ML20217J470
| ML20217J470 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/01/1997 |
| From: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| To: | |
| Shared Package | |
| ML17333A972 | List: |
| References | |
| NUDOCS 9708140279 | |
| Download: ML20217J470 (159) | |
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DQBLD C. COOK NUCLEAR PIANT (COOK NUCLEAR PLANT) r-UNIT NUMBERS 1 W DOCKET NOS. 50-135 AND 50-316 LICENSE NOS. DPR-58 AND DPR-74 UPDATED QUALITY ASSURANCE PROCRAM DESCRIPTION FOR THE COOK NUCLEAR PLANT JULY 1997 i-4 Concurred by:
( Date: 7 - 3 0 '1 7
, Performance Assurance Director l
approved by : 2'[OY',P f( Date:
r/ih:7 s, Vice Preside d (( IndianatMichiganiPowerjcompa'ny i
k i
m 9708140279 970901 PDR ADOCK 05000315
-P PDR g
STATEMENT OF POLICY FOR TIIE DONALD C. COOK NUCLEAR PLANT QUALITY ASSURANCE PROGRAM POLICY American Electric Power [2 recognizes the fundamental importance of controlling the design, modification, and operation of Indiana Michigan Power Company's Donald C. Cook Nuclear Plant by implementing a planned and documented quality assurance program, including quality control, that complies with applicable regulations, codes, and standards.
The quality assurance program has been established to control activities affecting ,
safety-related functions of structures, systems, and components in Cook Nuclear Plant. The quality assurance program supports the goal of maintaining the safety and reliability of Cook Nuclear Plant at the highest icvel through a systematic program designed to assure that activities affecting safety-related functions are conducted in compliance with applicable regulations, codes, standards, and established corporate policies and practices.
As chairman of the board, president, and chief executive officer of American Electric Power Company [1, I maintain the ultimate responsibility for the quality assurance program associated with Cook Nuclear Plant. I have delegated responsibliities for implementation of, and compliance with, the quality assurance program, as outlined in this statement.
IMPl,EMENTATION The isjiifo6 naris [assurangdist6f, under the direction of the ffs6snij vice president nuclear generation, has been assigned the overall-responsibility for
. specifying the quality assurance program requirements for Cook Nuclear Plant and i verifying their implementation. The prfohnance Wssu(arddith@ has authority to stop work on any activity affecting safety-related items that does not meet applicable administrative, technical, and/or regulatory requirements.
The 1.7-1 July 1997
t Statement of Policy for the Donald C. Cook Nuclear Plant
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s Mpiim$igisidiarshidirj6(6i 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 pidutifj vice president nuclear generation, under my direction, has been delegated responsibility for effectively implementing the quality assurance program. All other AEP divisions and departments having a supporting role for Cook Nuclear Plant are functionally responsible to the Ex6E6}iv6 vice president nuclear generation.
The site vice president Q, under the direction of the Egi~yti@ c vice president nuclear generation, is delegated the responsibility for implementing the quality assurance program at Cook Nuclear Plant.
The @ifp@ga@@irisifdiidsjbiis responsible for establishing a quality control program at Cook Nuclear Plant.
The $ph@{cyMQ@@foj is responsible for providing technical direction to the site vice president kg for matters relating to the quality assurance program at Cook Nuclear Plant. The piffirHiisbE[asitsisiBQIiist@ is responsible for maintaining a quality assurance goup at Cook Nuclear Plant to perform required reviews, audits, and surveillances, and to provide technical liaison services to the site vice president E.
The f6iisificentsifoi implementation of the quality assurance program ~isi dis @iMIEti$[puplug[pnistijph@@jiji#Gndg@eddr6].
Each Euclig3Miti6h] Map involved in activities affecting safety-related functions of structures, systems, and components in 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 applicable quality assurance program requirements.
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l '. 7 -2 July 1997
Statement of Policy for the Donald C. Cook Nuclear Plant COMPlJANCE The performance assurance director shall monitor compliance with the established
' quality assurance program. Audit programs shall be established to ensure that nuclear generation group activities comply with established program requirements, identify deficiencies or noncompliances, and obtain effective and timely corrective actions.
Any employee engaged in activities affecting safety-related functions of structures, systems, and components in Cook Nuclear Plant who believes the quality assurance program is not being complied with, or that a deficiency in quality exists, should notify his/her supervisor, the performance assurance director, and/or the site vice president, if the notification does not, in the employee's opinion, receive prompt or appropriate attention. the employee should contact successively higher levels of management. An employee reporting such conditions shall not
' be discriminated against by companies of the American Electric Power System, nor shall any supplier under contract with any of the companies of the American Electric Power System discriminate against any employee of the supplier for reporting such conditions. Discrimination includes discharge or other actions relative to compensation, terms, condhions, or privileges of employment.
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('S E, Linn Draper, Jr.
Chairman of the Board, President, and Chief Executive Officer 1.7-3 July 1997
1.7311 ORGANIZATION-1.7.1.1. SCOPE:
a W W y % % ) @ Q C6f Q nfl Q Q41 Q Qiffef M ibnffisg
(!&N)l is responsible for establishing and implementing the Quality Assurance (QA) program for the operational phase of the Donald C. 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, I&N retains overall responsibility.
I&M 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
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(QAPD) identifies the @jf} organizational responsibilities
- for activities affecting the quality of safety-related nuclear power plant structures, 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- IMPLKNENTATION 1.7.1.2.1 Source of Authority The chairman of-the board, president, and chief executive officer of'American-Electric Power Company, Inc. (AEP), ]
t1@Nhlitslwhb11pI6wnid[sebildisr M66 is responsible for safe operation of the Cook Nuclear Plant. Authority and responsibility for effectively implementing the QA program ,
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^ 4 1.7-4 July 1997 1 4
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for plant modifications, operations and maintenance are dele 6ated to the I&M(vide;l president} responsible 1rorfnuc16ar gen @ ktio R fThe[I&Mj icsilpr;esidential.a gserven?nsltha 2 #
Americfan}Kle'ct'ric Powir1 Service Corpo'rstion{(AEPSC) b ekecutiVs vice president nuclear generation.
In the operation of a nuclear power plant, the licensee is required to establish clear and direct lines of responsibility, authority and accountability. This requirement is applicable to the organization providing support to the plant, as well as to the plant staff.
The responsibility for the support of Cook Nuclear Plant 3
rests with 16M which includes the onsite and offsite AEP organizations that administer, operate, maintain, and modify the plant. The I&M vice president '
has primary responsibility for Cook Nucicar Plant. All I&M' nuclear
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generationfgroupJorganizations are functionally responsibic to the I&M vice president ig 4 (reference Figure 1.7 1).
In order to facilitate a more thorough understanding of the support functions, some of the responsibilities, authorities, and accountabilities within the organization are as follows:
- 1) The responalbilities of the I&M vice president gg shall be dedicated to the area of Cook Nuclear Plant operations and support.
- 2) The 16M vice president ,' shall be responsible for, and has the authority to direct, all Cook Nuclear Plant operational and support matters and shall make, or concur, in all final decisions re6arding significant nucicar safety matters.
1.7-5 July 1997
- 3) 1&M managers shall be familiar with activities within their scope of responsibility that affect plant safety and reliability.- They shall be cognizant of, and sensitive to, internal and external factors that might affect the operations of Cook Nuclear Plant.
- 4) I&M managers have a commitment to seek and identify D
problem areas and take corrective action to eliminate unsafe conditions, or to improve trends that will upgrade plant safety and reliability.
- 5) The ,I&d vice president , 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 site vice president from the primary responsthility for safe and reliable plant operation.
- 6) 16M managers shall be familiar with the policy statemends 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 Besconsibility for Attaininn Ouality Obiectives in 7&M Nuclear Generation The AEP chairman of the board, president, and chief
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executive officer has assigned the overall responsibility for specifying QA program-requirements and verifying their implementation to the pstformadeo assurance dirdctor.
1.7-6 July 1997 1
The I6H vice president ~~L) under the direction of the AEP chairman of the board, president, and chief executive-officer, is responsible for effectively implementing-the QA program, 9-The performatice assurance director, under the direction of the ([gj vice president ((7 is responsible for establishing the Cook Nuclear Plant quality control program.
Each 1&M manager < ^ involved in activities affecting safety related functions of structures, systems, and components in 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 complyir.g with, the applicable quality assurance program requirements.
1&M has an independent off site Nuclear Safety and Design Review Committee (NSDRC) which has been established .
pursuant to the requirements of the Technical SpecificationsR Appen, dix [CJto!..thislQAPDJ for the Cook Nuclear Plant. The function of the NSDRC is to oversee the engineering, desi 6n, operation, and maintenance of the Cook Nuclear Plant by performing audits and independent reviews of activities which are specified in the facility Technical Specifications.
The Cook Nuclear Plant on-site review group is the ~ ]
Plant Nuclear Safety Review Committee (PNSRC). This committee has also been established pursuant to the requirements of the Cook Nuclear Plant Technical Specificatioru gApperidix;Clto;this;QAPD. The function of 1.7-7 July 1997
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the PNSRC is to review plant operations on a continuing basis and advise the site vice president ,
on matters l
4 related to nuclear safety.
1.7.1.2.3 Coroorate Organization American Electric Power Comoany
, AEP, the' parent holding company, wholly owns the common stock of all AEP System subsidiary (operating) companies, f'E';Thechairmanoftheboard, president, and chief executive of ficer of AEP is the chief executive officer of AEP, and all operating companies. The responsibility for the functional management of the major operating companies is vested in the president of each operating company reporting to the AEP chairman of the board, president, and chief executive officer, Ooeratine. Companigg 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' supervision 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, AEPSC provides limited public affairs, accounting, and industrial safety direction.
The Cook Nuclear Plant is owned and operated by I&M which is part of the AEP System.
1.7-0 July 1997
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1.71.2.4 Ouality Assurance Responsibility of Ild
- 1) }&M 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, 1&M reviews Nuclear Regulatory Commission (NRC) letters, bulletins, notices..etc., for impact on plant design, and the need for design changes or modifications,
- 2) IGH furnishes quality assurance, engineering, design, construction, licensing, NRC correspondence, fuel management and radiological support activities.
- 3) I&M 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 pe.rformancesassurance' organization provides technical direction in quality assurance matters to the nuclea'rforganisati'no and oversees the adequacy, effectiveness and implementation of the QA Program through review and audit activities.
- 5) Cognizant engineer (e.g. , system engineer, equipment engineer, lead engineer, responsible engineer, procurement en6 1 neer etc.) is that n;, ' individual who provides the engineering / design expertise for a particular area of responsibility. This 1.7-9 July 1997
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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.
Quality Assurance Responsibility U- Cook Nuclear Plant The 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 categories of procedures identified in section 1.7.5.2.2 describe the means by which compliance is achieved and responsibilities are assigned ?. Figure 1.7-1 indicates the organizations l , j pertaining to the operation and support of the Cook Nuclear-Plant.
3 1,7.1.2,5 Orcanizarton The chairman of the board, president, and chief executive officer le ultimately responsible for the QA program associated with the Cook Nuclear Plant. This responsibility is administered through the 16M vice president respona,1 bid { fop nuclear generation.
1.7-10 July 1997 ts! _.
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thtelear- ce'nerationTT ^ l l
-_NuclearLgenerationis_comprisedofpsjhlstoij[affalyd,-
- nuclear. engineering,_ prfstaanha ' assurance', Misinsa( .i M fokE856*E, NitO[6kiratibhi dand[hunSIf{r$ldo,OrCi$.
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=PaEfsrE Aha Assur M (( % -
- The performis6s assurance dii~ector, reporting to the 16H vicepresidentijRgisresponsiblefortheperfoimanM assurance ufss nisatijoh, Peyfgrasn@sshrasps - consists of the following' brianizatilons-(Figure:1.7-2):
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Parformshpy engineering and snalysi's plshQhd supplier performance if J 7Q emmnwwn li::ndAthl4
_ meeww$2dailwML "'sMd Performan4E fssdranbs 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.
Verify implementation of solutions, as appropriate.
Prepare, issue and maintain-QA program documents, as 4
required, Verify the implementation of the QA program through scheduled audits and surveillances, 1:
' Verify the implementation of computer. software quality assurance through ceviews, surveillances-and audits, p-0 -
i 1.7411' July 1997 4
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- Audit engineering, design, procuntnent, construction I and operational documents for incorporation of, ar.d I
. cornpliaa:e with, applicable quality assurance l requirements to the extent specified by the f~ !
management approved QA program. ,
j - Organize and conduct the QA auditor ,
orientation, training, certification and ,
- qualification of f # audit personnel.
- Provide direction for the collection, storage, !
maintenance, and retention of quality assurance records.
Maintain, on data base, a list of suppliers of nuclear (N) items and services, plus other selected categories of suppliers.
- Identify noncompliances of the established QA program to the responsible organizations for corrective a-tions, and report algnificant occurrences that jeopardizo quality to senior l '
- management. !
- Follow up on selected corrective actions, taken in response to adverse conditions, to confirm effectiveness, t
- Review the disposition of selected conditions adverse to quality to assure that action taken will preclude recurrence.
- - Conduct in process QA audits or surveillances at supplier's facilities, as required.
Assist and advise other e :. groups in matters related
, to-the QA program.
4 - Conduct audits as directed by the NSDRC.
- - Maintain cognizance of it.dustry and governmental l quality assurance'requi ments such that the QA program is~ compatible with' requirements, as necessary.
Recommend for. revision to, or improvements in, the
- established QA Program to senior Q t management.
1.7-12 July 1997
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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 Cj management with periodic reporca concerning the status, adequacy and implementation of the QA 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 adequato QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualificat. ion of personnel to carry out QA assignments.-
Determine the acceptability of vendors to supply products and services for safet.y related applications.
- Provide working levol coordination with the Institute of Nuclear Power Operations (INPO) in the areas of INPO training, seminars, and workshops. This effort includes providing the,nuclsar! generation organizattori access to INPO resourcos, such as NUC1. EAR NETWORK, and effectively considerip5-lth0[480 of INPO recommendations contained in operating experience reports to improve Cook Nuclear Plant performance.
Develop and implement an effective Quality control (QC) 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 1.7-13 July 1997
roEstding quan ty control for Cook Nuclear plant are implemented, qualified personnel perform the work, and that these activities are properly documented.
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Direct the activities of contractor QC/nondesttvetivo examination (NDE) personnel assigned to the plant performance assurance department and provide oversight of work performed.
Qualification and certification of I&M personnel performing inspections or tests of major modifications and n a routino maintenanca to the requirements of Regulatory cuide 1,58 and ANSI N45.2.6, except no noted in Appendix B hereto, item 9.
- Proper cert.ification of contractor inspection, test and examination personnel in accordance with Regulatory Guide 1.58, ANSI N45.2.6, ASME B6PV Code and/or SNT TC 1A, as applicable.
- Selec tionj offaiqualificati'onf and.Leertificat,lon I
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adminis trator[(NDE !adminis tra to r); tolee r ti fy personns1Tinfaccordancelwith' ANSI;N45.216]!and.;SNTfTCi 1A Lanc applicable; Amnlifiention of Snecific Responsibilities Qualifir.fttion of the nerfortaance assurance director The performanets assurance director shall possess the following position 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 nuclear powar generation facilities' or utility facilities' QA, of which at Icast four (4) years unst be 1.7 14 July 1997
. _=. . -- _ - - . - - . . . - - - , -. -. _ -
experience in nuclear quality assurance related activities.
Knowledge of QA re6ulations, policios, '
practices and standards.
The same, or higher, organiration reporting level as the highest line manager directly responsible for performing activities affecting ;
the quality of 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 QA Manual (s). '
Performance of no other duties or responsibilities unrelated to QA that would prevent full attention to QA matters.
