical adequacy and inc1usion of appropriate quality requirements.

Top tier instructions and 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 gA Program for which they are responsible.

Special procedures may be issued for activities which have short-term appl i cabi 1 ity.

1.7.5.2.2 I

AEPSC activities relative to the Cook Nuclear Plant are outlined by procedures which provide the controls for the implementation of these activities.

AEPSC has two categories of gA Program implementation procedures:

1)

General Procedures (GPs) which are applicable to all AEPSC divisions and departments involved with Cook Nuclear Plant.

2)

~Or,"an'iaatsvi'ij procedures which apply to the specific division, department or section involved.

1.7.5.2e3 Activities at the Cook Nuclear Plant are controlled using plant procedures.

1.7-47

July, 1992

The PHIs have been classified into the following series:

1000 Per's'0'ncnef.:::;::;":Sii fe'ct'foi7":',:':'PNSRC-::P'r'0'c'e'dore's h4vAm'hrrA8w<<hch'ccmeNw c~oe)kwrh~ ca~wAhsc chhthc ccrhh c'~rnMv'.h~r 2000 Administrati on Document Control, Securi ty, Training, Records, Em'ergeji j:;::'Pl:i'"";;,"~'F5,'re';: Pi,.o't@ctioii',.".c;. Cl'eieaii'ce":.-,.'.Penis;Aj'~ChellcaL:

Ccon't're! ','ll'Kt'ei'..n'aIi':Cl'eanl.:,i'j'ieYs:'!ll'p'j'.lcll:":;.Res'pon'se ';:~"';.Stan'ding.::"'"oi,""d'ei'.,:i':,

Co>'r'ect)ve>Haintenance hm~sh4hm~wma%

hraWh;"w 'c cccch'000 Procurement, Receiving, Shipping and Storage 4000 Operations, Fuel Handling, Surveillance Testing, ~TestjCootioli 5000 Maintenance, Repair, Modification, Special Processes, Eg and ISI Co'nf,r'oil:;.".o',.".:;:;.Contr'a'ctor5

)hmhch'rhY hc h'NM4Yhccc ccchcc'Kc hHhW ccm hhVNI 6000 Technical Chemistry/Radiological

Controls, Racdja'ti'o'il;:,.PFotecti:;on',:+

- Performance/Engineering

Testing, and Instrument and Control Maintenance and Calibration, Heasujing,'and+Test'~Eqojpeeat 7000 guali ty Assurance, guali ty Control Program and Condition/Problem Reporting Instructions and procedures identify the regulatory requirements and commitments which pertain to the subject that it will control and establish responsibilities for implementation.

Instructions and procedures may either provide the guidance necessary for the development of supplemental instructions and/or procedures'o implement their requirements, or provide comprehensive guidance based on the subject matter..

1.7.5.2.4 Cook Nuclear Plant drawings are produced, controlled and distributed under the control of AEPSC and the Cook Nuclear Plant.

AEPSC design drawings are produced by, or under the control of, the AEPSC Nuclear EA'gi,'r}'eir$5g;":Oe'p'a'rtmeiit under a set of procedures which direct their development and review.

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

Specific c

1.7-48

July, 1992

drawings are reviewed and approved by the cognizant engineering of':gkA'iN I%A.

AEPSC has stationed an on-site design staff to provide for the revision of certain types of design drawings to reflect as-built conditions.

1.7.5.2.5 Complex Cook Nuclear Plant procedures are designated as "In Hand" procedures.

Examples of "In Hand" procedures are those developed for extensive or complex jobs where reliance on memory cannot be trusted.

Further, those procedures which describe a sequence which cannot be

altered, or require the documentation of data during the course of the procedure, are considered.

"In Hand" procedures are designated as such by double asterisks

(**) which precede the procedure number on the cover sheet, all pages and attachments of a procedure and the corresponding index.

1.7.6 DOCUMENT CONTROL 1.7.6.1 SCOPE Documents controlling activities within the scope defined in 1.7.2 herein are issued and changed according to established procedures.

Documents such as instructions, procedures and drawings, including 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.

l.7-49

July, 1992

1.7.6. 2 INPLEHENTATION 1.7.6.2.1 Controls are established for approval, issue and change of documents in the following categories:

a) b)

c) d)

e) f)

g)

Design documents (e.g., calculations, specifications, analyses)

Drawings and related documents Procurement documents Instructions and procedures Updated Final Safety Analysis Report (UFSAR)

Plant Technical Specifications Safeguards documents 1.7.6.2.2 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.

1.7-50

July, 1992

1.7.6.2s3

~

~

~

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Documents are issued and controlled so that:

a)

The documents are available prior to commencing work.

b)

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

1.7.6.2e4 Haster 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.

1.7.6.2.5 In the event a drawing is developed on-site to reflect an as-built configuration, the marked-up drawing is maintained in the paster Plant File and all holders of the drawing are issued appropriate notification to inform them the revision they hold is not current, cannot be used and, if required, reference must be made to the Paster Plant File drawing.

1.7.6.2.6 Documents prepared for use in training Q>: are appropriately marked to indicate that they cannot be used to operate or maintain the facility or to conduct activities affecting the quality of safety-related items.

At

.thai Cook Nuclear Plant, unless a document is identified as

'controlleder, kio'irff;-: 'epyc;,i sljon) it is automatically assumed 'that the document is for information Q!.::

use only.

1.7-51

July, 1992

1.7.7 CONTROL OF PURCHASED ITEMS AND SERVICES 1.7.7.1 SCOPE Activities that implement approved procurement requests for items and services are controlled to assure conformance with procurement document requirements.

Controls include a system of supplier evaluation and selection audits, acceptance of items and documentation upon delivery, and periodic assessment of supplier performance.

Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the Cook Nuclear Plant site prior to use of equipment, material, or services.

1.7.7.2 1.7.7.2.1 IMPLEMENTATION AEPSC qualifies suppliers and distributors by performing a documented evaluation of their capability to provide items or services specified by procurement documents.

Items and services designated as safety-related are purchased from suppliers whose gA programs have been accepted in accordance with AEPSC requirements, or from commercial grade suppliers through the AEPSC dedication program.

Suppliers of other items/services

'ai'.i:,:.'i9bject~to"';:,eiÃNN'ion:::,.'i+id,."'.:::appr0vil'::::'based:::;::af7'iccspiwce:;.~eri teri0 ij'i'pl".1;c5b3~%::::ti,:!.':th0se~f,',tfisj,':i;igni:",',

qualification of such suppliers is determined by the AEPSC gA Division.

In the discharge of this responsibility, the AEPSC gA Division may use information generated by other utilities.

The supplier, or distributor, must be approved before procurement can be completed.

AEPSC is a member of the Nuclear Procurement Issues Co~'tive (NUPIC), participates in joint suppl ier audi ts, and shares audi t informati on consi stent with NUPIC requirements.

The supplier, or distributor, must-be acceptable, or acceptable subject to follow-up, before a procurement can be approve and processed.

Additional audits will be conducted, as necessary, to meet requi rements.

Acceptance is not complete until it has been 1.7-52

July, 1992

r 4

J

determined that the suppliers'A program can meet the requirements for the item(s)/service(s) offered.

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

1.7.7.2.3 In-process audits of suppliers'ctivities during fabrication, inspection, testing and shipment of items are performed when deemed necessary, depending upon supplier qualification status, complexity of the i tem(s) being furnished, the items'mportance to safety, and/or previous supplier history.

These audits are performed by AEPSC gA. 'he cognizant engineer and/or responsible Cook Nuclear Plant personnel may also participate, if deemed necessary.

1.7.7.2.4 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.

1. 7-53

July, 1992

c)

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

The evaluation assures there is no adverse effect on interfaces, safety, interchangeability, 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.

1.7.7.2.5 Instructions and procedures address requirements for supplier selection and control, as well as procurement document control.

The PHI on receipt inspection of safety-related items addresses 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.

Provisions for receipt inspection apply regardless of where the procurement originates.

Additional inspections may apply if required by the procurement document.

Where items and/or services are safety-related and procurement is accomplished without assistance of AEPSC, supplier selection is limited to those companies identified as being qualified.

1.7.7.2.6

!Hiiii;;:i'equi!ibadlat::.,:'t Le,!:si.; tai re;-,,:. tages

:.ii:, 'li>i:,,::;;H L~iq:aK /n"r,::.":pIai

'-:,:iii

'a%designate'dgarai'~geig"iisneVi::::fii'il),,::until<i':ej'e3jit'iieet'fe'c't'edg During recei pt inspecti on, desi gnated materi al characteri sti cs and attributes are checked, and documentation is checked against the procurement documents.

