ML17333B108
| ML17333B108 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/29/1997 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:0847AG, AEP:NRC:847AG, TAC-M95888, TAC-M95889, NUDOCS 9711030248 | |
| Download: ML17333B108 (11) | |
Text
CATEGORY 1 REGULATCQI INFORMATION DISTRIBUTIONTEM (RIDE) g.w
~.4 0 ACCESSION NBR:9711030248 DOC.DATE: 97/10/29 NOTARIZED: NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana' 05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards answer to questions in 970929 RAI a marked-up S revised pages to QAP description.
DISTRIBUTION CODE:
Q004D COPIES RECEIVED:LTR L ENCL I
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TITLE: QA Topical Report,
- Change, Amendment, or Correspondence (Docket NOTES:
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RECIPIENT ID CODE/NAME HICKMAN,J INTERNAL: DRS/RGN.XK NRR/DISP/PIMB NUDOCS-ABSTRACT RGN3 FILE EXTERNAL: DMB/OSS NRC PDR COPIES LTTR ENCL 1
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indiana Michigan Power Company 500 Circie Drive Buchanan, Mi 491071395 INOMNA SllCHlGAM PQWM October 29, 1997 Docket Nos.:
50-315 50-33.6 AEP:NRC:0847AG U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
205SS Gentlemen:
Donald C.
Cook Nuclear Plant Units 1 and 2
RESPONSE
TO REQUEST FOR ADDITIONAL INFORMATION REGARDING QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD)
(TAC NOS.
M95888 AND M95889)
Reference:
Letter AEP:NRC:0847AE, Quality Assurance Program Description (QAPD)
Proposed
- Revision, dated August 1, 1997 In your letter of September 29,
- 1997, we were requested to supply additional information needed to resolve questions concerning the QAPD for Cook Nuclear Plant units 1 and 2.
These questions are addressed in the attachments to this letter.
Attachment 1 provides our answer to your questions.
Attachment 2
provides a marked-up version of the pages in question from our previous submittal.
Attachment 3 provides our revised QAPD pages resolving your questions.
a Sincerely, E.
E. Fitzpatrick Vice President vlb Attachments CC:
A. A. Blind A. B. Beach MDEQ -
DW a RDP NRC Resident Inspector J.
R. Padgett f
97fi030248 97i029 PDR AMCK 050003i5 P
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ATTACHMENT 1 TO AEP:NRC:0847AG
RESPONSE
TO REQUEST FOR ADDITIONAL INFORMATION REGARDING QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD)
(TAC NOS.
M95888 and M95889)
Attachment 1 to AEP:NRC:0847AG Page 1
ualit Assurance Pro ram Descri tion APD 0 erable Re irements American Electric Power Company (AEP) is proposing a
new QAPD Section 1.7.11.2.4 that states:
Technical Specification (TS) equipment can be considered operable prior to the satisfactory completion of tests when TS surveillance requirements provide an allowance of time to analyze test results.
AEP's justification of the new section states:
Clarification of equipment operability affected by TS testing.
This proposed change would revise the
{}APD to be consistent with the TSs (such as 4.7.5.1.c.3 and 4.7.6.1.b.4) that allow time for completion of laboratory analysis.
The TSs take precedence over the
{}APD.
The TSs give a definition of operability and this is where the clarification should be made.
Why is the new operability statement necessary if the TSs already allow AEP to declare a system, structure, or component operable before test results are analyzed2 Please explain where and why the current TSs are inconsistent with the current QAPD, if this is the case."
Xf the current TSs are consistent with the current
- QAPD, then why is a new {}APD section needea?"
Res onse to NRC uestion:
The quality assurance program description (QAPD), as written, could be interpreted in a way that does not allow time to analyze test results.
- Thus, the QAPD could be construed as more restrictive, hence inconsistent, with the technical specifications (T/Ss).