Ston Work Orderg -
The performanceiassuranceJnrganization 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 AEP chairman of the board, president, and chief executive officer has given the performance assurance director the authority to stop work on any activity affecting the quality of safety-related items that doer. not meet the aforementioned requirements. Stop work authority has been further delegated by the performands assurance director to the managerfo rperformanca engineeringTatid analysis,Landjthe'? manager of plant andfsupplier performance. ,
1.7 . July 1997
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The performanen assurance director and the subordinatK aanageys do not have the authority to stop unit operations, but will notify appropriate ' management of conditions which do not meet the aforementioned criteria, and recommend that unit operations be terminated.
OA Auditor. Qualification and Certification Procram 16M has established and maintains a QA auditor training and certification program for all QA auditors.
- Condition identification. Reportinn and Escalation 1&M has established mechanisma for the identification, reporting and escalation of conditions affecting the quality of safety-related items to a level of management whereby satisfactory resolutions can be obtained.
Regulatory' Affairs The regulatory affairs ~ director, reporting to the I&M vice president _ l is responsible for the following:
Formulate policies and practices relative to ,
licensing, , _
fuel management, and radiological support.
Maintain liaison with the performancefassurance director.
Implement the requirements of the , QA program.
1.7-16 July 1997
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l Maintain knowledge of the latest ( s licensing, and regulatory requirements, codes, standards, and federal regulations applicable to the operation of Cook Nuclear Plant.
Accomplish the procurement, economic, technical, I
licensin6 and quality assurance activities dealing j with the reactor core and its related fuel assemblies i and components.
Prepare bid specifications, evaluate bids, and negotiate and administer contracts for the procurement of all nucicar fuel and related components and services.
Maintain a special nuclear material accountability system.
Provide analyses to support nuclear steam supply system operation, including fuel economics, fuel mechanical behavior, " , 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.
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Obtain and maintain the NRC Operating Licenses and Technical Specifications for the Cook Nuclear Plant.
Act as the communication link between the NRC and I&M.
1,7-17 July 1997
1 Perform and coordinato efforts involved in gathering information, performing calcular. ions and generic l
studies; preparing criteria, reports, and responses; i reviewing ite%. affecting safety; and interpreting regulations.
, x .iThe preparation of changes to, and appropriate interpretation of, the plant Technical Specification submittals of license amendments; and the analysis of plant compliance with regulatory ,
l requirements. i
- Primary corporate contact for most oral and written communication with the NRC.
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. Review, evaluate, and respond to NRC requests for !
information and NRC notifications of regulatory e changes resulting in plant modifications or new facilities. Such responses are generated in {
accordance with appropriate administrative procedures. 6
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9-
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.w k , a Review, on a conceptual basis, plant reports, to the extent that they are related 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 i determino if there are any unreviewed safety questions as defined in 10CFR50.59.
Perform reviews of Condition Reports and 10CFR21 reviews in accordance with corporate requirements.
Operate the Action Item Tracking (AIT) system for E'- M internal commitment tracking,
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1,7-18 July 1997
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. &-_ . . . sm . .c Contribute to the annual FSAR' updates through reviews of Licensee Event Reports, and the Annual Operating Report, p , , ,
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, 4 Serve as technical advisors on plant audits.
Remain cognizant of current decomrnissioning practices and developments, i
Nuclear Encineerine
4 The ; l chief nuclear engineer,- _ i reporting to the 16H vice president n
- is responsible for certain engineering, design, procurement, and construction functions, 7 Nuclear engineering , ;is comprised of plant 3
engineering l [? design engineering [ f ,"1and_ production ,
engineeringy , , 'l .
- Certainforganizationslwithin;the'AEP power,generatiott group and; energy' delivery; provide occasi'nal o technical assistance for the Cook Nuclear Plant. The administrative and quality assurance controls for this assistance are controlled through documented interface agreements. 3.-- ;
CNuclear engineering U is responsible for the following:
Provide planning, engineering and design of the electrical facilities inside Cook Nuclear Plant up to the high voltage (IN) bushings. of the main generator transformers and mechanical facilities inside Cook
, Nuclear Plant including:
- determination of general layout and design;
- selection of equipment; 1.7-19 . July 1997
- preparation of one line and flow diagrams; and, !
- coordination of inside and outside plant facilities.
- Provide engineering and design of all controls for operation and protection of nuclear steam supply, steam generator, turbine generator, auxiliary
- equipment and general plant protection, including l checking and approving elementary, one line, and flow drawings.
Ensure that all purchased equipment conforms to accepted standards and fulfills the desired function.- ,
- Closely follow manufacturer's engineering and design processes to assure provision of adequate and ;
reliable equipment upon which depend the safety, reliability, and performance of the unit and plant. '
- Prepare, review and/or approve design changes, sketches, drawings, calculations, and design verifications, as required. *
- Perform safety reviews of design changes pursuant to 10CFR50.59. i
- Prepare and/or approve dedication plans. -
specifications and procurement documents.
- Perform drawing review of equipment, as appropriate. j
- Develop, review and/or approve procedures or correspondence as appropriate.
- Obtain, review and perform engineering and design evaluations, including environmental equipment qualification (EQ).
- Establish and maintain a central file for equipment i environmental qualification documentation. ,
- Coordinate operations y that support the Cook. !
Nuelear Plant Facility Data Base (FDB).
1.7 20 July 1997
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Perform calculations for proper application of equipment.
Perform and evaluate investigations, analyses and reports' for facilities pertaining to the engineering design, operation and maintenance of.the Cook Nuclear Plant.
Assist field personnel in installation, start up, and subsequent locating of problems in equipment, and in determining proper operation of equipment, during )
normal or after emergency operations.
Haintain a constant awareness for improvements and ;
more reliable design of equipment and facilities, maintenance and operating methods or procedures. -
Maintain a constant awareness of activities to ensure compliance with all applicable policies and procedures, initiating, when required, training or retraining programs.
- Participate, as assigned, on the NSDRC and NSDRC ,
subcommittees, and participate in matters covered in the committee's charter, e Provide responses to NRC correspondence, as required, !
Participate in the evaluation and remedy of any situation _ requiring activation of the Emergency ,
Response Organization.
Provide support personnel for the Emergency Response t Organization.
Provide technical support in areas of operation and maintenance, including: the Inservice Inspection (ISI) program; the QA program; the fire protection QA program; the a All.RA program covering radiation protection; and, the corporate and plant industrial
= safety program.
1.7-21 July 1997 r
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Provide technical direction and assistance in the layout and arrangement of equipment piping, systems, controls, etc., for the development of drawings.
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Develop System Descriptions.
Provide analytical support in engineering and design disciplines (e g., heat transfer, thermodynamics, fluid dynamics).
Provide engineering and design evalvations for CRa, LERs, INPO SOERs, and NRC Bulletins.
Participate, as assigned, on the r _ Condition Assessment Group (CAG).
Make recommendations and assist in the formulation of policies and practices relating to the design and engineering of office and service buildings, miscellaneous structures and material handling equipment, and provide the general supervision of the engineering of such facilities, structures and equipment.
Initiate and/or review, approve and control laboratory and field investigations and feasibility studies.
4 Arrange for outside engineering, design and consulting assistance, as required.
Perform shop and field surveillance on equipment being manufactured, fabricated, or installed.
- Provido fleid services to the Cook Nuclear Plant, including the assigning of personnel, as are required, during construction, normal or forced outages, or as requested.
1.7 22 July 1997 l
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. _ _ _ _ _ _ _ . . _ _ . _ _ _ __._ m _ . - . . . _ - _ . _ __..___. _ _ .
Assist in the planning and execution of maintenance J work on equipment, facilities, buildings and other i structures, i Supervise maintenance and repairs of all masonry and ;
concrete work at Cook Nuclear Plant, including supplying qualified inspection personnel.
Direct testing of materials used in concrete and testing of soils to be used in work at the Cook Nuclear Plant.
Review and recommend concrete raix formulations for all new construction.
Implement the corrective action program, with regard to activities affecting the quality of safety-related items and services, that controls and documents items, services or activities which do not conform to requirements.
Assist in the preparation of applicatione for ,
federal, state and local permits relative to installations being made which requiro such permits.
Conduct periodic management reviews of the activities
- of the department to ensure compliance with the [
objectives of the QA Program, and external technical
, surveillance, as necessary, of consultants, outside organizations and vendors over which the department is cognizant.
Establish and maintain a file for QA records.
Develop, review and epprove designs and drawings for mechanical, electrical and structural systems, equipment and facilities of the Cook Nuclear Plant.
Perform required calculations and analyses, including pipe stress, pipe support design, cable si::ing, conduit and cable tray support and structural steel and concrete.
1.7-23 July 1997
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Assist field personnel in the resolution of problems stemming from the installation of design changes, or from as-found plant conditions, including assigning personnel to the plant.
- Formulate, administer, and implement policies and practices relating to the engineering, and design of l the Cook Nuclear Plant. ;
Conduct functions so as to be in conformance with the operating licenses of the Cook Nuclear Plant.
Investigate evaluate and correct problems.
Coordinat. pecial projects and studies, as required.
Coordinate the development and maintenance of the ;
Vendor Drawing Control (VDC) programs which include coordinating the programs with interfacing di. visions / departments,
- Control the issuance and distribution of drawings for 1
the Cook Nuclear Plant, including monitoring of the Aperture Card Microfilm Program.
Supervise and control the work of consultants, architect / engineers and outside engineering and design agencies supplying services to 1&M in their i discipline and process notification of defects in accordance with company requirements, Also perform detailed reviews of engineering and design work submitted by outside agencies.
Review and update applicable sections of Cook Nuclear Plant Updated FSAR as assigned.
Participate, as members and as assigned, on committees and ad hoc task forces that review nuclear activities.
1,7-24 July 1997
Coordinato Cook Nuclear Plant activities associated !
I
-with the initiation, review, approval, engineering, ;
. design, production, examination, inspection, test, ,
turnover, and close out of design changes.
, p ymy - n --
3
.w c, i s , x . .t
, fg . w.rg ,. - _ y y o, U a + !.a;J + e 1 , - s ys. id Administer and implement job orders issued by the Cook Nuclear Plant organization for major 4 modifications, replacement and maintenance work with outside contractors.
Administer and monitor contractor's industrin1 safety programs and performance.
m w,' . w. , , . %s - ;
j !l + ;y:n .# 'k
< s lHanage construction labor relations with the [
international building and' construction trades unions. I
, e m .._ ,, - 7 . ,
o , t . . .- , h.: 1
-- Plan, organize and control major construction l projects, as assigned by the IWI vice president l b Maintain cognizance on matters pertaining to the Cook i Nuclear Plant ["j omergency response organization, s - Prepare labor estimates.
Provide constructability guidance when requested in support of engineering and design changes.
Formulate lPolici.esTand practices'relativetto nucle'er(se fety} -
Mai nta tniknowleidg[o[the]1ste a ci s a fe t9 ;
2 requirementspgodes,[scandatdagend fede ralj ragulati on'sj appl i.cablsi tolthe, operationfot(Cook l.NucicarlPl% Q Provsdefsealystsito;abpporc? reactor phjsicsscore[thermalihydrasligandi14CA-knd.inen {14CAit ransi en tima fe tyj analys is 1.7-25 July 1997 i
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andLother analysis; activities-~as requestedil Land, participate in: NRC and 1 NSDRC y meetingsitelated tolthese analysen.
- Coordinate the:developtnent;of'neutronics and thermal-hydraulic safety: codes'and conduct ; safety anAlysici Coordinate' computer code developmenti'and provide ~the. interface control for AEPSC informationfsystems.and.!!(4 nuclear generationi Reviewscoordinato,;and resolveLall ;
matters pertaining to;~nuclearLsafety. for Cook Nuclear.LPlant; Thisiincludes, but is not limited.tof ;the preparation of safety levalitationsi; 'or Lreviews',- for~~a designated subjecti
- provide support'in'. key ~ areas of .
exportisensuchfas'nuclearfengineeringi p robab ili s tic? analys i s'j ;;the rmohydraulic analysis, chemica1Lengineerin5I
- mechantcal" engineering,Telectrical engineering. and. technical' writing!
- Interface with.vendora and other~outside organizations;onlmattera connected"with the nuclear'ateam' supply, system'and~other arean.affecting;the~ safe; design land
~
operation of ;tioclearl plants)
ParticipateijasTappropriate;[inithe reviewofinuclearplant' operating experiences',;. ~and. relate" those Lexperiencon to L the ; design and isafe;'operationi Tof Cook Huclear: Plant!
1.7-26 July 1997
Devr30p';-lspecifyjLand/or review conceptual;nucioar m
safatyl:crAtaria; for Cook'Nuclest'Plantsin accordsuco kith established;regulatiotis', . ;This' includes" all informaticn' contained in Jthe TSAR,1. an~'wellTas specialited information.'such'as environmental qualificationfand fse1smic.;critoria{
Review and~ avaluate ;performatice . requirements forl systems,fequipmentfandiaateHals-for complianceiwith;specified sAfstyl. criteria?
Coordinate"Squipan;pt;Performanensand Information; Exchange.(EPIX);;with INPO!
- Recormnend .'facilitylengineering modification endfinitiata and approve plant 11mprovementfrequisitionsi Plan and direct engineering *nnd technical studiesi;. equipment p6rformance', and instrument"and contro11:naintenancol for Cook';NuclearlPlantf.-
Direc tip rod'.ma'.;; relatied" to 'on; n i t'o : fuel management .andl. reactor core physica testing,Tand_ ensure satisfactory completioM Coordinate the maintenance of1desigt) drawings]
1.7 27 July 1997
Site Doerations The [f"" l site vice president
- reports [T ' to the
.IM vice president l' , and is responsible for the Cook Nuclear Plant activities (Figure 1.7 1).
The inite'operationis organization is responsiblo for the following:
Ensure the safety of all facility employees and the general public relative to general plant safety, as well as radiological safety, by maintaining strict compliance with plant Technical Specifications, procedures and instructions.
Recommend facility engineering modification and initiate and approve plant improvement requisitions.
Ensure that work practicos in all siteLoperations organizations are consistent with regulatory standards, safety, approved procedures, and plant Technical Specifications. -
Provide membership, as required, on the l'NSRC. i
- Maintain close workinr, relationships with the NP.C. I as well as local, t ate, and federal government regulatory officials regarding conditions which could affect, or are affected, by Cook Nuclear Plant activities.
- Set up plant load schedules and arrange for equipment outages.
- Develop and efficiently implement all site centralized training activities.
1,7-28 July 1997
i ;
l i
Administer the contralized facility training complex, f simulator, and programa ensuring that program development is consistent with the systematic approach to training, maintain INPO accreditations,- '
regulatory and corporate requirements.
-f Ensure that human resource activities include <
I employee support programs (i.e., fitness for duty) consistent with INP0/NUMARC guidelines, company policies, and regulatory requirements and standards, Administer the NRC approved physical Security Program t in compliance with regulatory standards, Modified Amended Security Plan (MASp), and company policy. !
Supervise, plan, and direct the activities related to i I
the maintenance and installation of all Cook Nuclear Plant equipment, structures, grounds, and yards.
Prepare and maintain records and reporta pertinent to equipment maintenance and regulatory agency f
requirements, j
, ,g 4 y- .
j
. u.w w _ .
Enforce and coordinato 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 '
1 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 Nucicar 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, l
l l
1.7-29 July 1997 p
i Review reports and records, direct general inupection of operating conditions of plant equipment, and '
investi ate 6 any abnormal conditions, making recommendations for repairs. Establish and administer equipment clearance procedures consistent with company, plant, and radiation protection f standards; authorize and arrange for equipment outages to meet normal or emergency conditions.
Provide the shift operating crews with appropriate i procedures and instructions to assist them in operatin6 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, j 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.
- prepare reports of reportable events which are
-mandated by the NRC and the Technical Specifications.
.. Prepare statistical reports utilized in NRC Appraisal Meetings and Enforcement Conference, e
1.7-30 July 1997-t
i l
I . Coordinate the efforts of outside agencies, such as :
American Nuclear Insurers (ANI) INPO, and third. f party inspector programs. j
- Haintain knowledge of developments and changes in NRC l
requirements, industry standards and codes, !