If found acceptable, the "HOLD" tag is removed and replaced with an "ACCEPTED" tag and the item is placed in a designated area of 1.7-54

July, 1992

the storeroom.

Item traceabi lity to procurement documents and to end use is maintained through recording of "HOLD" and "ACCEPTED" tag'umbers on applicable documents.

Nonconforming items, or missing or questionable documentation results in items being placed on "HOLD" and maintained in a designated, controlled area of the storeroom.

If the nonconformance cannot be cleared, the item is either scrapped, returned to manufacturer, or dispositioned through engineering analysis".

1.7.7.2.7 i

Contractors providing services (on-site) for safety-related components are required to have either a formal quality assurance program and procedures, or they must abide by the Cook Nuclear Plant gA Program and procedures.

Prior to their working at the Cook Nuclear Plant, contractor quality assurance programs must be audi ted and approved by AEPSC gA.

Contractor procedures must be reviewed and approved by the originating/sponsoring department h'eid.

Further, periodic audits of site contractor activities are conducted under the direction of the AEPSC equality Assurance Superintendent.

1.7.7.2.8 To the extent prescribed in specific procurement documents, suppliers furnish quality records; documentary evidence that material and equipment either conforms to requirements or identifies any requirements that have not been met; and descriptions of those nonconformances from the procurement requirements, which have been dispositioned "use-as-is" or "repair."

This evidence is retained at the Plant, or at the Service Corporation.

To the extent prescribed in specific procurement agreements, suppliers are required to maintain additional (backup) documents in their record system.

1.7-55

July, 1992

In some cases, such as with NSSS, suppliers are designated primary record retention responsibility.

1.7.7.2.9 The capability of suppliers to furnish valid documentation is evaluated during procurement document reviews, annual supplier evaluations, and during audits.

1.7.8 IDENTIFICATION AND CONTROL OF ITEMS 1.7.8.1 SCOPE Items 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.

1.7.8. 2 IMPLEMENTATION 1.7.8.2.1 Controls are established that provide for the identification and control of items (including partially fabricated assemblies).

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

The method of identification is such that the quality of the item is not degraded.

1.7.8.2.3 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.

1.7-56

July, 1992

1.7.8.2.4 Requirements for the identification by use of heat number, part number, serial number,'etc.,

are included in AEPSC Specifications (DCCs) and/or the procurement document.

1.7.8.2.5 Separate storage is provided for incorrect or defective items that are on hold and material which has been accepted for use.

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

Records are maintained for the issue of items to provide traceability from storage to end use in the Cook Nuclear Plant.

1.7.8.2.6 When materials are subdivided, appropriate identification numbers are transferred to each section of the material, or traceability is maintained through documentation.

1.7.9 1.7.9.1 CONTROL OF SPECIAL PROCESSES SCOPE Special processes are controlled and accomplished by qualified personnel using approved procedures and equipment in accordance with applicable

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

1.7.9.2 IMPLEMENTATION 1.7.9.2.1 1.7-57 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

July, 1992

cleaning, application of protective coatings, concrete placement and NOE.

1.7.9.2.2 Special process requirements for chemical cleaning, application of protective coatings and concrete placement are set forth in AEPSC Specifications (DCCs) and/or directives prepared by the responsible AEPSC cognizant engineer.

These documents are reviewed and approved by other personnel with the necessary technical competence.

AEPSC Specifications are audited by the AEPSC gA Division.

Special process requirements for welding, heat treating and NDE are set forth in AEPSC Specifications, the AEP Melding and NDE manuals and plant procedures.

These specifications and manuals are prepared by, or are reviewed and approved by, the AEPSC Cognizant Engineer Welding and NDE Administrator.

The administrative controls portion of the NDE Manual is audited by AEPSC gA.

Special process procedures, with the exception of welding and heat

treating, are prepared by Cook Nuclear Plant personnel with technical knowledge in the discipline involved.

These procedures, which are also reviewed by other personnel with the necessary technical competence, are qualified by testing.

Welding is performed in accordance with procedures contained in the AEP Melding Nanual, or by approved contractor's Koeedueis.

These procedures are qualified in accordance with applicable

codes, and Procedure gualification Records are prepared.

Weld Procedure gualification Records are reviewed and approved by the AEPSC Cognizant Engineer Welding.

Weld qualification documentation is'retained in the AEP Welding Manual, or the approved contractor's manual.

Contractor welding procedures are qualified by the contractor.

These procedures and the qualif cation documentation are reviewed and approved 1.7-58

July, 1992

by the AEPSC Cognizant Engineer Welding. -This documentation is retained by the contractor.

I.7.9.2e3 NDE personnel are qualified and certified by a Cook Nuclear Plant NDE Level III who has been qualified and certified by the designated gP$ 6 NDE Administrator.

Certification is by examination.

Personnel qualification is kept current by re-examination at time intervals speci fie

'fiiWqua15~ficatTon/ci iltsfgcatTonTproceduram.::w'hicli..arse in accordance with the ASME Code.

Cook Nuclear Plant welders are qualified by the Maintenance Department usinDWEP~SC! ipjirdved procedures.

Supervision of Cook Nuclear Plant welder qualifications is performed by the Maintenance Department.

Examination of specimens is performed under the supervision of the Safety and Assessment Department in accordance with the AEP Welding Manual covering welder qualifi.cation.

Cook Nuclear Plant welder qualification records are maintained for each welder by the Maintenance Department.

Contractor and craft welders are qualified by the

'ontractor using procedures approved by the AEPSC Cognizant Engineer Welding in accordance, with AEPSC procedures.

Contractor and craft

. welder qualification records are maintained by the contractor.

1.7.9.2.4 gC/NDE Technicians assigned to the Safety and Assessment Department perform nondestructive testing for work performed by Cook Nuclear Plant and contractor personnel.

These individuals are qualified to either SNT-TC-IA, or ANSI N45.2.6, and records of the qualifications/

certifications are maintained at Cook Nuclear Plant.

1.7.9.2.5 for special processes that require qualified equipment, such equipment is qualified in accordance with applicable

codes, standards and specifications.

1.7-59

July, 1992

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1.7.9.2.6 Special process qualifications are reviewed during regularly scheduled gA audits.

gual ificati on recor ds are maintained in accor dance with 1.7.17 herein.

1.7.9.2.7 The documentation resulting from welding and nondestructive testing is reviewed by appropriate personnel.

1.7. 10 INSPECTION 1.7.10.1 SCOPE Activities affecting the quality of safety-related structures, systems and components 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 inspection, process monitoring, or both, are used as necessary.

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

1.7.10.2 IMPLEMENTATION 1.7.10.2.1 Inspections are applied to appropriate activities to assure conformance to speci fied requirements.

Hold points are provided in the sequence of procedures to allow for the inspection, witnessing, examination, measurement, or review necessary to assure that the critical, or irreversible, elements of an activity are 1.7-60

July, 1992

being performed as required.

Note that hold points may not apply to all procedures, but each must be reviewed for this attribute.

Hold points specify exactly what is to be done {e.g., type of inspection or examination, etc.),

acceptance criteria, or reference to another procedure, etc., for the satisfactory completion of the hold point.

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

Process monitoring is used in whole, or in part, where direct inspection alone is impractical or inadequate.

1.7.10.2.2 Training, qualification and certification programs for personnel who perform inspections are established, implemented and documented in accordance with 1.7.2 herein and as described in Appendix B hereto, item 9b, with exceptions as noted therein.

1.7.10.2.3 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.

1.7-61

July, 1992

e)

Identification of personnel responsible for performing the inspection.

f)

Acceptance and rejection criteria.

g)

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

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o.FARejuNtii'yi~6kfdh~~L:;3'3,::~andgANSIgk4..:.".K 1.7.10.2.5 Inspections associated with the packaging and shipment of radioactive waste and materials are conducted using the following program:

a)

NRC Licensed Packa in s Inspections of NRC licensed radioactive material packagings shall be performed by individuals independent from the work being performed.

The independent inspectors shall be Indiana Michigan Power personnel, qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1, as a minimum.

Additionally, the inspector shall be familiar with the activities being performed.