By adding QAPD section 1.7.11.2.4 in the previous submittal, we intended to acknowledge that the T/Ss take precedence over the
- QAPD, and mitigate the potential to interpret the QAPD in a way that is more restrictive, hence inconsistent, with the T/Ss.
We now propose a change to section 1.7.11.2.3 that would resolve the potential for an inconsistent interpretation between the T/S and the QAPD.
Section 1.7.11.2.4 is no longer proposed or needed.
ATTACHMENT 2 TO AEP:NRC:0847AG CURRENT PAGES MARKED-UP TO REFLECT PROPOSED CHANGES TO THE QAPD
Page 5
8th item 1.7-31 10th item 1.7-31 1.7-33 July,1997 Page Number Proposed Change (s)
Responsibility for planning and directing engineering and technical studies, equipment performance and instrument and control maintenance has been reassigned to nuclear engineering-reference to page 1.7-27.
Responsibility for directing on-site fuel management, and core physics testing has been reassigned to nuclear engineering-reference to page 1.7-27.
Lists new business performance organization responsibiiities reassigned from previous organizations.
1.7-34 Purchasing and Materials Management Department 1.7-46 1.7-69; 1.7.9.2.2 1.7-71; 1.7.9.2.3 1.7-73 1.7.10.2.1 Title change from vice president-purchasing and materials management to vice president-procurement and supply chain services.
Design change reviews and approvals are completed by appropriate cognizant personnel, management, and in accordance with technical specifications and regulatory requirements.
Clarifying that certain engineering specifications are in the form of dedication plans. Also, clarifying who is responsible for preparation, review, and approval of welding, heat treating, and nondestructive requirements, respectively.
Clarifying specific organizations responsible for welder qualifications.
"procedure which includes inspections"; added for clarification.
1.7-79 1.7.11.2.3 "hold points are" added for clarification.
Clarification of equipment operability affected by technical specification testing. This proposed change would revise the QAPD to be co tent with technical s ecification
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,',:."',"'"'"v*'",'ldata resulting from these tests is retained at the Cook Nuclear Plant after review by appropriate management personnel.
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tea,t':,:,r es@1'tvs::.'.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 structures, systems and components 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 Established procedures and instructions are used for calibration and control of measuring and test equipment utilized in the measurement, inspection and monitoring of 1 ~ 7-79 July 1997
ATTACHMENT 3 TO AEP:NRC:0847AG PROPOSED CHANGES TO THE QAPD
Page 5
8th item 1.7-31 10th item 1.7-31 1.7-33 July,1997 Page Number Proposed Change (s)
Responsibility for planning and directing engineering and technical studies, equipment performance and instrument and control maintenance has been reassigned to nuclear engineering-reference to page 1.7-27.
Responsibility for directing on-site fuel management, and core physics testing has been reassigned to nuclear engineering-reference to page 1.7-27.
Lists new business performance organization responsibilities reassigned from previous organizations.
1.7-34 Purchasing and Materials Management Department 1.7-46 1.7-69; 1.7.9.2.2 1.7-71; 1.7.9.2.3 1.7-73 1.7.10.2.1 Title change from vice president-purchasing and materials management to vice president-procurement and supply chain services.
Design change reviews and approvals are completed by appropriate cognizant personnel, management, and in accordance with technical specifications and regulatory requirements.
Clarifying that certain engineering specifications are in the form of dedication plans. Also, clarifying who is responsible for preparation, review, and approval of welding, heat treating, and nondestructive requirements, respectively.
Clarifying specific organizations responsible for welder qualifications.
"procedure which includes inspections"; added for clarification.
1.7-79 1.7.11.2.3 "hold points are" added for clarification.
Clarification of equipment operability affected by technical specification testing. This proposed change would revise the QAPD to be consistent with technical specifications.
1.7.11.2.3 Testing is accomplished 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+i.~or~a's
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,' eujrmi'n ti!ded teaasBeQ~: All 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 structures, systems and components 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 Established procedures and instructions are used for calibration and control of measuring and test equipment utilized in the measurement, inspection and monitoring of 1.7-79 July 1997