. regulatory compliance activities, and quality control f disciplines and techniques.
- Stop plant operation ~,(as(appropri'atey.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 of 1&M personnel performing inspection of normal operating activities to ANSI N18.1.
. 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.
Plan and direct b "" on site computer systems, Shift Technical Advisors, and emergency planning? _'.
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 monitor programs to ensure optimum plant efficiency.
- w.
3 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 1.7 31 July 1997
-9 ., me. -w-- % y,w,.ir.. - +- -.-pe- .,g%-y -
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design of equipment to improve safety of operations and overall plant efficiency.
Implement the y ] 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.
l - Plan and schedule the activities of the radiation protection department of the Cook Nuclear Plant in support of operations and 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 4 criteria.
- Administer and direct the Cook Nucicar Plant's radioactive waste programs, including volume reduction, packaging and shipping,
- Maintain the Cook Nuc1 car Plant Facility Data Base.
w _ ,
Procurementtreceiving,;qualitylcontrol rec e ip t ; inspec t i onil s to ra ge',1handl ing s issundstock11evellasIntehancefand ove rall ^ cont ro11 o f f s t'o re ali t em6 1.7 32 July 1997
_ _ ._. . _ _ _ . __ _ _ _ _ _ _ . _ - , ~,
t Provide materialfeervice;and support ~1n,accordance With policiosfand procedures} required'hy AEPSC purchasing and:materialsimanagement,*LQA,1and the NRC, Which are;taministered.and enforced sin a totalt of fore to;; ensure (safetyf and; plan.t reliability. !
Provide nuclear General;-Employen~ Training.;l(CET) Lfori
. i nuclear generation personneli Businman Performante The~ business; performance director. reporting'tnithe 1&M '
vice president Eis:reuponsibic forltholfollowing:
- Prepare and. administer equipment, labor.nnd: service contracts.
Administer' contracts'andischeduletoutpfde l contractora r vork forcen,-
- AdministrationLof. tha _QA records' program.1
- Stiopef-1. bids-l- recommend; awards and -
administer. construction l. labor,and servico contractsi Process incoming vendor 1information.-
5 1.7 33 July 1997
.- ~ _- -- - . - - - - - - - _--- - . _ .-- --.._. _
l Purchasine and Materials Managtment (not charted)
The AEP executive vice president administration and chief accounting officer, reportin6 to the AEP chairman of the i board, president, and chief executive officer, is responsible for ' i purchasing and naterials management , >
through the vice president procurementl& supply; chain se rvican_,;
Procurement &-supplyfchaintservices is responsible for the following: ;
- Procurement of safety related items from only qualified and approved suppliers.
- Provide supervision to Cook Nuclear Plant purchasing organf 2ation.
- Provide orderin6 and stocking descriptions (Material
& Equipment database) for safety related 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.
- Establish computerized inventory status reports, on line inventory and purchase order inquiry capabilities and other procedures to order, track and control materials.
Coordinate procurement activities with I&M L .
- Prepare and issue requests for quotations, contracts, service orders, blanket orders, and purchase orders for safety related items.
- Impicment corrective action as described in the I&M procedures for Cook Nuclear Plant.
1.7 34 July 1997 n
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_ _ _ _. _ _ _ _ - - . _. . ~ - _ . _ . _ _ . _ _ _ _ . . . _ . . _ . . . _ . . . _ _ _
Establish a system of document keeping and transmittal.
- Establish a system of document control for controlled procedures, instructions, and purchasing documents for safety related items.
The maintenance and control of selected procurement document standard phrases as identified by the parformance assurance director or designee.
- Conduct training sessions involvin5 purchasin6 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 ano t
services.
1.7.2 QUALITY ASSURANCE PROGRAM 1.7.2.1 SCOPE Policies that define and establish the Cook Nucicar Plant QA Program are summarir.ed 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 Nucicar Plant.
4 1.4 35 July 1997 i
-r-- - -,-, . -~ , . - . .
l l
l l
Quality assurance controls apply to activities affecting the quality of safety related structures, systems and ;
components to an extent based on the importance of those -
structures, systems, components, etc., (items) to safety.
Such activities are performed under controlled conditions, including the use of appropriate equiproenti environmental ;
conditions, assignment of qualified personnel, and I
assurance that all applicable prerequisites have been met, Safety related items are defined as items: ,
Which are associated with the safe shutdown (bot) of ,
the reactor; or isolation of the reactor; or maintenance of the intc6rity of the reactor enolant system pressure boundary.
- Whose failure might cause or increase the severity of a design basis accident as described in the Updated I FSAR; or lead to a release of radioactivity in excess of 10CFR100 guidelines, In general, safety related items are those which are classified Seismic Class I, or Elcetrical Class 1E; or associated with the Engineered Safety Features Actuation System (ESFAS); or associated with the Reactor Protection System (RPS). Note: Some nonsafety related items have been designed to Seismic Class 1 and/or Electrical Class 1E requirements. For exampic: post accident monitoring instrumentation is not safety.related but is qualified Seismic Class 1 and Electrical Class IE to meet the requirements of Reg, Guide 1.97, 1.7 36 July 1997
. , . - . . .y-- . , . ,, .,,-,..--r.- ..,....-..-..,-.m.,vw.,y,,.,,.,e.,.y_.- .,i,b-,vm . . - .. ..- . ..w .-.-.v---
A special QA Program has been implemented for Fire Protection items (Section 1.7.19 herein),
The QA Program alan includes provision for Radwaste QA in accordanco with the requirements .of 10CPR71, Subpart 11.
QA Program status, scope, adequacy, and compliance with 10CPRSO, Appendix B, are regularly reviewed by management through reports, meetings, and review of audit results.
The impicmentation of the QA program may be accomplished by 1&H or dele 6ated in whole or in part to other AEP System companies or outside parties, flowever, I&M retains full responsibility for all activities affecting safety related items. The performance of the delegated organization is evaluated by audit or survelliances on a frequency commensurate with their scope and importance of assigned work.
1.7.2.2 IMPLEMENTATION 1.7.2.2.1 The chairman of the board, president, and chief executive officer 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 portaining to quality assurance for nuclear power planti as required by the Cook Nucicar Plant operating licenses.
The statement makes this QAPD and the associated implementing procedures and instructions mandatory, and requires compliance by all responsible organizations and 1.7 37 July 1997
- - - - - -~
r individuals. The statement also identifies the management f positions within the companies vested with responsibility ,
and authority for implementing the program and assurina its effectiveness.
1.7.2.2.2 l s
The QA program at I&N consists of controls exercised by organizations responsible for attaining quality objectives, ,
and by organizations responsible for assurance functions.
The QA program effectiveness is continually assessed through management review of various reports, NSDRC review of the QA audit proBram, and shall also be periodically reviewed by independent outside parties as deemed neccesary l by management, ,
The QA program described in this QApD is intended to apply for the life of the Cook Nuclear plant.
The QA program applies to activities affecting the quality of safety related structures, components, and related consumables during plant operation, maintenance, testing, and all des! nE 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 uccessary by " 'l management, applicable portions of the QA program controls will be applied to nonsafety. i related activities associated with the implementation of ,
the QA program to ensure that commitments are met (e.6 .
off site records storage, training services, etc.).
1.7-38 July 1997
_ _ _ , . _ _ , . _ . . , . . _ . . _ . ~ . - . , . _ . , , _ _ _ _ _ . _ _ _ , _ -.
i
< i l
1.7.2.2.3 t
This QAPD, organized to present the QA Program for the Cook Nuclear Plant in the order of the 18 criteria of 10CFR$0, I Appendix B, states !&N policy for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this QAPD 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 QAPD that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation. The t
submittal of the changes described above shall be made in accordance with the requirements of 10CFR50.54.
The program described in this QAPD will not be intentionally changed in any way that would prevent it from r eeting the criteria of 10CFR50, Appendix B and other applicable operating license requirements.
1.7.2.2.4 Documents used for implementing the provisions of this QAPD include the following: i Plant Manager Instructions (PMIs) establish the policy at the plant for compliance w'th specified critetia, and assign responsibility to the various departments, as required, for implementation. Plant Manager Procedures (PHPs) Department Head Procedures (DHPs), and in some cases Department Head Instructions (DHIs), have been 4
1,7-39 July 1997
. - . - . , . , - , - _ , . _ . . . _ _ _.m - - ,,
1 prepared to describe the detailed activities required to support safe and effective plant operation as per the PMIs.
The PMIs are reviewed by performance [assuran'cesfor concurrence that they will satisfactorily implement regulatory requirements and commitments. PMIs and PMPs are reviewed by the PNSRC prior to approval by the site vice president , ,g.
DllPs and Dllls are reviewed within the departments prior to approval by the department head of origination. DilPs and DHis that might involve an unreviewed safety question as defined in 10CFR50.59 are reviewed by PNSRC prior to approval by the department head of origination.
AEP Nuc1Lar Organization Policy & Procedure Manual and General Procedures (cps) are utilized to define policies and requirements for quality assurance, and to implement certain QA program requirements. !)/ Division / department and/or section procedures are also used to implement QA program requirements.
When contractors 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 QA Program and the contract, and are approved by peiformancefAssurance prior to the start of work. Implementation of on-site contractor's QA programs, will be audited to assure that the contractor's programs are effective.
1.7-40 July 1997
s 1.7.2.2.5 Provisions of the QA program for the Cook Nuclear Plant apply. to activities affecting the quality of safety related items. Appendix A to this QAPD lists the Regulatory / Safety Guides and ANSI Standards that identify I&M commitment.
Appendix B describes necessary exceptions and-clarifications to the requirements of thoae documents. The scope of the program, and the extent to which its controls are applied, are established as follows:
a) T&M uses the criteria specified in the Cook Nuclear Plant Updated FSAR for identifying structures, systems and components to which the QA 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 engineering analysis of the function (s) of plant items in relation to afe operation and shutdown, c) The extent to which ca.ttrols specified in the QA 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.
1.7-41 July 1997
t '
4 = y a
- APPendiMt61thisir)APD ilden t i fie s P a dminis t'ra t ive 3 orit iol s [
r lsuchTas onsite~'andloffsitM revioW2committe# astivities?
- Meh?oith4{3#pl6mengoCsompjementUthe3d411ti assurarice programZdasoribeth6reini 1 7.2.2.6 s :
, - Activities'affecting safety related items are accomplished
- onder controlled conditions.- Preparations for such activities include consideration of the following: '
1 a) Assigned personnel are qualified.
- b) Work has been planned to applicable engineerin6 and/or Technical Specifications, c) - Specified equipment and/or tools are available. '
s d) Items are in an acceptablo status, e) Items on which work is to bo performed are in the proper condition for the task. ,
f) Proper approved instructions / procedures for the work are available for use- i g) Items and-facilities that could be damaged by the -'
work have been protected, as required. -t j h) Provisions have been made for special controls, t processes, tests and verification methods.
{
1.7.2.2.7
{- Responsibility and authority for planning and implementing indoctrination and training of I&M personnel are *
- specifically designated, as follows:
i a) The-training:and indoctrination' program provides for on going training and periodic familiarization with -
the QA-program for the Cook Nuclear Plant.
D-4 1.7 42 July 1997 o
4 1
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b) Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.8, MtSI N18.1, Regulatory Guide 1.58, ANSI N45.2.6, the ASME B&PV Code, or SNT TC 1A, as applicable, and with exceptions as noted in Appendix B hereto, c) Performanceiassurance 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 is 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.
1.7-43 July 19S7
Management / supervisory personnel receive functional training to the level necessary to plan, coordinate and administer the day-to-day verification activities of the QA Program for which they are responsible, Training of 16M personnel is performed employing 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 ,l? training department or other entities (internal and external to the AEP System);
and 3) formal, INPO accredited training conducted by the training department. Records of training sessions for such training are maintained. Where personnel qualifications or certifications are required, these certifications are performed on a scheduled basis (consistent with the appropriate code or standard),
Cook Nuclear Plant employees receive introductory training in quality assurance usually within the first two weeks of employment. In addition, I&M personnel receive training I
(
prior to being allowed unescorted access to the plar i .
This training includes management's policy for implementation of the QA program through plant manager and department head instructions and procedures. These instructions also include a description of the QA program, the use of instructions and procedures, personnel requirements for procedure compliance and the systems and components controlled by the QA program.
1.7-44 July 1997
[
1.7.3 DESIGN CONTROL 1.7.3.1 SCOPE Desi6n changes are accomplished in accordance with approved design. Activities to develop such desi Fns are controlled.
Depending on the scope of the 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 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 i 1.7.3.2.1 Design changes are controlled by procedures and instructions and are reviewed as required by 10CFR50,59 and the Technical Specifications.
Safety related and non safety related design changes are implemented via Design Change Packages (DCPS).
1.7.3.2.2 Design changes are reviewed to determine their impact on nuclear safety and to determine if the proposed changes 1.7-45 July 1997
~ involve an unreviewed safety question as defined by 10CFR50.59. If a design change were to involve an unreviewed safety-question, it would not be approved for implementation until the required NRC approval was received.
Design' Change' Packages (DCPs) are reviewed and approved ,
prior to implementation,yT by the DCPJteimimemberslandy cognizant M 'j managers. The PNSRC also reviews those DCPs, for which safety evaluations are deemed necessary, pursuant to 10CFR50.59 and Technical Specification 6.5.1.6.
1.7.3.2.3 When DCPs 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 g _
organization having responsibility for engineering direction of the design effort.
1.7-46 July 1997
. . ~. . .- . _ . . . . . -
1.7.3.2.4.
Checks are performed and documented to verify ties dimensional accuracy and completeness of design drawings and specifications.
1.7.3.2.5 Design change document packages are audited by performance anyurAnce to assure that the documents have been prepared, verified, reviewed and approved in accordance with company procedures. ,
1.7.3.2.6 -
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 stato-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 singly or in combination, depending on the needs for the design under.
consideration.
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.
1.7-47 July 1997
Qualification testing of prototypes, components, or ,
features is used when the ability of an item to perform an essentia1' safety function cannot otherwise be adequately '
substantiated. This testing is performed before plant equipment installation,_where possible, but always before i 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 a
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 i clearly documented.
Design reviews are performed by multi-organizational or interdisciplinary 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.
1 4
, 1.7.3.2.7 Persons representing applicable technical disciplines are-assigned to perform desiga verifications. These persons are qualified by appropriat 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.
2L 1.7-48 July 1997
- 2) The supervisor has not specified a singular design approach, ruled'out design considerations, nor established the design inputs.
And
- 3) The need is_ documented and approved by the supervisor's management.
Regularly scheduled QA audits verify conformance to previous items 1 through 3.
Design verification of safety related design changes shall be completed prior to declaring a design change, or portions thereof, operational.
1.7.3.2.8 Implementation of design changes is coordinated on site by nuslear engineeringj Material to perform the design change must meet the specifications established for the original system..or as specified by the DCP. For those design ,
changes where testing af ter completion is required, the testing documentation is reviewed by the organization performing the test and, when specified, by the DCP.
Further, completed design changes are audited /surveilled by performanceias'surance following installation and testing.
1.7.3.2.9 Changes to design documents, including field changes, are reviewed, approved and controlled.in a manner commensurate with that used for the original design. Such changes are 1.7-49 July 1997 i
l l
l
O evaluated for impact. Information on approved changes is transmitted to all affected organizations.
1.7.3.2.10 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.
1.7.3.2.11 Eatablished design control procedures provide for:
- 1) controlled submission of design changes,
- 2) ens i ncering evaluation,
- 3) review for impact on nuclear safety,
- 4) audit by pe'rformancefassurance;
$) design modification, !
~
- 6) managerial review, and
- 7) 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 applicabic regulatory and industry codes / standards requirements, and specify supplier QA Program requirements to the extent necessary to assure adequate quality.
1.7-50 July 1997 l
l.7.4.2 IMPLEMENTATION 1.7.4.2.1 Procurement control is established by instructions and procedures. These documents require that procurement documents be sufficiently detailed to ensure that purchased safety-related items and services 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 commercial grade dedication process.