Non-NRC Licensed Packa in s and Containers Inspections of non-NRC licensed radioactive material packagings and containers (shipping and/or burial) shall be performed by Indiana Michigan Power personnel, qualified in accordance with Regulatory Guide 18.

and ANSI N18.1, as a minimum.

c)

Trans ortation Vehicles Inspection of transportation vehicles being shipped as "exclusive use", shall be performed by Indiana Michigan Power personnel, qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1, as a minimum.

d)

Other ins ections and Verification Inspections and verifications of other activities associated with the packaging and shipment of radioactive materials and waste shanti

".e performed by Indiana and 1.7-63

July, 1992

Hichigan Power personnel, qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1, as a minimum.

1.7.10.2.6 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.

1.7.11 TEST CONTROL 1.7,.11.1 SCOPE Testing. i s performed in accordance with establ i shed programs to demonstrate that structures, systems and components will perform satisfactorily in service.

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

Types of tests are:

Scheduled Surveillance, preventive maintenance, post-design, qualification.

Unscheduled Pre-and post-maintenance.

Test parameters (including any prerequisites),

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

Test results are documented and evaluated.

1.7-64

July, 1992

1.7.11.2 IHPLEHENTATIOH 1.7.11.2.1 Tests are performed in accordance with programs, procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a) gualification tests, as applicable, to verify design adequacy.

b)

Acceptance tests of equipment and components to assure their operation prior to delivery or installation.

c)

Post-design tests to assure proper and safe operation of systems and equipment prior to unrestricted operation.

d)

Surveillance tests to assure continuing proper and safe operation of systems and equipment.

The PHI on surveillance testing

'll controls the periodic testing of equipment and systems to fulfi the surveillance requirements established by the Technical Specifications.

Controls have been established to identify uncompleted surveillance testing to assure it is rescheduled for completion to meet Technical Specification frequency requirements.

Oata taken during surveillance testing is reviewed by appropriate management personnel to assure that acceptance criteria is fulfilled, or corrective action is taken to correct deficiencies.

e)

Haintenance tests after preventive or corrective maintenance.

1.7.11.2.2 Test procedures.,

as required, provide mandatory hold points for witness or revi ew.

1.7-65

July, 1992

1.7. 11.2. 3

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

Al.l data resulting from these tests is retained at the Cook Nuclear Plant after review by appropriate management personnel.

1.7.12 CONTROL OF MEASURING AND TEST EQUIPMENT 1.7. 12. 1 SCOPE Measuring and testing equipment used in. 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 necessary limits.

1.7.12.2 IMPLEMENTATION 1.7.12.2.1

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h Established procedures and instructions are used for calibration and control of measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components.

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

AEPSC QA periodically assesses the effectiveness of the calibration program via the QA audit program.

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

1.7-66

July, 1992

1.7.12.2.3

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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.

1.7.12.2.4 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 and is authorized by the responsible manager.

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

The basis for acceptance is documented and authorized by the responsible manager.

1.7.12.2.5 Cook Nuclear Plant procedures define the requirements for the control of standards, test equipment and process equipment.

1.7.12.2.6 Mhen 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 1.7-67

July, 1992

results obtained since the most recent calibration.

Retests, or reinspections, are performed on suspect items.

The results of evaluations are documented.

1.7.13 HANDLING, STORAGE.

AND SHIPPING 1.7. 13. 1 SCOPE 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.

1.7.13. 2 IMPLEMENTATION 1.7.13.2.1 Procedures are used to control the cleaning, handling, storing, packaging, preserving and shi pping of materi al s, components and systems in accordance with designated procurement requirements.

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

a)

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

b) 'ackaging 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 co'ntent levels and temperature levels.

c)

Handling to preclude damage or safety hazards.

1.7-68

July, 1992

d)

Storing to minimize the possibility of loss, damage or deterioration of items in storage, including consumables such as chemicals, reagents and lubricants.

1.7.13.2.2 Controls have been established 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 in the Cook Nuclear Plant.

Controls are established in plant procedures.

1.7.13.2.3 Packaging and shipping requirements are provided to vendors

~f" AEPSC Specifications (DCCs) which are a part of the procurement~.document, or are otherwi se speci fied ~j'~4t'fie'~jrocuriei5<~+cQmeiit.

Controls for receipt inspection, damaged items and special handling requirements at the Cook Nuclear Plant are established by plant procedures.

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

1.7.13.2.4 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 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.

1.7.13.2.5 Special handling procedures have been implemented for the processing of nuclear fuel during refueling outages.

These procedures minimize the 1.7-69

July, 1992

risk of damage to the new and spent fuel and the possible release of radioactive material when placing the spent fuel into the spent fuel pool.

1.7.14 INSPECTION, TEST, ANO OPERATING STATUS 1.7.14.1 SCOPE Operating status of structures, systems and components 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.

1.7.14. 2 IMPLEMENTATION 1.7.14.2.1 For design change 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.

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

tests, or examinations.

Procedures exist which provide for the use of calibration and rejection

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

The Clearance Permit System uses various tags to identify equipment and system operability status.

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

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

1.7-70

July, 1992

1.7.14.2.2 Application and removal of inspection and welding stamps, and of such status indicators as tags, markings, labels, etc., is controlled by plant procedures.

The inspection status of materials received at the Cook Nuclear Plant is identified in accordance with established instructions.

The status is 1

identified as Hold, Hold for equality Control Clearance, Reject, or Accept.

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

Plant equality Control, or departmental ANSI

'N18.1 qualified personnel (reference 1.7.10.2.4 herein), inspect an activity at various stages and sign off the procedural inspection steps.

The status of welding is controlled through the use of a weld data block which identifies the inspection and NDE status of each weld.

1.7.14.2.3 Required surveillance test procedures are defined in PHIs.

These instructions provide for documenting bypassed tests and rescheduling of the test.

The status of testing after minor maintenance is recorded as part of the Job Order.

The status of testing after major maintenance is included as part of the procedure, and includes the performance of functional testing and approval of data by supervisory personnel.

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

The PMI for plant procedures requires that procedures be followed as written.

Alteration to the sequence of a procedure can only be accomplished by a procedure change which is subject to the same controls 1.7-71

July, 1992

as the original review and approval.

When an immediate procedure change is required to continue in-process work or testing and the required complete review and approval process cannot be accomplished, an "On The Spot" change is processed in accordance with the PHI on plant procedures.

1.7.14.2.4 Nonconforming, inoperable, or mal functioning structures, systems and components are clearly identified by tags, stickers, stamps, etc.,

and documented to prevent inadvertent use.

1.7. 15 NONCONFORHING ITEHS 1.7.15.1 SCOPE Haterials, parts, or components that do not conform to requirements are controlled in order to prevent their inadvertent use.

Nonconforming items are identified, documented, segregated when practical and dispositioned.

Affected organizations are notified of nonconformances.

1.7. 15. 2 IHPLEHENTATION 1.7.35.2.1 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.

Personnel authorized to disposition, conditionally release and close out nonconformances are designated.

The Job Order System and/or'the Condition/Problem Reports (refer to 1.7. 16 herein) are used at Cook Nuclear Plant to identify nonconforming items and initiate corrective action for items which are installed or have been released to the Cook Nuclear Plant.

Systems, components, or 1.7-72

July, 1992

materials which require repair or inspection are controlled under the Job Order System.

In addition, the various procedures identified in 1.7.14 herein provide for identification, segregation and documentation of nonconforming items.

1.7.15.2.2 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.

Completed Job Orders are reviewed by the supervisor responsible for accomplishing the work, and the supervisor of the department/section that originated the Job Order.

The gA Division periodically audits the Job Order System, and on a sample basis, Job Orders.

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Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements, or alternatives, 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, surveillance or operability tests are conducted on an item after rework, repair or replacement.

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

1.7-73

July, 1992

1.7. 16 CORRECTIVE ACTION 1.7.16.1 SCOPE Conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are identified promptly and corrected as soon as practical.

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 documented and reported to appropriate levels of management.

1.7.16. 2 IMPLEMENTATION 1.7.16.2.1 Procedures are established that describe the plant and AEPSC corrective action programs.

These procedures are reviewed and concurred with by the AEPSC gA Division.

1.7.16.2.2 Condition/Problem Reports -provide the mechanism for plant and AEPSC personnel to notify management of conditions adverse to quality.

Condition/Problem Reports are also used to report violations to codes, regulations and the Technical Specifications.

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

The Condition/Problem Report is used to document the investigation of a problem; and to identify the need for a design change to correct system or equipment deficiencies, or to identify the need for the initiation of Job Orders to correct minor deficiencies.