Procedures establish the review of procurement documents to determine that: appropriate technical and quality requirements are correctly stated, inspectable and i controllable; there are adequate acceptance criteria; and procurement documents have been prepared, reviewed and approved in accordance with established requirements.
The manager of the originating group, with support of the cognizant S engineering group, is responsible for assuring that applicable requirements are set forth in procurement documents.
The I&M may use' cognizant engineers in any procurement activity.
1.7-51 July 1997
l 1
f 1.7.4.2.2.
The Facility Data Base, in conjunction with other sources, is used for equipment safety classification and procurement grade. Engineering 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 safety-related 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.
Procurement documents for new safety related items are initiated by the cognizant engineering group which establishes initial requirements.
Replacement / spares are purchased to requirements equivalent to the original unicas 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 QAPD are considered for application to service contractors, also. As applicable, procurement documents include:
a) Scope of work to be performed.
1.7-52 July 1997
I:-
.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 MjjI&M 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 1;jI&M relies on suppliers to invoke guides / standards. ? (i;I&M recognizes that certain suppliers have acceptable 10CFR50, Appendix B QA programs, even though, 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 6 (I&M ,
- JI&M will assure that (1) the supplier's QA program provides adequate QA controls, regardless of the lack of specific commitment, or (2) controls will be invoked directly by '2 (I&M to assure adequate-quality of items / services received by suppliers, c) Regulatory, administrative and reporting requirements, d) Quality requirements appropriate to the complexity and-scope of the-work, including necessary tests and/or inspections, e) A requirement for a documented QA Program, subject to QA review and written concurrence prior to the start of work, f) A requirement for the supplier to invoke applicable quality. requirements on subtier suppliers.
1.7-53 July 1997
g) Provisions for access to supplier, and subtier suppliers', facilities and records for inspections.
-surveillances and audits.
h) Identification of documentation to be provided by the supplier, the schedule of submittals and documents requiring I&M approval.
1.7.4.2.4 Performancefa'ssurance performs audits of procurement docu-ments to assure that QA program requirements have been met.
These audits are conducted in accordance with pe'rformance assurance procedures, 1.7.4.2.5 Changes to procurement documents are controlled in a manner commensurate with that used for the original documents.
4 1.7.5 INSTRUCTIONS, PROCEDURES, AND DRAVINCS 1.7.5.1 SCOPE Activitics 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.
1.7-54 July 1997
1.7.5.2- IMPLEMENTATION 1.7.5.2.1 Instructions and procedures incorporate: 1) a description of the activity to be accomplished, and 2) appropriate quantitative (such.as tolerances and operating limits) and qualitative (such as workmanship and standards) acceptance criteria sufficient to determine that the activity has been satisfactorily accomplished. Hold points for inspection are established when required.
Instructions and procedures pertaining to the pecification of, and/or implementation of, the QA Program receive multiple reviews for technical adequacy and inclusion of appropriate quality requirements. Top tier instructions '
and procedures that define the quality assurance program requirements are reviewed and/or approved by performance assurance. 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 QA Program for which they are responsible.
Special procedures may be issued for activities which have short term applicability.
1.7.5.2.2 I&M activities are outlined by procedures which provide the controls for the implementation of these activities. I&M hus the following categories of QA program implementation procedures:
1.7-55 July 1997
1)' Cencral Procedures (gps) -Plant Manager's Instructions (PMI's) and American Electric Power Nuclear Organization Procedures (AEPN0s) which are applicable to part or all organizations involved with
-Cook Nuclear Plant.
2 ). Organization procedures which apply to the specific division, department or section involved.
- 1.7.5.2.3 The procedures controlling I&M activities are classified !
into-the following series:
1000 Personnel Selection, PNSRC Procedures 2000 Administration - Document Control, Security, Training, Records, Emergency Plan, Firo Protection, Clearance Permits, Chemical Control, Internal Cleanliness, Spill Response, Standing orders, Corrective Maintenance.
3000 Procurement, Receiving, Shipping and Storage 4000 Operations, Fuel Handling, Surveillance Testing, Test Controls 5000 Maintenance, Repair, Modification, Special Processes, EQ and ISI Control of Contractors 6000 Technical - Chemistry / Radiological Controls, Radiation Protection, Performance / Engineering Testing, and Instrument and Control Maintenance and Calibration, Measuring and Test Equipment 7000 Quality Assurance, Quality Control Program and Condition / Problem Reporting 1.7-56 July 1997
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 to implement their requirements, or provide comprehensive guidance based on the subject matte .
1.7.5.2.4 Cook Nuclear Plant drawings are produced, controlled and ;
distributed under the control of I&H. I&M design drawings are produced by, or under the control of, 7% nuclear engineering under a set of procedures which direct their development and review. These procedures specify requirements for inclusion of quantitative and qualitative ,
acceptance criteria. Specific drawings are reviewed and approved by the cognizant engineering organization.
I&M has stationed an on site design staff to crovide for the revision of certain types of design drawings to reflect as-built conditions.
1.7.5.2.5 Complex ,
procedures thts are specific to Cook Nuclear Plant site are designated as "In Hand" procedures, Examples of "In Hand" procedures are those developed for extensive or complex jobs where reliance son 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, 1.7-57 July 1997
-u-..s- y - m A
_._. . - - _ = - . - - _
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.
Chaages to controlled documents are reviewed and approved by the same organizations that performed the original review and approval, or by other qualified, responsibic orSanizations specifically designated in accordance with the procedures governing these documents, Obsolete or superseded documents are controlled to prevent inadvertent use.
1.7.6.2 IMPLEMENTATION 1.7.6.2.1 Controls are established for approval, issue and chcnge of documents in the following categories:
a) Design documents (e.g., calculations, specifications, analyses) b) Drawings and related documents c) Procurement documents 1.7-58 July 1957
d)- Instructions and procedures -
e) Updated Final Safety Analysis Report (UFSAR) f) Plant Technicalz Specifications g) 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 desi 6nated in accordance with the procedure governing the review and approval of specific types of documents.
1.7.6.2.3 Documents are issued and controlled so that:
a)- Tlus documents are available prior to commencing work, b) Obsolete documents are replaced by current documents in a timely manner.
1.7-59 July 1997
i 1.7;6.2.4 Master lists, or equivalent controls, are used to identify the current revision of instructions, procedures -
specifications and drawings. These' control documents are updated and distributed to designated personnel who are responsible for maintaining current copies of the applicable documents. The distribution of controlled documents is performed under procedures requiring receipt acknowledgement and in_accordance with established distribution lists.
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 Master 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 Master Plant File drawing. !
1.7.6.2.6 Documents prepared for use in training 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 the Cook Nuclear Plant, unless a document is identified as 'contro11ed' or
' working copy' only, it is automatically assumed that the document is for information use only.
1.7-60 July 1997
1.7.7 CONTROL OF PURCHASED ITEMS AND SERVICES 1.7.7.1 SCOPE Activities that implement approved procurament requests for items and services are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection audito, 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 availabic to the Cook Nuclear Plant site prior to use of equipment, material, or services.
1.7.7.2 IMPLEMENTATION 1.7.7.2.1 I&M qualifies suppliers (including distributors to the extent they perform quality related activities) 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 QA programs have been accepted in accordance with 1&M requirements, or from commercial grade suppliers through the I&M dedication program. Suppliers of other items / services are subject to evaluation and approval based on acceptance criteria applicable to those items / services.
Qualification of such suppliers is determined by performance [assuranbe. In the discharge of this responsibility, performance"assurunce may use information generated by other utilities. The supplier must be 1.7-61 July 1997
approved before procurement can be completed. 1&M is a member of the Nuclear Procurement issues Committee (NUPIC),
participates- in joint supplier audits, and shares audit information consistent with NUPIC requirements. The supplier must be acceptable, or acceptable subject to follow up, before a procurement can be approved and processed. Additional audits will be conducted, as necessary, to meet requirements. Acceptance is not complete until it has been determined that the suppliers' QA 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 application-specific requirements cannot be contractually imposed in a practical manner at the time of procurement, programs for dedication to safety related standards are established by engineering personnel and accomplished prior to the item being accepted for safety related use, 1.7.7.2.3 In process audits of suppliers' activities during fabrication, inspection, testing and shipment of items are performed when deemed necessary, depending upon supplier qualification status, complexity of the item (s) being furnished, the items' importance to safety, and/or previous supplier history. These audits are performed by performance [Assu'r'ahce! The cognizant engineer and/or responsible Cook Nuclear Plant personnel may also participate, if deemed necessary.
1.7-62 July 1997
, 1.7,7,2.4
-Spare and replacement parts are procured in such a manner [
I
-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 i original, c) Where quality requirements for-the original items r
-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 4
after-previous-procurement of the item (s), are identified and incorporated, a
d 4
1.7-63 July 1997
I-1.7.7.2.5 Instructions and procedures address the requirements for supplier selection and control, as well as procurement document control, The program for receipt inspection of safety related items addresses inspection of incoming items, including a review of the documentation require'd under the procurement. Receipt inspection personnel sre qualified and certified in accordance with the requirements of ANSI N45.2.6. Provisions for receipt inspection apply regardless of whero the procurement originates. Additional inspections may apply if required by the procurement document.
Items, which have special procurement requirements (such as nuclear fuel and nuclear fuel components), may involve detailed source evaluations or audits at the supplier's facility prior to shipment to supplement receipt inspection. Personnel performing these evaluations and audits will be qualified in accordance with ANSI N18.1 i and/or ANSI N45.2.23. Receipt inspections at the site will i be performed by personnel certif.ted to ANSI N45.2.6. In addition, reviews of special procurement documents or shipping manifests will be performed by personnel trained in the procurement and qualified in accordance with ANSI N18.1.
Where items and/or services are safety-related and procurement is accomplished without assistance of I&M, supplier selection is limited to r: hose companies identified as being qualified.
1.7-64 July 1997
7 1.7.7.2.6 Items received at the site. are tagged with a " HOLD" tag and/or placed in-a designated area (e.g., new nuclear fuel) until receipt inspected. During receipt inspection, designated material characteristics and attributes are checked, and documentation is checked against the procurement documents. When the receipt inspection of items is supplemented by source evaluations or audits at the vendor prior to shipment, appropriate visual and/or mechanical inspections will be completed to ensure that shipping damage has not occurred If found acceptable, the
" HOLD" tag is removed and replaced with an " ACCEPTED" tag and/or the item is placed in a designated area.
Item traceability to procurement documents and to end use is maintained through recording of identification numbers or, " HOLD" and " ACCEPTED" tag numbers on applicable documents.
i Nonconforming items, or missing or questionable -l documentation results in. items being placed on " HOLD" and maintained in a designated, controlled area. If the nonconformance cannot be cleared, the item is either scrapped, returned to manufacturer, or dispositioned through en61 neering analysis.
1.7.7.2.7 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 1&M QA Program and procederes. Prior to their working at 1.7-65 July 1997
the Cook Nuclear Plant, contractors working under their own quality assurance programs must be audited and approved by performance] assurance. Contractor procedures must be reviewed and approved by the originating /sponsorins '
department head. Further, periodic audits of site contractor activities are conducted under the direction of a
'[j performance assurance 4
7 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 b;ylI&M.
4 To the extent prescribed in specific procurement agreements, suppliera are required to maintain additional (backup) documents in their record system.
In some cases, such as with NSSS, suppliers are designated primary record retention responsibility, i
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.
1.7-66 July 1997
l 1.7.8 IDENTIFICATION AND CONTR01, 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 traceabic 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 applicabic drawings, specifications, or other pertinent documents to ensure that only correct and acceptable items are used. Verification of traceability is performed and documented prior to release for fabrication, assembly, or installation.
1.7-67 July 1997
)
-1.7.8.2,4 !
1 Requirements for the identification by use of heat number,
. part number, serial number, etc., are included in engineerths specifications
- and/ or the procurement document, i
1.7.8.2.5 4 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' usage 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, appropriato identification numbers are transferred to each section of the material, or traceability is maintained through documentation.
1.7.9 CONTR0b 0F SPECIAL PROCESSES 1.7.9.1 SCOPE Special processes are controlled and accomplished by qualified' personnel using approved precedures and equipment in accordance with applicable codes, standards, specifications, criteria and other special requirements.
1.7-68 July 1997 en w w me p/m tr - +- e2*eF'.w---f+"
- . .- -. .- - - - _ - . - . . = - ~ -. . - -
1.7.9.2 IMPLEMENTATION 1.7.9.2.1 1
processes subject to special process controls are those for which full verification or characterization by direct inspection is impossible c.1:npractical. Such processes 1
include welding, hont treating, chemical cicaning, ,
I
. application of protective coatings, concrete placement and NDE.
1.7.9.2.2 Special process requirements for chemical cicaning, application of protective coatings and concrete placement are set forth in chgineering specifications ~/
dedication plans and/or directives prepared by the responsibic , co6nizant engineer. These documents are reviewed and approved by other personnel with the necesr.ary I technical competence.
Special process requirements for welding, heat treating and NDE are set forth in engineering specifications, the Welding , Manual; and plant procedures. Specini '
process; requirements'for! welding and hear treating are
~
preparedLbyl,or,are' reviewed;and' approved by, the. cognizant engineer:woldingL (Special process requirementsifor.NDE'are prepared;by. lor"are reviewed and ipprovedibyi .the NDE adm7.istrator(and/cy Cook Nuclear. plant? NDEl Level III pe r'sonnel?
Special process procedures, with the exception of welding and heat treating, are prepared by Cook Nucicar plant personnel with technical knowledge in the discipline 1.7-69 ' July 1997
. i I
i involved. These procedures, which are also reviewed by l l
l other personnel with the necessary technical competence, :
are qualified by testing.
Welding is performed in accordance4 with procedures contained in the f5] Welding Manual, or by approved contractor's procedures. These procedures are qualified in ;
accordance with applicable codes, and Procedure Qualification Records are prepared. Weld procedure- ,
i . specifications are reviewed and approved by the Et t
- cognizant engineer + velding. Weld procedure qualification- l documentation is retained in the AEP Wolding Manual, or the -f approved contractor's manual.
Contractor welding procedures are qualified by the
]
contractor. These procedures and'the qualification-documentation are reviewed and approved by the ['f]
cognizant engineer welding. This documentation is retained I by the contractor.
1.7.9.2.3 :
NDE personnel are qualified and certified by a Cook Nuclear Plant.NDE level-III who has been qualified and certified by the designated gf,y NDE administrator. Certification is by examination. Personnel qualification is kept current by re examination at time intervals specified in qualification / certification procedures which are in accordance with the ASME Code.
4 e
J1.7-70 July 1997
. $l
i l
Cook Nuclear Plant welders are quallfled by the maintenance ,
organization;[and/or'the;projectmanagementand installation'aerviccaforganization using y. , approved kelding procedurea specifications. T Administration of Cook i Nuclear plant welder qualifications is performed by the maintenance, and/or;the project'managementf and" installation i seryice? organizations. Examination of qualification !
specimens is performed under the supervision of the performance assurance orgsnt'ratf orj in accordance with the Wolding Manual andLnuclearLengineering; specifications ,
covering welder qualification. Cook Nuclear Plant wolder qualification records are maintained for taa,Lutenanceftind
'ontracter weldern by nucladt engineering. Contractor c f welders are qualified by the contractor using procedures '
approved by the , cognizant engineer welding in accordance with I&M procedures. Contractor qualification .
records are maintained by the contractor.
1.7.9.2.4 ;
QC/NDE technicians assigned to s , performance assurance perform nondestructive testing for work performed by Cook Nuclear plant and contractor personnel. Thero individuals are qualified to either SNT.TC 1A, or ANSI N45.2.6, and records of the qualifications / certifications are maintained bylI&ML 1.7,9.2.5 For special processes that require qualified equipment, so:h equfpment la qualified in accordance with applicable coden, standards and specifications.
1.7-71 July 1997
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1.7.9.2.6 Special proceses qualifications are reviewed during regularly scheduled QA audits. Qualification records are maintained in accordance with 1.7.17 herein.