Further, Condition/Problem Reports are used to identify those actions necessary to prevent recurrence of the reported condition.

1.7-74

July, 1992

Significant problems, which are so designated on Condition/Problem

Reports, are reviewed by the PNSRC for evaluation of actions taken, or being 'aken,

.'o correct the deficiency and prevent recurrence.

The AEPSC NSDRC is responsible for assuring that independent reviews of violations (as specified in the Technical Specifications) are performed.

These violations are considered significant problems which are documented on Condition/Problem Reports.

The reviews will provide an independent evaluation of the reported problems and corrective actions.

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

1.7.17 EQUALITY ASSURANCE RECORDS 1.7. 17. 1 SCOPE Records that furnish evidence of activities affecting the quality of safety-related structures, systems and components are maintained.

They are accurate, complete, legible and are protected against

damage, deterioration, or loss.

They are identifiable and retrievable.

1.7.17.2 IHPLBlEMTATION 1.7.17.2.1 Documents that furnish evidence of 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:

a) b)

c) d)

Results of reviews,'nspections, surveillances,

tests, audits and material analyses.

gualification of personnel, procedures and equipment.

Operation logs.

Maintenance and modification procedures and related inspection results.

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e) f)

g) h)

Reportable occurrences.

Records required by the plant Technical Specifications.

Problem Reports.

Other documentation such as drawings, specifications, dedication

plans, procurement documents, calibration procedures and reports.

Radiographs.

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

Criteria for the storage location of quality related records, and a retention schedule for these

records, has been established.

File Indexes have been established to provide direction for filing, and to provide for the retrievability of the records.

. Controls have been established for limiting access to the Plant Paster

~ File to prevent unauthorized entry, unauthorized

removal, and for use of the records under emergency conditions.

The NcoecgHanajement Supervisor is responsible for the control and operation of the Plant Master File Room.

1.7.17.2.3 Within AEPSC, each department/division manager is responsible for the identification, collection, maintenance and storage of records generated by their department/division.

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

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July, 1992

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.

1.7.17.2.5 Only authorized personnel may issue corrections or supplements to records.

1.7.17.2.6 Traceability between the record and the item or activity to which it applies is provided.

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Except for records that can only be stored as originals, such as radiographs and some strip charts, or micrographs thereof, records are stored in remote, dual facilities to prevent

damage, deterioration, or loss due to natural or unnatural causes.

When only the single original can be retained, special fire-rated facilities are used.

1.7.18 AUDITS 1.7. 18. 1 SCOPE A comprehensive system of audits is carried out to provide independent evaluation of compliance with, and the effectiveness of, the gA Program, including those elements of the program implemented by suppliers and contractors.

Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited.

Audit results are documented and reviewed by management.

Follow-up action is taken where indicated.

1.7-77

1.7. 18. 2 IMPLEMENTATION

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1.7.18.2.1 AEPSC A Division Res onsibilities The basic responsibility for the assessment of the gA Program is vested in the AEPSC gAO.

The AEPSC gAD is primarily responsible for ensuring that proper gA programs are established and for verification of their implementation.

These responsibilities are discharged in cooperation with the AEPSC and Cook Nuclear Plant management and their staffs..

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

All areas where the requirements of 10CFR50, Appendix B

apply are audited within a period of one to two years.

1.7.18.2.3

~

~

~

~

The AEPSC gAO conducts audits to verify the adequacy and implementation of the gA Program at the Cook Nuclear Plant and within the AEP System.

~

gA audit reports are distributed to ~We appropriate management and the NSDRC (all audits).

1.7.18.2.4 The independent off-site review and audit organization is the AEPSC NSDRC.

This committee is composed of AEPSC, I&A and Cook Nuclear Plant management members.

An NSORC Manual has been developed for this committee which contains the NSDRC Charter and procedures.

The NSDRC conducts periodic audits of Cook Nuclear Plant operations pursuant to established criteria (Technical Specifications, etc.).

NSDRC audit reports are submitted for review to the NSDRC membership, the Chairman of the NSDRC, and the AEPSC Senior Executive Vice President 1.7-78

July, 1992

Engineering and Construction.

Problem Reports provide for the recording of actions taken to correct deficiencies found during these audi ts.

1.7.18.2.5 The Cook Nuclear Plant on-site review group is the PNSRC.

This committee reviews plant operations as a routine evaluation and serves to advise the Plant Manager on matters related to nuclear safety.

The composition of the committee is defined in the Technical Specifications.

The PNSRC also reviews instructions, procedures, and design changes for safety-related systems prior to approval by the Plant Manager.

In addition, this committee serves to conduct investigations of violations to Technical Specifications, and reviews significant Problem Reports to determine if appropriate action has been taken.

1.7.18.2.6

~

~

Audits of suppliers and contractors 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, construction, installation, inspection and testing.

Principal contractors are required to audit their suppliers systematically in accordance with the criteria established within their quality assurance programs.

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

1.7-79

July, 1992

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

1.7.18.2.9 Audit procedures and the scope, plans, checklists and results of individual audits are documented.

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

1.7.18.2.11 Management of the audited organization identifies and takes appropriate action to correct observed deficiencies and to prevent recurrence.

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

Such follow-up includes reaudits, when necessary.

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

The following activities constitute formal elements of that assessment:

1.7-80

July, 1992

a)

Audit reports, including follow-up on corrective action accomplishment,and effectiveness, are distributed to appropriate

evels of management.

b)

Individuals independent from the QA organization, but knowledgeable in auditing and quality assurance, periodically review the effectiveness of the QA Programs.

Conclusions and recommendations are reported to the AEPSC Vice President Nuclear Operations.

1.7.19 FIRE PROTECTION QA PROGRN 1.7. 19.1 Introduction The Cook Nuclear Plant Fire Protection QA Program has been developed using the guidance of NRC Branch Technical Position (APCSB) 9.5-1, Appendix A, Section C, "Quality Assurance Program,"

and NRC clarification "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance,"

dated June 14, 1977.

As such, the Fire Protection QA Program is part of the overall QA Program for the plant.

The Fire Protection QA Program encompasses

design, procurement, fabrication, construction, surveillance, inspection, operation, maintenance, modification, and audi ts.

Implementation and assessment of the Fire Protection QA Program is the responsibility of each involved AEPSC and Indiana Michigan Power Company organization.

1. 1. 19. 2 The Fire Protection QA Program is under the management control of AEPSC.

This control consists of:

1.7-81

July, 1992

1)

Verifying the effectiveness of the Fire Protection gA Program through review, surveillance, and audits.

2)

Directing formulation, implementation, and assessment of the Fire Protection gA Program by procedural controls.

3)

Assuring the gA program is acceptable to the management responsible for fire protection.

The Plant Manager has delegated responsibility to various Cook Nuclear Plant departments for the following fire protection activities:

a) b)

c) d)

e) f)

g)

Maintenance of fire protection systems.

Testing of fire protection equipment.

Fire safety inspections.

Fire fighting procedures.

Fire dr ills.

Emergency remote shutdown procedures.

Emergency repair procedures (10CFR50, Appendix R).

The Fire Protection gA Program at the Cook Nuclear Plant also provides for inspection of fire hazards, explosion hazards, and training of fire brigade and responding fire departments.

The.Safety.".:ta're::::A'sseMTiTeTif,":.OFp'ii tN7iVi't~s'Fir@!ProtY44"oi Shi ft upervi sor on duty, or designee, is designated as the Fire Brigade Leader and coordinates the fire fighting efforts of shift personnel and the Fire Br'gade.

iTTii0gie:,:e::stidessg'a'r'tleei::

resides::""ae-:";fedidtdflaT::,:withej~aTil gt stees":kiieiii7edge: te;"'terse:.as as%addi;:ser':::ter'tjietK>rsese Br' drata~ace ie 1.7. 19.3 Desi n Control and Procurement Document Control guality standards are specified in the design documents such as appropriate fire protection codes and standards,

and, as necessary, deviations and changes from these quality standards are controlled.

1.7-82

July, 1992

I C

I 1

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The Cook Nuclear Plant design was reviewed by qualified personnel to en ure inclusion

.'F appropriate fire protection requirements.

These reviews include items such as:

1)

Verification as to the adequacy of electrical isolation and cable separation criteria.

2)

Verification of appropriate requirements for room isolation (sealing penetrations, floors and other fire barriers).

3)

Determination for increase in fire loadings.

4)

Determination for the need of additional fire detection and suppression equipment.

Procurement of fire protection equipment and related items are subject to the requirements of the fire protection procurement documents.

A review of these documents is performed to assure fire protection requirements and quality requirements are correctly stated, verifiable, and controllable, and that there is adequate acceptance and rejection criteria.

Procurement documents must be prepared,

reviewed, and approved according to gA Program requirements.

Design and procurement document

changes, including field changes and design deviations, are controlled by procedure.

1.7.19.4 Instructions Procedures and Drawin s Inspections,

tests, administr ative controls, fire drills and training that assist in implementing the fire protection program are prescribed by approved instructions or procedures.

July, 1992 Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with approved procedures.

Activities associated with the fire protection systems and fire 1.7-83

protection related systems are prescribed and accomplished in accordance with documented instructions, procedures, and dr awings.

Instructions and procedures for design, insta!lation, inspection, tests, maintenance, modification '.nd administrative controls are reviewed through audits to assure that the fire protection program is maintained.

Operation and maintenance information has been provided to the plant in the form of System Descriptions and equipment supplier information.

1.7.19.5 Control of Purchased Items and Services Heasures are established to assure that purchased items and services conform to procurement docume'nts.

These measures include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspections at suppliers, or receipt inspection.

Source or receipt inspection is provided, as a minimum, for those items where quality cannot, be verified after installation.

1.7.19.6

~Ins ection A program for independent inspection of the fire protection activities has been established and implemented.

These inspections are performed by personnel other than those responsible for implementation of the activity.

The inspections include:

a)

Inspection of installation, maintenance and modification of fire protection systems and equipment.

b)

Inspections of penetration seals and fire retardant coating installations to verify the activity is satisfactorily completed in accordance with installation specifications.

1.7-84

c)

Inspections of cable routing to verify conformance with design requi rements as speci fied in AEPSC Speci ficati ons and/or pl ant procedures.

d)

Inspections to verify that appropriate requirements for fire barriers are satisfied following installation, modification, repair or replacement activities.

e)

Measures to assure that inspection personnel are independent from the individuals performing the activity being inspected and are knowledgeable in the design and installation requirements for fire protection.

f)

Inspection procedures, instructions or checklists for required inspections.

g)

Periodic inspections of fire protection systems, emergency breathing and auxiliary equipment.

h)

Periodic inspections of materials subject to degradation, such as fire stops, seals and fire retardant coating as required by Technical Specifications or manufacturer's recommendations.

1.7.19.7 Test and Test Control a)

Installation testing Following installation, modification, repair, or replacement, sufficient testing is performed to demonstrate that the fire protection systems and equipment will perform satisfactorily.

Written test procedures for installation tests incorporate the requirements and acceptance limits contained in applicable design documents.

b)

Periodic testing Periodic testing occurs to document that fire protection equipment functions in accordance with its design.

1.7-85

July, 1992

1,

c)

Programs have been established to verify the testing of fire protection systems, and to verify that test personnel are effectively trained.

d)

Test results are documented, evaluated, and their acceptability determined by a qualified responsible individual or group.

1.7.19.8 Ins ection Test and 0 eratin Status The inspection, test and operating status for plant Technical Specification fire protection systems are performed as described in 1.7.14 herein.

1.7. 19.9 Nonconformin Items Technical Specification fire protection equipment nonconformances are identified and dispositioned as described in 1.7.15 herein.

1.7. 19. 10 Corrective Action The corrective action mechanism described in 1.7.16 herein applies to the Technical Specification fire protection equipment.

1.7.19.11 Records Records generated to support the fire protection program are controlled as described in 1.7. 17 herein.

1.7. 19. 12 Audits Audits are conducted and documented to verify compliance with the Fire Protection gA Program as described in 1.7.1.18 herein.

Audits are periodically performed to verify compliance with the administrative controls and implementation of fire protection quality 1.7-86

July, 1992-

r

assurance criteria.

The audits are performed in accordance with pre-established written procedures or checklists.

Audit results are documented and reviewed by management having responsibility in the area audited.

Follow-up action is taken by responsible management to correct the deficiencies revealed by the audit.

1.7-87

July, 1992

1

~

AMERICANELECTRIC P R SERVICE CORPORATION Support Organization for the Cook Plant CHAIRMANOF THE BOARD AND CHIEF EXECUTIVEOFFICER

+ PRESIDENT AND CHIEF OPERATING OFFICER SENIOR EXECUTIVE VICE PRESIDENT ENGINEERING AND CONSTRUCTION I

CO 00 DIRECTOR QUALITY ASSURANCE VICE PRESIDENT NUCLEAR OPERATIONS VICE PRESIDENT PROJECT MANAGEMENT AND CONSTRUCTION OTHER AEPSC ENGINEERING/DESIGN SUPPORT OTHER AEPSC SUPPORT QUALITY-ASSURANCE DIVISION NUCLEAR OPERATIONS DEPARTMENT PROJECT MANAGEMENT AND CONSTRUCTION DEPARTMENT

~NOTE S NUCLEAR ENGINEERING DEPARTMENT PLANTMANAGER COOK NUCLEAR PLANT SITE CONSTRUCTION MANAGER LEGEND ll

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~ 'OT PART OF AEPSG ORGANIZATION-SHOWN FOR INFORMATIONONLY

+ EFFECTIVE MARCH 1, 1992 ADMINISTRATIVEAND FUNCTIONALDIRECTION FUNCTIONALDIRECTION FOR THE COOK NUCLEAR PLANT

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American Electric Power Company AMERICAN ELECTRIC POWER COMPANY American Electric Power Service Corporation I

I CO LD Appalachian Power Company Ohio Power Company Indiana Michigan Power Com an Columbus Southern Power Com an Kingsport Power Company Kentucky Power Company Michigan Power Company Wheeling Power Company

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Cook Nuclear Plant administrative, technical, and functional direction

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)Gn "S 'i; Jointly owned with Buckeye Power, Inc.

generating subsidiary tQI R

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ORGANIZATIONAL RELATIONSHIPS WITHIN THE AMERICAN ELECTRIC POWER SYSTEM PERTAINING TO QUALITY ASSURANCE AND QUALITY CONTROL SUPPORT OF THE COOK NUCLEAR PLANT Fi~fure No. 1.7-3 CHAIRMAN OF THE BOARD AND CHIEF EXECUTIVE OFFICER AEPSC, INDIANAMICHIGANPOWER COMPANY AND OTHER AEP SUBSIDIARIES

+ PRESIDENT AND CHIEF OPERATING OFFICER AEPSC, AND VICE PRESIDENT AND DIRECTOR INDIANAMICHIGANPOWER COMPANY ANDOTHER AEP SUBSIDIARIES SENIOR EXECUTIVE VICE PRESIDENT ENGINEERING &CONSTRUCTION AEPSC, AND VICE PRESIDENT, INDIANA MICHIGAN POWER COMPANY VICE PRESIDENT NUCLEAR OPERATIONS AEPSC AND VICE PRESIDENT, INDIANA MICHIGAN (MANAGER OF NUCLEAR OPERATIONS)

DIRECTOR QUALITY ASSURANCE AEPSC NUCLEAR OPERATIONS 8 NUCLEAR ENGINEERING DEPARTMENTS OTHER AEPSC DEPARTMENTS I

I-I I

PLANT MANAGER COOK NUCLEAR PLANT 1

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QUALITY ASSURANCE SUPERINTENDENT (ON SITE) AEPSC SAFETY 8 ASSESSMENT SUPERINTENDENT NOTES

+ EFFECTIVE MARCH 1, 1992 LEGEND Administrative and functional direction Technical direction

...... Technical liaison Funcbonal direction for Cook Nudear Plant Activities 1.7-90

July, 1992

AEPSC QUALITYASSURANCE DIVISIONORGANIZATION AEPSC DIRECTOR QUALITYASSURANCE SECTION MANAGER QUALITYASSURANCE SUPPORT SECTION MANAGER AUDITSAND PROCUREMENT SECTION MANAGER QUALITYASSURANCE ENGINEERING SECTION MANAGER NUCLEAR SOFTWARE QUALITYASSURANCE QUALITYASSURANCE SUPERINTENDENT (SITE)

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Organization for the Cook Nuclear Plant Indiana Michigan Power Company Plant Manager Executive Staff Assistant Plant Safety Chairman Assistant Plant Manager Production Assistant Plant Manager Technical Support Assistant Plant Manager Projects Accounting and Budget Manager Operations Superintendent Radiation Protection Su rlntendent Integrated Scheduling Superintendent Safety and Assessment Superintendent Quality Control/NDE Maintenance Superintendent

.Plant Engineering Superintendent Computer Sciences Superintendent Administrative Superintendent Ca tD lO EO Stores

. Supervisor Chemistry Superintendent Emergency Planning Coordinator Site Construction Manager Nuclear Security Manager Training

'Superintendent Human Resources Supervisor

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APPENDIX A REGULATORY AND SAFETY GUIDES ANSI STANDARDS 1.