1.7.9.2.7 The documentation resulting from welding and nondestructive i testin6 is reviewed by appropriate personnel.
1.7.10 INSPECTION 1.7.10.1 SCOPE Activities affecting the quality of safety related i structures, systems and components are inspected to verify their confstmance with requirements. These inspect'.ons 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 specified requirements, 1.7-12 July 1997
I 4
lloid points are provided in the sequence of procedures to allow for the inspection, witnessing, examination, measurement, or review necessary to assure that the
- critics 1, or irreversible, elements of an activity are being performed as required. Note that hold points may not i
- apply to all procedures but each procedure"which includes !
- inspsetions must be reviewed for this attribute.
lloid points specify exactly what is to be done (e.g., type l of inspection or examination, etc.), acceptance criteria, or reference to another procedure, etc., for the '
i satisfactory completion of the hold point. When hold pointslare 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. i 1.7.10.2,2 L i
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.
r 1.7,10.2.3 Inspection requirements are specified in procedures,
-instructions, drawings or checklists as applicable. They provide for the following, as appropriate:
1.7-73 July 1997
_ . - , ._ - ~ , . - _ , _ _- . _ _ _ - , , , . _ - _ _ _ . . . . _ _ _ _ _. ~ - - _- . - _ _
. _ - . _ _ . ___ ____ _ _ _ _ _ - _ _ _ _ _ . _ . - ~ - _ . _ _ _ _ _ _ _ - _ - _ _ . _ _ - - - _ _ _ _ .
a) Identification of applicable revisions of required instructions, drawings and specifications, b) Identification of characteristics and activities to be inspected.
c) Inspection methods.
- l d) Specification of measuring and test equipment having.
the necessary accuracy.
1 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. -
4 1.7.10.2.4 Inspections are conducted using the following programs:
- a. Peer Insocetion Procrqm. The Peer Inspection Program is based on the premise that I&M personnel are qualified to ANSI N18.1 (1971), Selection and Traininc of Nuclear Power-Plant Personnel, and are periodically trained in their skill area using INPO accredited training. As a result of their experience, qualifications, and training, I&M personnel may perform inspections of work functions associated with normal operation of the Plant, routine maintenance, and certain routine technical 1.7 74 July 1997 2
-- , , - , - , r - u - - .n,-- -
v-
activities which are routinely performed by 1&M i personnel (peers). Peer in6pection personnel are independent in that they do not perform or directly supervise the work being inspected, but they may be from the same work group..
- b. ANSI N45.2.6 Inspection Procram. . Major modification r and non routine maintenance work on safety related l equipment is inspected per. ANSI N45.2.6, Ou211fications of Inspection. Examination. and :
Testine Personnel for Nuclear Power Plants; whether it is performed by 16M or contractor personnel. All safety related work performed by contract personnel is inspected per ANSI N45.2.6. Inspections of these work activities are performed by inspectors qualified <
and certified in accordance with Regulatory Guide ,
1.58 and ANSI N45.2.6. Contractors performing work
, on safety related equipment are required tu comply l with the applicable requirements of Regulatory Guide 1.33 and ANSI N45.2. !
1.7.10.2.5 Inspections associated with the packaging and shipment of radioactive vaste and materials are conducted using the following program: ,
a) NRC Licensed Packacines - Inspections of NRC licensed radioactive material packagings shall be performed by
- individuals independent from the work being performed. The independent inspectors shall be I&M personnel, qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1, as a minimum.
1.7-75 -July 1997 t
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Additionally, the inspector shall be familiar with the activities being performed.
b) Non NRC Licensed Packagings and Containers .
Inspections of non.NRC licensed radioactive laaterial packagings and containers (shipping and/or burial) !
shall be performed by 16N personnel, qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1, as a minimum. ;
c) Transportation Vehicles . Inspection of ;
transportation vehicles being shipped as " exclusive use", shall be performed by I M personnel, qualified ,
in accordance with Regulatory Guide 1,8 and ANSI N18.1, as a minimum, d) Other inspections and Verification Inspections and I verifications of-other activities associated with the l packaging and shipment of radioactive materials and waste shall be performed by IM personnal, qualified in accordance with Regulatory Culde 1.8 and AN.sl N18.1, as a rainimum, 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, 1.7-76 July 1997 ,
-,e w. . . . ____,.-..,_m .,m.,. , , _ , ,o,.t-. --,.,- e ,-- . -.,..e _, _ , , e.,.-...- ...#.,...., ,, . . . . , _ . . , . -_- . . . . , . _
-_ . . . .. . - ~ _ - _ - . - . - . . . . - - - . - . - - . - - . . . . . - . -
1.7.11 TEST CONTROL 1.7.11.1 SCOPE 4
Testing is performed in accordance with established l programs to demonstrate that structures, systerno and component 9 will perform satisfactorily in service. The testing is performed by qualified personnel in accordance .
with written procedures that incorporate specified requireinents and acceptanco criteria. Types of tests are:
Scheduled Surveillance, preventive maintenance, post design, qualification.
Unscheduled Pre.maintenanca and post maintenance.
Test parameters (including any prerequisites),
instrumentation requirements, and environrnental conditions are specified in test procedures. Test results are documented and evaluated.
1.7.11.2 IMPLEMENTATION 1.7.11.2.1 Tests are performed.in accordance with programs, procedures and criteria that designato when tests are required and how they_are to be performed. Such testing includes the following:
1,7 77 July 1997
i i
a) Qualification tests, as applicable, to verify design adequacy, 1
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 3
operation, d) Surveillance tests to assure continuing proper and safe operation of systems and equipment. The PMI on surveillanca testing controls the periodic testing of equipment and systems to fulfill 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. Data 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) Maintenance tests after preventive or corrective ,
maintenance.
1.7.11 2.2 Test procedures, as required, provide mandatory hold points for witness or review, 1.7-78 July 1997
1.7.11.2.3 i TestinC is accomplished after installation, maintenance, or repair, by surveillance test procedures, or performance tests, which must be satisfactorily completed prior to .
I determining the equipment is in an operable status,-except forl Technical Speciff eation equipment addressed in section l
1.7,11.2;4 below; All data resulting from these tests is j retained at the Cook Nuclear Plant after review by appropriate management personnel.
1.7.11',2.4 Technica1' Specification equipment"can?be" considered operabloiprior to tho Luatisfactory completion of tests when Technical Specificat'.on aurveillance
~
requirements provideLan: allowance of time)to analyze test results.
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
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structures, systerns and components. These procedures and instructions describe calibration techniques and ,
frequencies,- and maintenance and control of the equipment. i Performancej. assurance periodically assesses the i effectiveness of tha calibration program via the : audit l program.
J 1.7.12.2.2 ,
Measuring and test equipment is uniquely identified and is traceable to its calibration source.
I 1.7.12.2.3 l r
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 i 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 af fect the required measurement accuracy.
Calibration standards are traceable to nationally l recognized standards; or where such standards do not exist, proviulons are established to document the basis for T
calibration.
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i The primary standards used to calibrate secondary standards have, except in certain instances, an accuracy of at least i 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 responsibic 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
- When measuring and testing equipment used for inspection '
and testing is found to be outside of required accuracy limits at the time of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration. Retests, or reinspections, are performed on suspect items. The results of evaluations are documented. r 1.7.13 IIANDLING, STORAGE AND Si!IPPING 1.7.13,1 SCOPE Activities with the potential for causing contamination or deterioration, by environmental conditions sach as temperature or humidity that could adversely. affect the 1.7 81 July 1997 4
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l 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 l l
Procedures are used to control the cleaning, handling, storing, packaging, preservin6 and shipping of materials, components and systems in accordance with designated procurement requirements. These procedures include, but '
are not limited to, the -! allowing functions:
a) Cleaning . to assure that required cleanness levels are achieved and maintained.
b) Packaging and preservation - to provide adequate protection against damage or deterioration. When necessary, those procedures provide for special environments, such as inert gas atmosphere, specific moisture content levels and temperature icvels.
a c) _ llandling to preclude damage or safety hazards, d)- Storing to minimize the possibility of loss, damage or veterioration of items in storage, including consumables such as chemicals, reagents and lubricants .-
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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 Nucicar Plant. Controls are established in plant procedures.
1.7.13.2.3 Packaging and shipping requirements are provided to vendors in engineering specifications (DCCs) which are a part of the procurement document, or are otherwise specified in the procurement document. 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 steci components and saaterials 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 perishabic 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 cleanness of the storage area.
1.7-83 July 1997
1 l
1.7.13.2.5 i
special handling procedures have been impleinented for the processing of nuclear fuel durin6 refueling outages. These I
procedures minimize the risk of darnage to the new and spent fuel and the possible release of radioactive reatorial when placing the spent fuel into the spent fuel pool.
I 1.7.14 INSPECTION, TEST, AND OPERATING STATUS l l
1.7,14.1 SCOPE operating status of structures, systerns and components is indicated by ta561 n6 of valves and switches, or by other specified means, in such a manner as to prevent inadvertent i operation. The status of inspections and tests performed 4 on individual iterns 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, systerns 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 1.7-84 July 1997
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inspection status. The Clearance Permit System uses [
t various tags to identify equipment and system operability ;
1 status, Another program establishon 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.
1.7.14.2.2 f
f 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 identified as lloid, lloid for '
Quality Control Clearance, Reject, or Accept, f
a The inspection status of work in progress is controlled by ;
the use of hold points in procedures. Performance assurance, 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 veld.
1.7-85 July 1997
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I 1.7.14.2.3 !
Required surveillance test procedures are defined in PMIs. l "These instructions provide for documenting bypassed tests !
and rescheduling of the test.
4 The status of testing after minor maintenance is recorded as part of the Job Order and/or procedure. The status of
- testing af ter major maintenance is included as part of the procedure, and includes the performance of functional 3 testing and approval of data by supervisory personnel. ,
P Testing,-inspection and other operatiors important to ,
safety are conducted in accordance with properly reviewed and approved procedures. The PM1 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 i same controls as the original review and approval. When an ,
immediate procedure change is required to continue in- j
. 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 PM1 on ;
plant procedures.
1.7.14.2.4 Nonconforming, inoperable, or malfunctioning structures, I systems and components are clearly identified by tags, stickers, stamps, etc., and documented to prevent inadvertent use.
i 1.7-86 July 1997
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l 1.7.15 NONCONFORMING ITEMS 1.7.15.1 SCOPE ,
Materials, 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 IMPLEMENTATION 1.7.15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which render the quality unacceptable or indeterminate, are identified as nonconforming and any further use is controlled.
Nonconformances are documented and dispositioned, and notification is made to affected organizations. Personnel -
authorized to disposition, conditionally release and close out nonconformances are designated, a The Job Order System and/or the Condition Reports (refer to 1.7.16 herein) are used at Cook Nuc1 car 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 materials which require repair or inspection are controlled under the Job Order System. In addition, the various procedures identified in 1.7.14 herein provido for identification, segregation and documentation of nonconforming items, 1.7 87 July 1997
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1.7.1$.2.2 i i
Nonconforming items are identified by marking, tagging, segregatin6, 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.
I
, Completed Job Orders are reviewed by the supervisor !
responsible for accomplishing the work, and the supervisor i of the department /section that originated the Job Order. ,
- PerformanceTassurance periodically audits the Job Order i System, and on a sample basis, Job Orders.
1.7.15.2.3 ;
Items that have been repaired or reworked are inspected and I tested in accordance with the oriS inal inspection and test {
requirements, or alternatives, that have been documented.
r Items that have the disposition of " repair" or "use as is" require documentation justifying acceptability. The I 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.
1.7-88 July 1997 e e e n , . , ~ -. r- ,--,..r,..,--s- ...-,..,.- - - - - . - , - ,, - - , . - - , , - - < . . , -v v , . . . - - , , ..v.
s 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 condition, and preventive action is ;
implemented to prevent recurrence. In these cases, the condition, cause and corrective action taken is documented and reported to appropriato levels of tnanagement.
1.7.16.2 IMPLEMENTATION 1.7.16.2.1 ,
Procedures are established that describe I&M's corrective action program!. These procedures are reviewed and l concurred with by performance assurance. ,
1,7.16.2.2 Condition Reports and audit / surveillance reports provide th9 mechanism for I&M personnel to notify management of ,
conditions adverse to quality. Condition Reports are als',
used to report violations to codes, regulations and the Technical Specifications. Investigations of reported conditions adverse to quality are assigned by management.
The Condition' Report is used to document the investigation of an adverse condition; and to identify the need for a design change to correct system or equipment deficiencies, t
1.7-89 July 1997
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I or to identify the need for the initiation of Jon Orders to correct minor deficiencies. In the case of significant conditions adverse to quality, Condition Reports are used to identify those actions necessary to prevent recurrence of the reported condition.
)
., The PNSRC evaluates actions taken or being taken to correct i and prevent recurrence of the deficiency for condition reports involving:
- a. a violation of Technical Specification ;
- b. a reportable event {
- c. any accidental, unplanned, or uncontrolled ;
radioactive release
- d. a nafety related adverse trend
- e. a potential nuclear safety hazard
- f. an entry into Technical Specification LCO 3.0.3 (failure to comply with LCO's not containing specific shutdown schedule)
- g. a Technical Specification LCO entry that was the result of personnel error The NSDRC is responsible for assuring that independent reviews of violacions (as spectiicd in the Technical Specifications) are performed. These violations are considered significwnt conditions which are documented on Condition Reports. The revieva will provide an independent evaluation of the reported conditions and corrective actions.
PerforaAncelausurance pedodically audits the corrective act. ion system for compilance and effectiveness.
1.7*90 July 1997
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I 1.7.17 QUALITY 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 IMPLEMENTATION 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) Results of reviews, inspections, surveillances, tests, audits and material analyses.
b) Qualification of personnel, procedures and equipment, c) Operation logs, d) Maintenance and modification procedures and related inspection results.
e) Reportable occurrerces, f) Records required by the plant Technical Specifications, g) Condition Reports.
h) Other documentation such as drawings, specifications, dedication plans, procurement documents, calibration procedures and reports.
- 1) Radiographs.
1.7-91 July 1997
l 1.7.17.2.2 Instructions and procedures establish the requirements for the identifiestion and preparation of records for systems and equipment under the QA Program, and provide the controls for retention of these records.
Criteria for the storage location of quality related records, and a reter. tion 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 or,en established for limiting access to the Plant Master File to prevent unauthorired entry, unauthorized removal, and for use of the records under emergency conditions. The Nuclear Records Management Supervisor is responsible for the control and operation of the Plant Master File Room.
1.7.17.2.3 Within 16M, each manager is responsible for the identification, collection, maintenance and storage of records generated by their organization. Procedures ensure the maintenance of records sufficient to furnish objective evidence that activities affecting quality are in compliance with the established QA Program.
1.7-92 July 1997
1.7.17.2,4 n
When a document becomes a record, it is designated as permanent, or nonpermanent, and then transmitted to ille.
Nonpermanent records have specified retention times.
-Permanent records are maintained for the itfe of the plant or equipment, es 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.
1,7.17.2.7 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, specini firo rated facilities aro used.
When optical disk technology in used for records storage, the.following quality controls are used:
The optical disk technology does not allow deletion or: modification of record images.
The image of each record is written-onto two optical disks, 1.7-93 July 1997 m- num q mi .
The legibility of each record image is verified to ensure that the image is legible on both disks. If the image in illegibl~, the hard copy record is maintained as the record copy.
One optical disk is stored in the document imaging system for on line retrieval.
The second (backup) optical disk is stored in a special fire rated facility or in a separate remote location.
To ensure permanent retention of records, the records stored on an optical disk are acceptably copied onto a new optical disk before the manufacturer's certified useful life of the original disk is exceeded. This includes verliication of the records so copied.
Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.
If the optical disk document imaging system in use is to be replaced by an incompatible new system, the records stored on ths old system's disks are acceptably converted into the new system before the old system is taken out of service. This includes verification of the records so copied.
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 QA Program including thoso elements of the program implemented by suppliers and contractors.