Reg.

Guide 1.8 (9/75)

ANSI N18.1 (1971)

Personnel Selection and Training Selection and Training of Nuclear Power Plant Personnel 2.

Reg.

Guide 1.14 (8/75)

Reactor Coolant Pump Flywheel Integrity 3.

Reg.

Guide 1.16 (8/75)

Reporting of Operating Information, Appendix A Technical Specifications 4.

Safety Guide 30 (8/72)

ANSI N45.2.4 (1972).

equality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment'uring the Construction of Nuclear Power Generating Stations 5.

Reg.

Guide 1.33 (02/78)

ANSI N18.7 (1976)

(ANS 3.2 1976)

ANSI N45.2 (1977) equality Assurance Program Requirements (Operation)

Administrative Controls and equality Assurance for the Operational Phase of Nuclear Power Plants equality Assurance Program Requirements for Nuclear Facilities 1.7-93

July, 1992

6.

Reg.

Guide 1.37 (3/73)

ANSI N45.2.1 (1973) equality Assurance Requirements for Cleaning of Fluid Systems and'ssociated Components of Mater-Cooled Nuclear Power Plants Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power

.Plants 7.

Reg.

Guide 1.3 (10/76)

ANSI N45.2.2 (1972) equality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase) 8.

Reg.

Guide 1.39 (10/76)

ANSI N45.2.3 (1973)

Housekeeping Requirements for Water-Cooled Nuclear Power Plants Housekeeping During the Construction Phase of Nuclear Power Plants 9.

Reg.

Guide 1.54 (6/73)

ANSI N101.4 (1972) equality Assurance Requirements for Protective, Coatings Applied to Water-Cooled Nuclear Power Plants equality Assurance for Protective Coatings Applied to Nuclear Facilities 10.

Reg.

Guide 1.58 (9/0) qualification of Nuclear Power Plant

, Inspection, Examination and Testing Personnel 1.7-94

July, 1992

ANSI N45.2.6 (1978) gualifications of Inspection, Exami-

nation, and Testing Personnel for Nuclear Power Plants 11.

Reg.

Guide 1.63 (7/78)

Electric Penetration Assemblies in Containment Structures for Light-Water-Cooled 'Nuclear Power Plants 12.

Reg.

Guide 1.64 (10/73)

ANSI N45.2.11 (1974)-

guality Assurance Requirements for the Design of Nuclear Power Plants guality Assurance Requirements for the Design of Nuclear Power Plants 13.

Reg.

Guide 1.74 (2/74)

ANSI N45.2.10 (1973) guality Assurance Terms and Definitions guality Assurance Terms and Definitions 14.

Reg.

Guide 1.88 (10/76)

ANSI N45.2.9 (1974)

Collection, Storage, and Maintenance of Nuclear Power Plant guality Assurance Records Requirements for Collection,

Storage, and Maintenance of guality Assurance Records for Nuclear Power Plants 15.

Reg.

Guide 1.94 (4/76) equality Assurance. Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants 1.7-95

July, 1992

ANSI N45.2.5 (1974)

Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants 16.

Reg.

Guide 1.108 (/77)

Peri odi c Testing of Diese1 Generator Units used as Onsi te Electri c Power Systems at Nuclear Power Plants 17.

Reg.

Guide 1.123 (7/77)

ANSI N45.2.13 (1976)

Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 18.

Reg.

Guide 1.144 (1/79)

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ANSI N45.2.12 (1977)

Auditing of Quality Assurance Programs for Nuclear Power Plants Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 19.

Reg.

Guide 1.146 (8/80)

ANSI N45.2.23 (1978)

Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 1.7-96

July, 1992

20.

ANSI N45.2.8 (1975)

Supplementary guali ty Assurance Requirements for Installation; Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants 21.

ANSI N45.4 (1972)

Leakage-Rate Testing of Containment Structures for Nuclear Reactors 1.7-97

July, 1992

APPENDIX B AEPSC/IKH EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES 1.

GENERAL Certain Regulatory Guides invoke, or imply, Regulatory Guides and standards in addition to the standard each primarily endorses.

Certain ANSI Standards invoke, or imply, additional standards.

2.

Exce tion Inter retation The AEPSC/ISM commitment refers to the Regulatory Guides and ANSI Standards specifically identified in Appendix A.

Additional Regulatory

Guides, ANSI Standards and similar documents implied, or referenced, in those specifically identified are not part of this commitment.

I N18.7, General Exce tion Inter retation AEPSC and IM have established both an on-site and off-site standing committee for independent review activities; together they form the independent review body.

The standard numeric and qualification requirement may not be met by each group individually.

Procedures will be established to specify how each group will be involved in review activities.

This exception/interpretation is consistent with the plant's Technical Specifications.

1.7-98 July, l992

2a.

Sec.

4.3.1

~ll "Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas:...."

Exce tion Inter retation AEPSC Nuclear Safety and Design Review Committee (NSDRC) and Plant Nuclear Safety Review Committee (PNSRC) will not have members specified by number, nor by technical disciplines, and its members may not have the experience and competence required to review problems in all areas listed in this section.

This exception/interpretation is consistent with the plant's Technical Specifications.

The NSDRC and PNSRC will not specifically include a member qualified in nondestructive testing, but will use qualified technical consultants to perform this and other functions as determined necessary by the respective committee chairman.

2b.

Sec. 4.3.2.1 "When a standing committee is responsible for the independent review program, it shall be composed of no less than five persons of whom no more than a minority are members of the on-site operating organization.

Competent alternates are permitted if designated in advance.

The use of alternates shall be restricted to legitimate absences of principals."

Exce tion Inter retation See Item 2a.

1.7-99

July, 1992

2c.

Sec. 4.3.3.1 Re uirement

"... recommendations

... shall be disseminated promptly to appropriate members of management having responsibility in the area reviewed."

Exce tion Inter retation Recommendations made as a result of review will generally be conveyed to the on-site, or off-site, standing committee.

Procedures will be maintained specifying how recommendations are to be considered.

2d.

Sec. 4.3.4 Re uirement "The following subjects shall be reviewed by the independent review body:...."

Exce tion Inter retation Subjects requiring review wi 11 be as specified in the plant Technical Specifications.

2e.

Sec. 4.3.4(3)

'Changes in the Technical Specifications or License Amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change."

Exce tion Inter retation Although the usual practice is to meet this requirement, exceptions are made to NSDRC review and approval prior to implementation in rare cases with the permission of the NSDRC Chairman and Secretary.

PNSRC review and approval is always done prior to implementation of Technical Specification changes.

1.7-100

July, 1992

2f.

Sec.

4.4 Re uirement "The on-site operating organization shall provide, as part of the normal duties of plant supervisory personnel Exce tion Inter retation Some of the responsibilities of the on-site operating organization described in Section 4.4 may be carried out by the PNSRC and/or NSDRC as described in plant Technical Specifications.

2g.

Sec.

5.2.2 "Temporary changes, which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures.

At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operator's license on the unit affected."

Exce tion Inter retation I8N considers that this requirement applies only to procedures identified in plant Technical Specifications.

Temporary changes to these procedures shall be approved as described in plant Technical Specifications.

2h.

Sec.

5.2.6 Re uirement "In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14.

Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfilltheir intended safety. functions."

Exce tion Inter retation IM initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which is a 1.7-101

July, 1992

C l

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41 e

Ei gj,

requirement to veri fy equipment acceptability.

This action includes a

technical evaluation of the equipment's operability status.

2i.

Sec.

5.2.

R~i "A surveillance testing and inspection program... shall include the establishment of a master surveillance schedule reflecting the status of all planned in-plant surveillance tests and inspections."

Exce tion Inter retation Separate master schedules may exist for different programs, such as ISI, pump and valve testing, and Technical Specification surveillance testing.

2j.

Sec.

5.2.13.1 "To the extent necessary, procurement documents shall require suppliers to provide a guality Assurance Program consistent with the pertinent requirements of ANSI N45.2 1977."

Exce tion Inter retation To the extent necessary, procurement documents require that the supplier

'has a documented guality Assurance Program consistent with the pertinent requirements of 10CFR50, Appendix B; ANSI N45.2; or other nationally recognized codes and standards.-

2k.

Sec.

5.2.13.2 R~i ANSI N18.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

Exce tion Inter retati on The required documentary evidence is available at the site prior to use, but not necessarily prior to installation.

This allows installation to 1.7-102

July, 1992

proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

21.

Sec.

5.2.15 II "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

Exce tion Inter retation Biennial reviews are not performed in that IN has programmatic control requirements in place that make the biennial review process redundant from a regulatory perspective.

These programmatic controls were effected in an effort to ensure that plant instructions and procedures are reviewed for possible revision when pertinent source material is revised, therefore maintaining the procedures current.

We believe that this

approach, in addition to an annual random sampling of procedures, better addresses the intent of the biennial review process and is more acceptable from both a technical and practical perspective than a static two-year review process.

2m.

'Sec.

5.2.16 Records shall be made, and equipment suitably marked, to indicate calibration status.

Exce tion Inter retation See Item 6b.

1.7-103

July, 1992

2n.

Sec.

5.3.5(4)

This section requires that where sections of documents such as vendor

manuals, operating and maintenance instructions, or drawings are incorporated directly, or by reference into a maintenance procedure, they shall receive the same level of review and approval as operating procedures.

Exce tion Inter retation Such documents are reviewed by appropriately qualified personnel prior to use to ensure that, when used as instructions, they provide proper and adequate information to ensure the required quality of work.

Haintenance procedures which reference these documents receive the same level of review and approval as operating procedures.

3.

N45.2.1, 3a.'ec.

3

~ll N45.2.1 establishes criteria for classifying items into "cleanliness levels,"

and requires that items be so classified.

~Exce tion Inter retation Instead of using the cleanliness level classification system of N45.2.1, the required cleanliness for specific items and activities is addr'essed on a case-by-case basis.

Cleanliness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material.

As a minimum, cleanliness inspections are performed prior to closure of "nuclear" systems and equipment.

Such inspections are documented.

1.7-104

July, 1992

3b.

Sec.

5 "Fitting and tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed."

Exce tion Inter retation IN sometimes uses other nonhalogenated

material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection.

4.

N45.2.2, General N45.2.2 establishes requirements and criteria for classifying safety related items into protection levels.

Exce tion Inter retation Instead of classifying safety related items into protection levels, controls over the packaging,

shipping, handling and storage of such items are established on a case-by-case basis with due regard for the item's complexity, use and sensitivity to damage.

Prior to installation or use, the items are inspected and serviced, as necessary, to assure that no

. damage or deterioration exists which could affect their function.

4a.

Sec. 3.9 and Appendix A3.9

~lt "The item and the outside of containers shall be marked."

(Further criteria for mar king and tagging are given in the Appendix.)

Exce tion Inter retation These requirements were originally written for items packaged and shipped to construction projects.

Full compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, 1.7-105 July,. 1992

increase the probability of damage to the item.

The requirements are implemented to the extent necessary to assure traceabi lity and integrity of the item.

4b.

Sec.

5.2.2 "Receiving inspections shall be performed in an area equivalent to the level of storage."

Exce tion Inter retation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item.

However, such inspections are performed in a manner and in an environment which do not endanger the required quality of the item.

4c.

Sec. 6.2.4

~lt "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted."

Exce tion Inter retation

~ Packaged food for emergency or extended overtime use may be stored in material stock rooms.

The packaging assures that materials are not contaminated.

Food will not be*"used" in these areas.

4d.

Sec. 6.3.4 "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."

Exce tion Inter retation See N45.2.2, Section 3.9 (Exception 4b.).

1.7-106

July, 1992

4e.

Sec. 6.4.1

~ll "Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its container

... is being maintained."

Exce tion Inter retation The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule.

Instead, the inspections and examinations are performed in accordance with material storage procedures which identify the characteristics to be inspected and include the required frequencies.

These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.

5.

N45.2.3, 5a.

Sec.

2.1 Cleanliness requirements for housekeeping activities shall be established on the basis of five zone designations.

fxce tion Inter retation Instead of the five-level zone designation system referenced in ANSI N45.2.3, 18M bases its controls over housekeeping activities on a

consideration of what is necessary and appropriate for the activity involved.

The controls are effected through procedures or instructions.

Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control and security.

The procedures and instructions make use of standard janitorial and work practices to the extent possible.

However, in preparing these procedures, consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3.

1Property "ANSI code" (as page type) with input value "ANSI N45.2.3.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..7-107

July, 1992

~

~

~

~

6.

N45.2.4, 6a.

Sec.

2.2

~R Section 2.2 establishes prerequisites which must be met before the installation, inspections and testing of instrumentation and electrical equipment may proceed.

These prerequisites include personnel qualification, control of design, conforming and protected materials and availability of speci fied documents.

Exce tion Inter retation During the operations

phase, this requirement is considered to be applicable to modifications and initial start-up of electrical equipment.

For routine or periodic inspection and testing, the prerequisite conditions will be achieved, as necessary.

6b.

Sec.

6.2.1

~ll "Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed cal ibrati on."

~ Exce tion Inter retation Frequently, physical size and/or location of installed plant instrumentation precludes attachment of calibration labels or tags.

Instead, each instrument is uniquely identified and is traceable to its calibration record.

A scheduled calibration program assures that each instrument's calibration is current.

7..

N45.2.5, 7a.

Sec. 2.5.2 Re uirement "Mhen discrepancies, malfunctions or inaccuracies in inspection and testing equipment are found during calibration, all items inspected with 1.7-108

d

that equipment since the last previous calibration shall be considered unacceptable until an evaluation has been made by the responsible authori ty and appropri ate acti on taken. "

Exce tion Inter retation I&M uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section 2.5.2.

The N18.7 requirements are more applicable to an operating plant.

7b.

Sec.

5.4 1l "Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more often if deemed necessary.

Impact torque wrenches used for inspection must be calibrated at least twice daily."

Exce tion Inter retation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16.

Calibration intervals are, based on use and calibration history rather than as per N45.2.5.

8.

N45.2.6, Sec.

1.2 "The requirements of this standard apply to personnel who perform inspections, examinations and tests during fabrication prior to or during receipt of items at the construction site, during construction, during preoperational and start-up testing and during operational phases of nuclear power plants."

Exce tion Inter retation Personnel participating in testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6, but need only be trained to the extent necessary to perform the assigned function.

1.7-109

July, 1992

'e

. Guide 1.58 General

~R gualification of nuclear power plant inspection, examination and testing personnel.

9a.

C.2.a(7)

~R Regulatory Guide 1.5 endorses the guidelines of SNT-TC-1A as an acceptable method of training and certifying personnel conducting leak tests.

Exce tion Inter retation ISH takes the position that the "Level" designation guidelines as recommended in SNT-TC-lA, paragraph 4 do not necessarily assure adequate leak test capability.

18H maintains that departmental supervi sors are best able to judge whether engineers and other personnel are qualified to direct and/or perform leak tests; Therefore, IEH does not implement the recommended "Level" designation guidelines.

It is IM's opinion that the training guidelines of SNT-TC-IA, Table I-G, paragraph 5.2 specifically are oriented towards the basic physics

~involved in leak testing, and further, towards individuals who are not graduate engineers.

IN maintains that it meets the essence of these training guidelines.

The preparation of leak test procedures and the conduct of leak tests at Cook Nuclear Plant is under the direct supervision of Performance Engineers who hold engineering degrees from accredited engineering schools.

The basic physics of leak testing have been incorporated into the applicable test procedures.

The review and approval of the data obtained from leak tests is performed by department supervisors who are also graduate engineers.

1.7-110

July, 1992 IN does recognize the need to assure that individuals involved in leak tests are fully cognizant of leak test procedural requirements and thoroughly familiar with the test equipment involved.

Plant performance engineers receive routine,.informal orientation on testing programs to-

t.

ensure that these individuals fully understand the requirements of performing a leak test.

9b.

C5, C6, C7, C,

C10 Exce tion Inter retation IKN takes the position that the classification of inspection, examination and test personnel (inspection personnel) into "Levels" based on the requirements stated in Section 3.0 of ANSI N45.2.6 does not necessarily assure adequate inspection capability.