1.7-94 July 1997
The system of audits includes limited scope surveillances, which provide flexibility for more timely coverage of certain activities. 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.
i 1.7.18.2 IMPLEMENTATION 1.7.18.2.1 Performance ~Ansuranc.e Responsibilities The basic responsibility for the assessment of the QA Program is vested in performance assuranco. Perfocmance assurance is primarily responsible for ensuring that proper QA programs are established and for verification of their implementation. These responsibilities are discharged in ecoperation with I&M management and their staffs.
1.7.18.2.2 Internal audits are performed in accordance with established schedules that reficct 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 performance assuranco conducts audits to verify the adequacy and implementation of the QA Program at 1&M and uithin the AEP System. QA audit reports are distributed to the appropriate management and the NSDRC (all audits).
1.7-95 July 1997
1.7.18.2.4 The independent off-site review and audit organization is the: a NSDRC. This committee is composed of I&M ,
management members. An NSDRC Hanual 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.).
MSDRC audit reports are submitted for review to the NSDRC menbership and the Chairman of the NSDRC. Condition Reports and/or audit reports provide for the recording of actions taken to correct deficiencies found during these audits.
3 1.7.18.2.5 The I&M,on-sita review group is the PNSRC. This cramittee
. reviews plant operations as a routine cvaluation and serves to advise the site vice president f on matters related to nuclear safety. The composition of the committee is afined in the Technical Specifications.
The PNSRC also reviews instruc t ions, procedures, and design changes for safety related systems prior to approval by the sitt vice president >
. In addition, this committee ser"es to conduct invx 4 tigations of violations to Technical Specifications, and reviews significant Condition Faports to determine if appropriate action has been taken.
1,7-96 July 1997
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, i
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 prograns.
3 1.7.18.2.7
=
Regularly scheduled audits are supplemented by "special b
audits" when significant changes are made in the QA 1
/ ,. program, when it is suspected that quality is in jeopardy,
'4
- or when an independent assessment of program effectiveness S
is considered necessary.
1.7.18.2.8 Audits include an objective evaluation of practices, j procedures, instructions, activities and items related to quality; and a review of documents and recorda to confirm that the QA Program is effective and properly implemented.
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1.7 18.2.9. ,
. Audit procedures and the scope, plans, checklists and
- results of individual audits are documented.
1.-7.18.2.10 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. In the case of significant conditions adverse to quality, appropriate action is taken to prevent recurrence. Follow. -
up is performed by the auditing organization on selected adverse conditions, to ensure that the appropriate actions were taker., Such follow up actions may include, but are not limited to, re-audits, subsequent audits, surveillances, or other appropriate means.
1.7.18.2.12 The adequacy of the QA Program is regularly assessed by management. The following activitics constitute formal.
elements of that assessment; a) Audit reports, including follow-up on corrective action accomplishnent and effectiveness, are distributed to appropriate levels of management.
1.7-98 July 1997
b) Individuals independent from the QA or5anization, but knowledgeable in auditing, and quality assurance, periodically review the effectiveness of the QA programs. Conclusions and recommendations are reported to the 16N vice president T^0 1.7.19 FIRE PROTECTION QA PROGRAM
-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 Juae 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, i surveillance, inspection, operation, maintenance, ;-
modification, and audits.
Implementat, ion and assessment of the Fire Protection QA Program is the responsibility of I&MQ 1.7-99 July 1997
f 1.7.19.2 Organization The Fire Protection QA Program is under the management and control of 3&N/ This control consists of:
- 1) Verifying the effectiveness of the Fire Protection QA Program through review, surveillance, and audits.
- 2) Directing formulation, implementation, and assessment of the Fire Protection QA Program by procedural controls.
- 3) Assuring the QA program is acceptable to the management responsible for fire protection.
The site vice president has delegated responsibility to various Cook Nuclear Plant departments for the following fire protection activities:
.\
a) Maintenance of fire protection systems, b) Testing of fire protection equipment. I c) Fire safety inspections, d) Fire pre-plans.
e) Fire drills, f) Emergency remote shutdown procedures.
g) Emergency repair procedures (10CFR50, Appendix R).
The Fire Protection QA Program at the Cook Nuclear Plant also provides for inspection of fire hazards, explosion hazards, and training of fire brigade and responding fire departments.
, 1.7-100 July 1997
The plant protection department's fire protection shift t
supervisor on duty, or designee, is designated as the fire
. brigade' leader and coordinates the-fire-fighting efforts of the-fire brigade. The operations department provides an individual with plant systems knowledge to serve aslan:
advisor to the fire bri ade 6 leader.
1,7.19.3 Desicn Control and Procurement Document Control Quality 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.
The Cook Fuelear Plant design was reviewed by qualified personnel to ensure inclusion of 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 (scaling 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 1.7-101 July 1997
h 1
procurement documents. A review of these documents is #
- performed to assure fire protection requirements and qualityfrequirements 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 QA Program requirements .
4 f Design and procurement. document changen, including field changes and design deviations, are controlled by procedure.
d 1,7,19,4 lH3tructions. Proctiures l and Drautogg Inspections, . tests, administrativo controls,' fire drills and training that assist in implementing the fire protection program are prescribed by approved instructions or procedures.
Indoctrination and training programs for fire prevention and fire fighting are. implemented in accordance with approved procedures. Activities associated with the fire 4- protection systems and fire protection related systems are prescribed-and accomplished in accordance with documented
- instructions, procedures, and drawings. Instructions and 1 procedures for design, installation,. inspection, tests, maintenance, modification and administrative controls are reviewed through audits to assure that the fire protection I. program is maintained.
Operation and maintenance information has been provided to the . plant in the form of. System Descriptions and equipment
, supplier _information.
1.7-102 July 1997 4
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1.7.19.5 control of Purchased Items and Services
- Measures are-established to assure that purchased items and
' services conform to procurement documents. 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 Insoection 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 setivity is satisfactorily completed in accordance with installation specifications.
1.7-103 July 1997
c). -Inspections of cable routing to verify conformance with design requirements as specified in engineering specifications and/or plant 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 1.7-104 July 1997-
satisfactorily. Written' test procedures for installation tasts incorporate the requirements and acceptance limits contained in applicable design documents.
b) Periodic tenting . Periodic testing occurs to document-that fire protection equipment functions in accordance with its design.
c) Programs have been established to verify the testing of firo 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 Innnection. Test and operatine status The inspection, test and operating status for plant i Technical Specification fire protection systems aro performed as described in 1.7.14 herein.
1.7.19.9 Nonconformine items Technical Specification fire protection equipment nonconformances are identified and dispositioned as described in 1.7.15 herein.
1.7-105 July 1997
f-1.7.19.10 Cerrective Action The corrective action mechanism described in 1.7.16 herein applies to the Technical Specification fire protection equipment.
I 1.7.19.11 Records Records l that] furni_sh. evidence fof thel quality [ofL activities [
hthifoflystdas,fstructures^ and componentalas.sociatediwith thelfIrelprotectioniprogram?;are ma.intained. The maintenance oflthe; recordsjincisdes assuring lthk9 records J
arefaccurate;[ complete.-;1egible;-?and~ protected against damagojLde_terioration, Lor!1oss. :The records.are identifiable?and; retrievable; -The'resordsLinclude results of reviewsi(insp;ectionsl,-(testa, audits, monitoring 1of work performanceWandlqualificatio.ns ;of; personnel and equipment; Inspectionfandf tes.cf recordalidentifyyltheT inspeg*irTorlda to '
recorderf thel type' of(observations,(results? acceptability; and@c tiordsltakenTin?connectio'n lwithionyldefi~ciencies' noted.- (Records' provide for; traceability of activities'that occurTat"the.l plant 2thatfaffectL theTquality oflfire protection;systemi;istructures,(andcomponents; 1.7.19,12 Audits Audits are conducted and documented to verify compliance with the Fire Protection QA Program as described in 1.7.18.1 herein.
Audits are periodically performed to verify compliance with the administrative controls and implementation of fire 1.7-106 July 1997
i protection quality assurance criteria. The audits are performed in accordance with pre-established written procedures or checklists. Audit results are documented and reviewed by reanagement having responsibility in the area audited. Follow-up action is taken by responsible management to correct the deficiencies revealec by the audit.
t ,
1.7-107 July 1997
AMERICAN ELECTRIC POWER Chairman of the Board, President and Chief Executive Officer
~
- AEPSC Executive Vice President
" Nuclear Generation 3
' I&M Vice President l
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Site l Chief Nuclear Performance Business Performance Regulatory Affairs Human Resources Vice Pres; dent Engineer Assurance Director Director Director Manager 4I3 C
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PERFORMANCE ASSURANCE
, Performance Assurance Director Performance Engineering I Plant and Supplier and Analysis Manager Performance Manager
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SITE OPERATIONS Site Vice President l Site Operations l ,
i Plant Manager Plant Protection l Emergency Plan Work Control l I E Coordinator
~
N j e Operations Scheduling Maintenance Material Management Training t Chemistry l
1 Radiation f?otection
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APPENDIX A REGULATORY-AND-SAFETY GUIDES / ANSI STANDARDS'
- 1. Reg. Guide 1.8 (9/75) - Personnel Selection and Training ANSI N18.1 (1971) -
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)- -
Quality Assurance Requirements for the Installation, Inspection, and festing of Instrumentation and Electric Equipment ANSI N45.2.4 (1972) -
Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Cencrating Stations-
- 5. Reg. Guide 1.33 (02/78)~ - Quality Assurance Program Requirements (Operation)
ANSI N18.7 (1976) - Administrative Controls and Quality 1.7-111 July 1997
(ANS 3.2 1976) Assurance for the operational Phase of Nuclear Power Plants ANS1 N45.2 (1977) --
Quality Assurance Pro 6 ram Requirements for Nuclear Facilities
- 6. Reg. Guide 1.37 (3/73) -
Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants ANSI N45.2.1 (1973) -
Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants
- 7. Reg. Guide 1.38 (10/76) - Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and llandling of Items for Water-Cooled Nuclear Power '
Plants ANSI N45.2.2 (1972) -
Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase).
'1.7-112 July 1997
. - . . . . - - . - .- . . - . - . _ - . . . ~ _ . . . . . - - - .. - .
I 1
i
. 8, Reg.L0uide 1.39 (10/76) -
llousekeeping Requirements for Water Cooled Nuclear Power Plants ANSI N45.2.3 (1973) - Housekeeping During the ,
Construction Phase of Nuclear Power Plants
- 9. Reg. Guide 1.54 (6/73) -
Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants ANSI N101.4 (1972) - Quality Assurance for Protective Coatings Applied to Nuclear Facilities
- 10. neg. Guide 1.58 (9/80) -
Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel ANSI N45.2.6 (1978) -
Qtalifications of Inspection, Examination, 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 1.7-113 July 1997
.2 3
- 12. Reg.' Guide.l 64 (10/73) - Quality Assurance Requirements for the Design ofl Nuclear Power Plants ANSI N45.2.11 (1974)- -
Quality Assurance Requirements for the Design of Nuclear Power Plants
- 13. Reg. Guide 1.74 (2/74) -
Quality Assurance-Terms and Definitions ANSI N45.2.10 (1973) -
Quality Assurance Terms and Definitions
- 14. Reg. Guide 1.88 (10/76) - Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records ANSI N45.2.9 (1974) -
Ren ents for Collection, Storage, and Maintenance of Qua);ty Assurance Records for Nuclear Power Plants
- 15. Reg. Guide 1,94 (4/76) -
Quality Assurance Requirements for Installation, It.spection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants 1.7-114 July 1997-
[-
ANSI N45.2.5-(1974) -
Supplementary Quality Assurancu Requirements for Installation, Inspection; and Testing of Structural Concrete and Structural Steel During the-Construction Phase of Nuclear Power Plants Reg. Guide 1.123 (7/77) - Quality Assurance 6
- 16 .
Requirements for Control of Procurement of items and Services for Nuclear Power
- Plants ANSI N45.2.13 (1976) -
Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants
- 17. Reg. Guide- 1.144 (1/79) - Auditing of Quality Assurance Programs for Nuclear Power Plants
- r. ANSI N45.2,12 (1977) -
Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants
- 18. Reg. Guide 1.146 (8/80) -
Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 1.7-115 July 1997 9
l
. ANSI N45.2.23 (1978) -
Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants
- 19. ANSI N45.2.8 (1975) -
Supplementary Quality Assurance Requirements for Installation, Inspection and' Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear
-Power Plants' 1
- 20. ANSI N45.4 (1972) -
Leakage Rate Testing of !
Containment Structures for Nuclear Reactors i
l i
1.7-116 July 1997 l
APPENDIX B I&M EXCEPTIONS TO OPERATING PflASE SIANDARDS AND REGULATORY GUIDES
- 1. fEHEEAL Recuirement 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, Exception /Interoretation The [,il&M 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.
- 2. N18.7, General Excention/ Interpretation
, ?I&M has established both an on-site and off-site standing committee for independent review activities; together they form the andependent 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.
1.7-117 July 1997
2a. Sec. 4.3.1 Reauirement
" 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: ...."
Execotion/ Interpretation The 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 Reouirement "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 sita? operations. Competent alternates are permitted if designated in advance. The use of alternates shall be restricted to legitimate: absences of principals."
1.7-118 July 1997
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- SeefItem 2a.
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' 2 c . -- Sec. 4.3.3.1 Requirement - >
n "'.... recommendations ...- shall be disseminated promptly to appropriate members of ranagement _having responsibility in the area reviewed." ,
'Exce p ti on/Inte rc re tation- t Recommendations made as a result oC' review will generally be conveyed to the on site, or off site, standing committee.< Procedures will be maintained specifying how recommendaticas are to be considered.
2d. Sec. 4.3.4 3nouirement I
"The following subjects shall be reviewed by the -
independent review body: .. ." '!
,Jxcention/IntArgrstation-Subjects. requiring review will be as specified in the plant S ,
-Technical Specifications.
2e.: Sec. 4;3.4(3); !
Reautrement
" Changes in the Technical Specifications or .Licer.se Amendments relating to nuclear safety are-to be reviewed i f
'the independent' review body prior to. implementation, except in'those' cases whure.the' change.is identical to a previously; reviewed proposed change."
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1.7-119; July 1997 s
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- Excention/Interoretation 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 implementati... '; Technical
. Specification changes.
2f. Sec. 4.4 Reouirement "The on site operating organization shall provide, as part of the normal duties of plant supervisory personnel . . . ."
Exception /Internrotation
. Some of the respot.sibilities 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 Reauirement
" 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."
Excention/Interoretation I&M considers that this requirement applies only to procedures identified in plant Technical Specifications.
-Temporary changes to these procedures shall be approved as
. described in planc Technical Specifications.
1.7-120 July 1997
.. - .. _ . . . - ,. -. . - - - ~ - . . . - _ - . - _ - . - _
i l
2h. Sec. 5.2.6 )
Reouirement "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 q 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 fulfill their intended safety functions."
Exception /Interoretation I&M Initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a
~
test or inspection which is a requirement to verify equipment acceptability, This action includes a technical evaluation of the equipment's operability status.
4
- 21. Sec. 5.2.
Reautrement "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."
1 Exception / Interpretation Separate master schedules may exist for different programs, such as ISI, pump and valve testing, and Technical Specification surveillance testing.
.1.7-121 July 1997
-l 2
2j. Sec. 5.2.13.1 Recuirement "To the extent necessary, procurement documents shall require suppliers to provido a Quality Assurance Program consistent with the pertinent requirements of ANSI N45.2 -
1977."
1
)
Exception / Interpretation To the extent necessary, procurement documents require that the supplier has a documented Quality Assurance Program consistent with the pertinent requirements of 10CFR50, Appendix B; ANSI N45.2: or other nationally recognized codes and standards, i
i 2k. Sec. 5.2.13.2 Reautrement i l
ANST N18.7 and N45.2.13 specify that where required by i l
code, regulation, or contract, documentary evidence that '
items conform to procurement requirements shall be availabic at the nuclear power plant sito prior to '
installation or use of such items.
Excention/Interoretation The required documentary evidence is available at the site prior to use, but not necessarily prior to installation.
F This allows installation to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
- 21. Sec. 5.2.15 Reautrement
" Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure _no less
,7-122 July 1997
frequently than every two years to determine if changes are necessary or desirable,"
Exception /Internretation Biennial reviews are not performed in that I&M 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 biennist 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 :
Egggirement Records shall be made, and equipment suitably marked, to '
indicate calibration status, Excention/Intercretation See Item 6b, 2n. Sec. 5.3.5(4)
Reautrement 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, 1.7-123 July 1997
Excention/Interoretation-
-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. Maintenanco- j procedures which reference these. documents receive the same l 1evel of review and approval as_' operating procedures.
- 3. N45.2.1, 3a, Sec. 3 Reauirement N45,2,1 establishes criteria for classifying items into
" cleanness levels,* and requires that items be so classified.
Exception /Interoretation Instead of using the cleanness level classification system of N45,2.1, the required cleanness for specific items and activities is addressed on a case by-case basis.
Cleanness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material. As a minimum, cleanness inspections are performed prior to closure of " nuclear" systems and equipment, Such inspections are documented.
3b. Sec. 5
.Recutrement
" 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."
1,7-124 July 1997
. -. . - . . - - - . .-. . --- _ . . - ~ . - . - - - - . . - -
Exception / Interpretation 16M 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. 'N4$.2.2, General Reauirement N45.2.2 establishes requirements and criteria for classifying safety related items into protection levels.
Excention/ Interpretation Instead of classifying safety related items into protection levels, controls over the packaging, shipping, handling and storage of such items are established on a cara by case basis with due regard for the item's complexi use and sensitivity to damage. Prior to installation or use, the -
items are inspected and serviced, as necessary, to assure i that no damage or deterioration exists which could affect their function.
t 4a. Sec, 3,9 and Appendix A3,9
- Recuirement "The item and the outside of containers shall be marked."
(Further criteria for marking and tagging are given in the t
Appendix,)
Excention/Interoretation 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, i increase the probability of damage to the item. The 2.7-125 July 1997
I requirements are implemented-to theLextent necessary to assure traceability and integrity of the item.
4b. :Sec. 5.2.2 Reautrement
" Receiving inspections shall be performed in an area equivalent to the level of storage."
f.xcention/Interoretation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item. Itowever, such inspections are performed in a manner and in an environment which do not endanger the required quality of the item.
G 4c. Sec. 6.2.4 Etquirement "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted."
Excenrion/Internretation 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 storage areas.
( 4d, Sec. 6.3.4 Reautrement "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,"
1.7-126 July 1997
. _ __,__.____._-_-____-._O
i l.
Exception / Interpretation LSee N45,2,2, Section 3.9 (Exception 4a. above).
40 Sec. 6.4.1 Reauirement
" Inspections and examinations shall be perforbed and
. documented on a periodic basis to assure that the integrity of the item and its container ... is being maintained."
Exception / Interpretation 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 frequencir.. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from +
item to item.
5, N45.2.3, Sa. Sec. 2.1 Reauirement I
Cleenliness requirements for housekeeping activities shall be established on the basis of five zone designations.
Egggotion/ Interpretation Instead of the-five-level zone designation system referenced in ANSI N45.2.3, I&M 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 1.7-127 July 1997
h 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.- flowever, in preparing these procedures, consideration is also given to the recommendations of ;
Section 2.1 of ANSI N45.2.3.
- 6. N45.2.4, 6a. Sec. 2.2 Reautrement 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, i control of design, conforming and protected materials and availability of specified documents.
-l Exception / Interpretation 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, y as necessary, 6b. Sec. 6.2.1 Reautrement
" Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of
-person that performed calibration."
1 1.7-128 July 1997
- )
. . _ _ m ._. ._ _. ._._ . __ _ ._ _. . .__ _ _.__ __ . - .
Exception /Interoretation 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. Tec. 2.5.2 Reautrement "When discrepancies, malfunctions er inaccuracies in inspection and testing equipment are found during calibration, all items inspected with that equipment since .
the last previous calibration shall be considered unacceptable until an evaluation has been made by the responsible authority and appropriate action taken."
Exception /Inte rtire tation .
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 Reautrement
" 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."
1.7-129 July 1997 l
. _ . _ _ - . . _ , _ _ . . __ . . _ _ _ _ _ _ . _ __ . ~ _ . . . _ _ . , -
-Exception / Interpretation 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 rathat than as per.N45.2.5.
- 8. N45.2.6, Sec. 1.2 Eqauirement .
1 "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."
Exception /Interoretation 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 h
necessary to perform the assigned function.
. 9. Rec. Guide 1.58 - General keoutrement Qualification of nuclear power plant inspection, '
examination and testing personnel.
9a. C.2.a(7)
Renuirement Regulatoty Guido 1.58 endorses the guidelines of SNT TC-1A as an acceptable method of training and certifying personnel conducting leak tests.
4 1.7-130 July 1997 S
- - ~ - -- - _ ~ - . . - - _ . . .. -_- - - -. - .. - . - . - -- -
Exception /Interoretation I AM takes the position that the " Level" designation guidelines as recommended in SNT-TC-1A, paragraph 4 do not-necessarily assure adequate leak test capability. I&M maintains that departmental supervisors are best able to judge whether engineers and other personnel are qualified to direct and/or perform leak tests. Therefore, I&M does not implement the recommended " Level" designation guidelines.
It is I&M's opinion that the training guidelines of SNT-TC-1A, 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. I&M 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 e Plant is under the-direct supervision of performance i 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.
I&M does recognize the need to assure that individuals involved in leak tests are fully cognizant of leak test procedural requirement and thoroughly familiar with the
. test equipment involved. Plant performance engineers receive routine, informal orientation on testing programs to ensure that these-individuals fully understand the
- requirements of performing a leak test.
4 1.7-131 July 1997
- _ .. _ . - ~
9b. CS, Co, C7, C8, C10-Exception / Interpretation I&M takes the position that the classification of inspection, examination and test personnel (inspection personnel) into "Lcvels" based on the requirements stated in Section 3.0 of ANSI N45.2.6 does not necesscrily assure adequate inspection capability. I&M 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 burdenseme administrative work load, could inhibit inspection activities, and provides no assurance of inspection capabilities. Therefore, I&M does not implement the " Level" classification concept for inspection, examination and test personnel.
l The methodology under which inspections, examinations and testa are conducted at the Cook Nuclear Plant requires the involvement of first.line supervisors, engineering personnel, departmental supervisors and plant management, i 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 laspector category. These management supervisory and engineering personnel, as a minimum, meet the educational and experience requirements of "Lovel II and Level III" personnel, as required, to meet the criteria of ANSI 18.1 which' exceeds those of ANSI N45.2.6. In I&M's opinion, no useful purpose is served by classification of management, supervisory and engineering personnel into " Levels."
t, 1.7-132 July 1997 i
I l
+
Therefore, I&M takes the following positions relative to >
regulatory positions C5, 6, 7, 8 and 10 of Regulatory Cuide 1.58.
4 C5 Based on the discussion in 9b, this position is not applicable to the Cook Nucicar Plant.
C6 Replacement personnel for Cook Nuc1 car Plant management, supervisory and engineering positions subject to ANSI 18.1 will meet the educational and experience requirements of ANSI 18.1 and'therefore, those of ANSI N45.f.6.
i Replacement inspection personnel will, as a minimum, a meet the educational and experience requirements of ANSI N45.2.6, Section 3.5.1 " Level I."
C-7 I&M, as a general practice, complies with the training recommendations as set forth in this ;
regulatory position. .
t C-8 All I&M inspection, examination und test personnel ,
are instructed in the normal course of employee training in radiation protection and the means to minimize radiation dose expoture.
C 10 I&M maintains documentation to show that inspection personnel meet the minimum requirements of " Level I,"
and that management, rupervisory and engineering personnel meet the minimum requirements of ANSI 18.1.
1.7-333 July 1997
-.- .- . .-. .. ._- . . ~ - . - . ._ - . - . .. .- .. - - . - - -
10 N45.2.8,.
10a. Sec. 2.9e-
-Ecouirement 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.
Exception / Interpretation All of the documents listed are not necessarily required at the construction site for installation and testing, jl&M assures that they are available to the site, as necessary.
10b. Sec. 2.9e Reautrement Evidence that engineering or design changes are documented
, and approved shall be available at the construction site -
prior to installation. <
Exception / Interpretation Equipment may be installed before final approval of 4
engineering or design changes. Ilowever , the system is not placed into service untti such changes are documented and approved.
10c. Sec. 4.5.1 Reouirement l " Installed systems and components shall be cleaned, flushed and conditioned according to the requirements of ANSI N45-.2.1. Special consideration shall be given to the following requirements: .. ." (Requirements are given for chemical conditioning, flushing and process. controls.)
1.7-134 July 1997 e*$ - e,,n y y- -
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.- -..-.4 .--, ralu- 6e. . - +.. M f .*A J Exception / Interpretation 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 matetenance or modification activities.
- 11. N45.2.9 11a. Sec. 5.4, item 2 Reaufrement
- 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.
Exception / Interpretation Records are suitably stored in steel file cabinets, or on shelving in contriners. Methods other than binders, folders, or envelopes (for example, dividers) may be used to organize the records for storage.
lib. Sec. 6.2 Recuirement "A list shall be malntained designating those personnel who shall have access to the files" Excention/ Interpretation 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 exisc for general use.
1.7-135 July 1997
11c. Sec. 5.6 Reouirement When n' single records storage facility is maintained, at least the following features should be considered in its construction: etc.
Excention/Internretation The Cook Nuc1 car Plant Master File Room and other off-site record storage facilities comply with the requirements of NUREG 0800 (7/81), Section 17.1.17.4.
- 12. Reg Cuide 1.144/ ANSI N45.2.12 12a. Sec. C3a(2)
Reauirement Applicable elements of an organization's Quality Assurance program for " design and construction phase activities should be audited at least annually or at least once within the life of the activity, which 'er is shorter."
Excention/Internretation i
Since most modifications are straight forward, they are not audited individually. Instead, selected controls over modifications are audited periodically.
12b. Sec C3b(1)
Reautrement This section identifies procurement contracts which are
-exempted from being audited.
Excep t ion /Inte rpre ta t ion l
In addition to the exemptions of Res. Guide 1.144, [I&M considers that the National Institute of Standards and 1
-Technology, or other Stats and Federal Agencies which may provide services ta , II&M, are not required to be audited, 1.7-136 July 1997 i
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..12c. Sec. 3.3-Recuirement
.An effective audit system shall be established and-maintained and shall include the following essential.
elements........ ,
3.3.7 Provision for verification of effective corrective action on a timely basis.
Execution /Interoretation Verification of the implementation of effective corrective action is performed as indicated in Section 1.7.18.2.11 of this QAPD. Only selected corrective / preventive actions, determined by the auditing organization, will be verified by the auditing organization.
12d. 4.5.1 Requirement ,
...In the event that corrective action cannot be completed within thirty days, the audited organization's response shall include a scheduled date for the corrective action, i The audited organization shall provide a follow up report stating the corrective action taken and the date corrective action was completed.
Exception /Inte rore tat iSD The auditing organization will determine when it is necessary for the audited organization to provide a response-within thirty days. If the auditing organization-does not designate that the response must be completed-within the- thirty day time frame and forwarded to the auditing organization, the corrective action document will 1.7-137 July 1997
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be processed in accordance with the corrective action-program. The program' determines the safety significance, extent-of the' investigation required, investigation due date, and required lerel of management review and approval.
The audited-6rganization will provide follow up: ;
documentation to the appropriate' level of management as to tho' status of the corrective / preventive' action.
Documentation of follow up will be provided to the auditing organization when specified by the auditing organization.
- 13. N45.2.13, 13a. Sec. 3.2.2 P
RequireGnnt N45.2.13 requires that technical requirements be specified
'n i procurement documents by reference to technical requirement documente. Technical requirement documents are to be prepared, reviewed and released under the y
requirements established by ANSI N45,2.11. i e
Exception / Interpretation 9 For replacement parts and materials, , "[I&M follows 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' or without specifically idencified QA requirements, spare .9nd replacement parts may be similarly procured,-but- - <
care shall be exercised to ensure at least equivalent performance."
1.7 138 July 1997 i
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13b. Sec. 3.2.3 Reauirement
" Procurement documents shall require that the supplier have a documented quality assurance- program that implements parts or all of ANS1 N45.2 as well_as applicable quality assurance program requirements of other nationally recognized codes and standards."
Exception / Interpretation >
Refer to item 2j 13c, Sec. 3.3(a)
Reauirement Reviews of procurement documents shall be performed prior to release for bid and contract award.
7 Excention/Interoretation 4 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)
Reautrement Review of changes to procurement documents shall be performed prior to-release for bid and contract award.
Exception /Interoretation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified-in ANSI N18.7, Section 5.2.13.1, Subitems 1 1.7-139 July 1997 ,
1 1
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through 5). The timing of reviews will be the same as for
-review of the original procurement documents.
13e. Sec. 10,1 Requirement "Where required by code,-regulation, or contract i 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."
Exception /Interoretation Refer to Item 2k, Recuirement
" Post-installation test requirements and acceptance documentation shall be mutually ectablished by the purchaser and supplier."
Execntion/ Interpretation In exercising its ultimate responsibility for its quality '
assurance program, ;7I&M establishes post-installation test requirements giving due consideration to supplier recommendations.
- 14. Bec. Guide 1.146/ ANSI N45.2.23 and ANSI N45.2.2.12 14a. ANSI N45.2.23. Sec. 1.1 Reauiremer.t This standard provides requirements and guidance for the qualification of audit team leaders,. henceforth identified as " lead auditors." -
~ 1.7-140 July 1997
14b. AtLSJ..N45.2.12, Sec. 4.2.2 Reautrement A lead auditor shall be appointed team loader.
Excention/ Interpretation The (;, audit program is directed by the performance assurance director and is administered by designated performanceTassurance ~ ; managers / supervisors who are certified lead auditors.
Audits are, in most cases, conducted by individual auditors, not by " audit teams," 1hese auditors are certified in accordance with established procedures and are assigned by the responsible perform'ance assuraned 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.
Established RM 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 a pefformancW assurr. ice manager / supervisor, thereby meeting 'he .equirements of ANSI N45,2,23 relative to " lead auditors", and " audit team
, leaders."
- 15. ANSI N18.1 Section 4.2.2 Reauirement At the time of initial core loading or appointment to the active position the operations manager shall hold a senior reactor operator's license, 1.7-141 July 1997 1
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.Excention/Internretation.
The requirement implies that only personnel which currently ;
hold a senior reactor operator's license can-be appointed as' operations manager. -I&M takes the position that the operations-superintendent must hold or have held a senior-
- operator license at Cook' Nuclear-Plant or a similar reactor; and one mid level operations production supervisor shall hold a current senior operator license. This exception / interpretation is consistent with Technical Specification 6.2.2.h, previously approved by Nuclear Regulatory Commission, e
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ATTACHMENT TO AEP:NRCt00027A
. APPENDIX C '40 QAPD IN ACCORDANCE '
WITH ADMINISTRATIVE LETTER 95 I a
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-Appendix C INDEX ADMINISTRATIVE CONTROLSI
- 6.5 REVIEW ~AND AUDIT.
. 6.5.1- -PLANT NUCLEAR SAFETY. REVIEW COMMITTEE PAGE. f Function! . . . . . . . . .-. . . . . . . . .-. . . . . 1.7-- -:143 (
Composition , . . . . . . . . . , . . . - . . . . .:.--.-,-.-. .1.7'-143 i
Alternates . . . - . - . . . . . . . . ... . .. . . . . . . - 1.7 --144 "
-Meeting-Frequencyh-'. . . . , . .: . . . . . . _. . . ....; 1. 7 -- . . 144 ;
Quorum. . .. . . , ,. . . . . . . . .:. . . . . . .. . . 1.7 -144 Responsibilities- .L.................J.:
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1.7.- 144 l Authority . . . . .'. . ... ~. . . . . . . . . . . . . . 1.7 - 145 Records . -. .. . . . . . . . . . . . .- . . ..... -2,7' =145
'6.5.2 -NUCLEAR SAFETY AND DESIGN REVIEW COMMITTEE.