IM maintains that departmental and first line supervisors are best able to judge the inspection capability of the personnel under their supervision, and that "Level" classification would require an overly burdensome administrative work load, could inhibit inspection activities, and provides no assurance of inspection capabilities.

Therefore, IEN does not implement the "Le'vel" classification concept for inspection, examination and test personnel.

The methodology under which inspections, examinations and tests are conducted at the Cook Nuclear Plant requires the involvement of first line supervisors, engineering personnel, departmental supervisors and plant management.

In essence, the last seven (7) project functions shown in Table 1 to ANSI N45.2.6 are assigned to supervisory and engineering personnel, and not to personnel of the inspector category.

These managemen't supervisory and engineering personnel, as a minimum, meet the educational and experience requirements of "Level II and Level III" personnel, as required, to meet the criteria of ANSI 1.1 which exceeds those of ANSI N45.2.6.

In IM's opinion, no useful purpose is served by classification of management, supervisory and engineering personnel into "Levels."

Therefore, IQ takes the following positions relative to regulatory positions C5, 6, 7, and 10 of Regulatory Guide 1.5.

C-5 Based on the discussion in 9b, this position is not applicable to the Cook Nuclear Plant.

1.7-111

July, 1992

C-6 Replacement personnel for Cook Nuclear Plant management, supervisory and engineering positions subject to ANSI 1. 1 will meet the educational and experience requirements of ANSI 18.1 and therefore, those of ANSI N45.2.6.

Replacement inspection personnel will, as a minimum, meet the educational and experience requirements of ANSI N45.2.6, Section 3.5.1 "Level I."

C-7 18M, as a general

practice, complies with the training

., recommendations as set forth in this regulatory position.

C-8 All IM inspection, examination and test personnel are instructed in the normal course of employee training in radiation protection and the means to minimize radiation dose exposure.

C-10 ISH maintains documentation to show that inspection personnel meet the minimum requirements of "Level I," and that management, supervisory and engineering personnel meet the minimum requirements of ANSI 18.1.

10Property "ANSI code" (as page type) with input value "ANSI 18.1.</br></br>10" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

N45.2.8, 10a.

Sec.

2.9e Re uirement Section 2.9e of N45.2.8. lists documents relating to the specific stage of installation activity which are to be available at the construction site.

Exce tion Inter retation All of the documents listed are not necessarily required at the construction-site for installation and testing.

AEPSC and IM assure..

that they are available to the site, as necessary.

1.7-112

July, 1992

10b.

Sec.

2.9e

~ll Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.

Exce tion Inter retation Equipment may be installed before final approval of engineering or design changes.

However, the system is not placed into service until such changes are documented and approved.

10c. Sec. 4.5.1

~ll "Installed systems and components shall be cleaned, flushed conditioned according to the requirements of ANSI N45.2.1.

consideration shall be given to the following requirements:

(Requirements are given for chemical conditioning, flushing control s.)

and Special and process Exce tion Inter retation Systems and components are cleaned, flushed and conditioned as determined on a case-by-case basis.

Measures are taken to help preclude the need

~for cleaning, flushing and conditioning through good practices during maintenance or modification activities.

1.7-113

July, 1992

ll.

N45.2.9 lla. Sec. 5.4, Item 2 Records shall not be stored loosely.

"They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers."

Steel file cabinets are preferred.

Exce tion Inter retation Records are suitably stored in steel file cabinets, or on shelving in containers.

Methods other than binders, folders, or envelopes (for example, dividers) may be used to organize the records for storage.

lib. Sec.

6.2

~ll "A list shall be maintained designating those personnel who shall have access to the files".

Exce tion Inter retation Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5.

These rules do not always include a requirement for a list of personnel who are authorized access.

It should be noted that duplicate files and/or microforms may exist for general use.

llc. Sec.

5.6 When.a single records storage facility is maintained, at least the following features should be considered in its construction:

etc.

T Exce tion Inter retati on The Cook Nuclear Plant Master File Room and other off-site record storage facilities comply with the requirements of NUREG-000 (7/81), Section 17.1.17.4.

12.

Re

. Guide 1.144 ANSI N45.2.12 12a.

Sec.

C3a(2)

~ll Applicable elements of an organization's guality Assurance Program for "design and construction phase activities should be audited at least annually or at least once within the life of the activity, whichever is shorter."

Exce tion Inter retation Since most modifications are straight forward, they are not audited individually.

Instead, selected controls over modifications are audited periodically.

12b. Sec.

C3b(l) lt This section identifies procurement contracts which are exempted from being audited.

Exce tion Inter retation In addition to the exemptions of Reg.

Guide 1.144, AEPSC/I&A considers that the National Institute of Standards and Technology, or other State

~ and Federal Agencies which may provide services to AEPSC/I&A, are not required to be audited.

12c. Sec. 4.5.1 Re uirement Responses to adverse audit findings, giving results of. the r evi ew and investigation, shall clearly state the correcti ve action taken or planned to prevent recurrence.

"In the event that cor recti ve action cannot be completed within thirty days, the audited organi zati on '

response shall include a scheduled date for the correcti ve action. "

July, 1992

Exce tion Inter retation AEPSC/I&M take the position that certain circumstances warrant more than thirty (30) days to completely investigate the cause and/or total impact of an adverse finding.

For these circumstances, an initial thirty (30) day response will be provided which addresses a schedule for known corrective actions, the reason why additional investigation time is

needed, and a schedule for completion of the investigation.

These initial responses require the approval of the Director equality Assurance.

13.

N45.2.13, 13a.

Sec. 3.2.2 N45.2. 13 requires that technical requirements be specified in procurement documents b

reference to technical requirement documents.

Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.11.

Exce tion Inter retation For replacement parts and materials, AEPSC/IM follow ANSI N18.7, Section 5.2. 13, Subitem 1, which states:

"Where the original item or part is found to be commercially 'off the shelf'r without specifically identified gA requirements, spare and replacement parts may be similarly

procured, but care shall be exercised to ensure at least equivalent performance."

13b. Sec. 3.2.3 "Procurement documents shall require that the supplier have a documented equality Assurance Program that implements parts or all of ANSI N45.2 as well as.applicable equality Assurance Program requirements of other nationally recognized codes and standards."

1.7-116

July, 1992

Exce tion Inter retation Refer to Item 2j.

13c.

Sec. 3.3(a) lt Reviews of procurement documents shall be performed prior to release for bid and contract award.

Exce tion Inter retation Documents may be released for bid or contract award before completing the necessary reviews.

However, these reviews are completed before the item or service is put into service, or before work has progressed beyond the point where it would be impractical to reverse the action taken.

13d.

Sec. 3.3(b)

Review of changes to procurement documents shall be performed prior to release for bid and contract award.

Exce tion Inter retation This requirement applies only to quality related changes (i.e.,

changes

.to the procurement document provisions identified in ANSI N18.7, Section 5.2. 13. I, Subitems 1 through 5).

The timing of reviews will be the same as for review of the original procurement documents.

13e.

Sec.

10.1 Re uirement "Where required by code, regulation, or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods.".

1.7-117

July, 1992

Exce tion Inter retation Refer to Item 2j.

"Post-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."

Exce tion Inter retation In exercising its ultimate responsibility for its guality Assurance

Program, AEPSC/IKH establishes post-installation test requirements giving due consideration to supplier recommendations.

14.

Re

. Guide 1. 146 ANSI N45.2.23 and ANSI N45.2.2. 12 14a.

ANSI N45.2.23 Sec.

1.1

~R This standard provides requirements and guidance for the qualification of audit team leaders, henceforth identi fied as "lead auditors."

14b.

ANSI N45.2.12, Sec. 4.2.2 A lead auditor shall be appointed team leader.

Exce tion Inter retation The AEPSC audit program is directed by the AEPSC Director guality Assurance and is administered by designated gA Division section managers/supervisor who are certified lead auditors.

Audits are, in most cases, conducted by individual auditors, not by "audit teams."

These auditors are certified in accordance with established procedures and are assigned by the responsible gA section manager/supervisor based on their demonstrated audit capability and general knowledge of the audit subject.

In certain cases, this results in an individual other than a "lead auditor" conducting the actual audit function.

1.7-118

July, 1992

Established AEPSC audit procedures require that, in all cases, the audit functions of preparation/organization, reporting of audit findings.and evaluation of corrective actions be reviewed by gA Division section managers/supervisor, thereby meeting the requirements of ANSI N45.2.23 relative to "lead auditors",

and "audit team leaders."

1.7-119

July, 1992