Function . . . . . . . . . . . . . . .. . . .. .
. . 1.7 - 145 Composition . 1.7 - 146
. Alternate Members .
-Consultanto.. . . . . . . . . . . . . . . . . .....
1.7 - 146 1.7 -.146 Meeting Frequency . . . . . . . . . . . . . . ..... 1.7.- 146 Quorum . . . . . . . . . . . . . . . . . . . ..... 1.7'- 147 R* view . . . . . . . . . . . . . . . . . . . . ..... 1.7 - 147-Audits- . . . . . . . . - . . . . . . . . .. . ..... 2.7 - 148. l
-Authority . . . . . . . . . . , . . . . . . . ..... 1.7 - 148 Records 1.7 - 149 6.5.3 TECNNICAL REVIEW AND CONTROL . . . . . . . . . . . . . 1.7 - 149 6.10 RECORD RETENTION . . . . . . . . . . . . . . 4 . . . . 1.7 - 151
- ADMINISTRATIVE CONTROLS- i 6.5 REVIEW AND AUDIT 6.5.1 Plant Nuclear Safety Review Committee (PNSRC)-
FUNCTION P
6.5.1.1- The PNSRC shall function to advise the Site Vice President '
or designee, on all matters related to nuclear safety. .
COMPOSITION 6.5.1.2 The PNSRC shall be composed of aIPlantTMahiyWMr?his7designeeMea Manager (s),pand ~ - Department Superin(endentis)[of [ , [ p'ersonnell reporting J ' directly - to ane f Areag fManager -or a Department Superintendent. - The membership"shall' represent the functional areas -
. of the plant, including, but not limited to Operations, Engineering,. "
Licensingi Maintenance, and Radiation Protection.
.The'PNSRC. membership shall. consist ofiat least one individual-from each of the areas designated. All members, including the Chairman and his alternates, the members and . their alternates, 'shall be
= designated by the Site Vice President. g.-
i 1.7 - 143 July 1997 1
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M!KDQLTRATIVE CONTRQM _
PNSRC members and alternates shall meet or exceed the minimum qualifications of ANSI N18.1 1971 Section 4.4 for comparable positions. The nuclear power plant operations individual shall meet the qualifications of section 4.2.2 of ANSI N18.1 1971 except for the _ requirement to hold a current Senior Operator License. ' The operationo individual must hold or . have held a Senior Operator License at Cook Nuclear Plant or a similar reactor. The maintenance individual shall meet the qualifications of section 4.2.3 of-ANSI N18,1-1971, M JERNATES 6 5.1.3 No more than two alternates shall participate ao votino membero in PNSRC activities at any one time.
MEETING FRFOUENCY 6.5.1;4 The PNSRC ahall meet at.least once per calendar month and as convened by the PNSRC Chairman or his designated alternateo.
QMQEW 6.5.1.5 The quorum of the PNSRC chall consist of the Chairman or his designated alternate and at least three members including alternates.
RESPONSTQILITIES 6.5.1.6 The PNSRC shall be responsible fcr
- a. Review of all - Plant Manager Instructions (PMIs) and revisions thereto,
- b. Review of safety evaluations for (1) plant site procedures and revisions thereto which af fect tne nuclear safety of the plant; (2) changes or modifications to nuclear safety-related otructures, systems or components; and (3) tests or experiments which af fect plant nuclear safety te verify that such actions did not constitute an unreviewed. safety question as defined in 10 CFR 50.59,
- c. Review of (1) proposed procedures and revisions to procedures, (2) changes to equipment, systems, or f acilitien, and (3) proposed tests or-experiments which may involve an unreviewed safety question as defined in 10 CFR 50.59.
- d. Review of proposed changes to Appendix "A" Technical Spec 3 fications or the operating License and rendering determinations writing with regard to whether or not the proposed change constitutes a Significant Hazards Consideration _(s) ,
- e. Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Chairman of the NSDRC.
- f. Review of all' REPORTABLE EVENTS.
t 1.7 - 144- July 1997 I-
ADMINISTRATIVE CONTROLS g, steview of f acility operations - to detect potential nuclear safety hazards.
- h. Performance of special reviews, investigations of analyses and reports thereon.as requested by the Chairman of the NSDRC.
- 1. Deleted
- j. Deleted
- k. Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering eva.uations,
- recommendations, and dispcsition of the corrective action to prevent recurrence and the forwarding of these reports to the Executive Vice President - Nuclear Generation and to the NSDRC.
- 1. Review of changes to the PROCESS CCNTROL PROGRAM, OFFSITE DOSE CALCULATION MANUAL, and radwaste treatment system.
AUTHORITY C;5.1.7 The PNSRC shall
- a. Recommend to the Site Vice President ., . , or designee, written approval or disapproval of items considered under 6.5.1.6 (a) through (d) above,
- b. Render determinations in writing with regard to whether or not each item considered under 6.5.1.6 (a) through (c) and (e) above constitutes an unreviewed safety question,
- c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Executive Vice President - Nuclear Generation and the NSDRC of disagreement' between the PNSRC and the Site Vice President -; however, the Site Vice President shall have responsibility _for resolution of such disagreements pursuant to 5.1.1 above.
RECORDS 6.5.1.8 The PNSRC shall maintain written minutes of each meeting and copies shall be provided to the Chairman of the NSDRC.
6.5.2 NUCLEAR SAFETY AND DESIGN REVIEW COMMITTEE (NSDPC)
FUNCTION 6.5.2.1 The NSDRC shall function to provide independent review and audit of designated activities in the areas of:
- a. nuclear power plant operations
- b. nuclear engineering
- c. chemistry and radiochemistry
- d. metallurgy
-e. instrumentation and control
, 1.7 - 145 July 1997
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1 hpMINJSTRATIVE CONTHQL),
- f. radiological safety
- g. mechanical and eiectrical engineering
- h. quality assurance practices COMPOSITION 6.5.2.2 The NSDRC shall be composed of the following regular members:
- 1. Executive Vice President- Nuclear generation (NSDRC Chairman)
- 2. Director - Regulatory;Affa2rs (NSDRC Secretary)
- 3. Site Vice President .
- Donald C. Cook Huclear Plant
- 4. Plant Manager - Donald C. Cook ~ Nuclear Plant
$. Chief Nuclear Engineer ,
- 6. Director ~- Dusiness Performance 7 Director - Performance Assurance
- 8. Director i Plant Engineering
- 9. Manager --Performance Engineering'and Analysis
- 10. Special" Assistant i Nuclear Engineering 11.
12.
13.
Additional members and Vice Chairman may be appointed by the Executive Vice Presidenc.
6LigkNATE MEMBEfM 6.5.2.3 Designated alternate members chall be appointed by the Executive Vice President or such other person as he shall designate. In addition, temporary alternate members may be appointed by the NSDRC Chtirman to serve on an interim basis, as required. Temporary alternate members are empowered to act on the behalf of the regular or designated alternate members for whom they substitute.
CONSULTANTS 6.5.2.4 Consultants shall be utilized as determinad by the NSDRC Chairman to provide expert advice to the N3DRC.
MEETItM PREQUENCX 6.5.2.5 The NSDRC shall meet at least once per six months.
1.7 - 146. July 1997 l
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&QMINISTRATlIX CONTROhg OUOPUM r
, 6.5.2.6 A quorum, the minimum number of regular members and alternates required to hold a NSDHC meeting shall be eight members, of whom no more than two shall be designated or temporary alternates. The s Chairman or acting Chairman shall be present for all NSDRC meetings, i If the number of members present* is greater than a quorum, then the ;
majority prticipating and voting at the meeting shall not have line responsibility-for operations of the facility. For the purpose of a quorum, only the plant Manager is considered to have line responsibility.
REVIEt[
6.5.2.7 The NSDRC is responsible for assuring that independent ** reviews of the following are performedt
- a. The safety evaluations for 1) changen to procedures, equipment or '
systems and 2) tests or experiments completed under the provision of -
10 CFR 50.59 to verify that -such actions did not constitute an unreviewed safoty question,
- b. proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.
- c. proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59.
- d. Proposed changes in Technical Specifications or this operating license.
- e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f. Significant operating abnormalities or deviations from normal and expected perf orm; nce of plant equipment that af fect nuclear safety.
- g. All REPORTADl.E EVENTS.
- h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of saf ety-related structures, systems, or componence.
- 1. Reports and meeting minutes of the PNSRC.
' Regular NSDRC members are expected to attend the meeting whenever possible, and alternates may attend as voting members only on an irregular basis. If both a regular member and his alternate attend a meeting, only the regular member may p'articipate as a voting member, and the alternate is considered a guest.
Independent reviews may be performed by groups which report directly to the NSDRC and which must have NSDRC membership participation.
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ARK 11GRIEATIVE CONTROLQ AUDITS ;
6.5.2.8 Audits of facility activities shall be performed under the cognizance of the NSDRC. These audits shall encompass:
- a. The conformance of f acility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months. :
- b. The perf ormance, training, and qualifications of the entire f acility sts!I at least once per 12 months.
- c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear uafety at least once per 6 months.
- d. The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix "B", 10 CFF 50, at least once per 24 months,
- e. Deleted,
- f. Deleted.
- g. The fire protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel,
- h. The fire protection equipment and program implementation at least once per 12 months uning either a qualified offsite licensee fire protection engineer or an outside. independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year.
- 1. The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.
- j. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months,
- k. The PROCESS CONTROL PROGRM and implementing procedures for solidification of radioactive wastes at least once per 24 months.
- 1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 1.21, Rev.1, June 1974 and Regulatory, Guide 4.1 Rev.1, April 1975 at least once per i 12 months,
- m. Any other area of facility operation considered appropriate by the NSDRC.
AUTHOPITY 6.5.2.9 The NSDRC shall report to and advise the Executive Vice President Nuclear Generation on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.
1.7 - 140 July 1997
ADMINISTRATIYg_,@EIBpLa E&GEDE 6.5.2.10 Records of 11SDRC activitica shall be prepared, approved and distributed as indicated belows i
- a. Minutes of each !JSDRC meeting shall be prepared, approved and issued within 14 days following each meeting. ,
- b. Reporto of reviews encompassed by Section 6.5.2.7 above, shall be preparcd, approved and incued within 14 days following completion of the review. ,
- c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Executive Vice President truelear Generation and to the management positions responsible for the areas audited within -
30 days after completion of the audit.
6.5.3 TEcittifCAL PIyJJW A!7D Cot 7 TROL i 6.5.3.1 Activities whien affect nuclear safety shall be conducted an follows:
- a. Procedures required by Specifir ation 6.0 and other procedures which af f ect plant r,uelear saf ety, and changes thereto, chall be prepared, reviewed and approved. Each such procedure or procedure change shall be reviewed by a qualified individual / group other than the individual / group which prepared the procedure or procedure change, but who may be from the same organization as the individual / group which prepared the procedure or procedure change. Procedures other than Plant Manager Procedures shall be approved by the appropriate depar tment head as previously designated in writing by the Site Vice President' , or designee. The Site Vice President: , or designee, shall approve Plant Manager Procedures. Temporary changes to procedures which do not change the intent of the approved proceduren shall be approved for implementation by two members of the plant staff, at least one of whom holds a Senior Operator license, and documented. The temporary changea shall be approved by the original approval authority within 14 dayn of implementation.
For changes to procedures which may involve a change in intent of the approved procedures, the person authorized above to approve the procedure shall approve the change prior to impicmentation.
- b. Proposed changes or modificationa to plant nuclear safety-related structures, systems and componento shall be reviewed as designated by the Site Vice President . , or designee. Each such modification shall be reviewed '(reference T/s 6.5.3.1.e) by a qualified (reference T/S 6.5.3.1.d) individual /grc,up other than the individual / group which designed the modification, but who may be f ron. the same organization as the individual / group which designed the modifications, Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved prior to implementation by the Site Vice President ., or designee.
1.7 149 July 1997
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- c. Proposed tests and experiments which af f ect plant nuclear safety and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Each such test or experiment shall be reviewed by qualified individvals/ groups other than the individual / group which prepared the proposed t at or experiment tv assure cross disciplinary review as approprir a for the proposed test or experiment. Proposed tests and experiments shall be approved before implementation by the Site Vice President
, or designee,
- d. Individuals who conducted the reviews performed in the accordance with Specification 6.5.3.la, 6.5.3.1b, and 6.5.3.1c, shall be members of the plant management staff previously designated by the Site Vice President and shall meet or exceed tha minimum >
qualifications of ANSI N18.1 1971 Section 4.4 for comparable positions. Each such review shall include a determination of whether or not additional, cross-disciplinary review is necessary.
. If decmed necessary, such review shall be performed by qualified personnel of the appropriate discipline, i e. Each review shall include a determination of whether or not an unreviewed safety question is involved. Pursuant to 10 CFR 50.59, URC approval of items involving unreviewed safety questionn shall be
- obtained prior to the approval of the Site Vice President ,
or designeo, for implementation.
- f. Deleted. >
- g. Deleted.
6.5.3,2 Records of the above activities shall be provided to the site Vice President or designee, PNSRC and/or the NSDRC as necessary for required reviews.
- 6. 6 PEPORTABLE EVENT ACTIOli 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
- a. (retained in technical specifications)
- b. Each REPORTADLE EVENT shall be reviewed by the MSRC, and the results of t.h i s review chall be submitted to the NSDRC and the Executive Vice President - Nuclear Generation.
L7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a safety limit ic violated:
- a. The NRC Operations Center shall be notifle. cy telephone as ooon as posuible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Within 24;bours. notify the Executive Vice PresidentL- Nuclear Genera. tion..
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, t, . datety Limit violation Report shall be prepared. The report shall reviewed by PNSRC. This report shall describe (1) applicable l t maumstancea preceding the violations (2) effects of the violation ,
. gun f acility components, systems or structures; and (3) corrective
.ction taken to prevent recurrence, Within_14 days-of the violation, the safety Limit Violation Report f c.
, shall be submitted to the Commission, - and to the Executive Vice 4
president
- Nuclear Generation.
- d. _( retained in technical _ specifications) 3.d PPOCEDURES AND PROOPMS 4 6.8.2 Each procedure and administrative policy of Technical Specification G.B.1
/ , and changes thereto, including temporary changes, chall be reviewed prior to implementation as set ferth in Specification 6.5 above. ;
L 10 PECOI(D PETENTION 6.10.1 The following records shall be retained for at least five years
- a. Records and logo of unit operation covering time interval at each power level.
- b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.
c All REPORTABLE EVENTS aubmitted to the Commission.
- d. Records of surveillance activities, inopections and calibrations required by the Technical Specifications.
- c. Recordo of changes made to the procedures required by Technical Specification 6.8.1.
- f. Records of sealed source and fincion detection leak tests and results,
- g. Records of annual physical inventory of all sealed source material on record.
6.10.2 The following recorda shall be retained for the duration of the Facility Operating Licenoei
- a. Records and drawing changes reflecting unit design modifications made to ayatoms and equipment described in the Final Safety Analysis Report.
- b. Records of new ar.d irradiated fuel inventory, fuel transfers and assembly burnup histories.
- c. Records of radiation exposure for all individuals entering radiation control areas.
- d. Recorda of gaseous and liquid radioactive material released to the environment, 1 *1 -
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- e. Records of transient or operational cycles for those facility ;
components identified in the Updated Final Safety Analysin Report.
- f. Records of reactor tests and experiments.
9 Records of training and qualification f or current members of the Plant. Staff.
- h. Records of in-pervice inspections performed pursuant to thene Technical Specifications.
- 1. Records of Quality Assurance activities required by the OA Manual,
- j. Recordo of reviews performed f or changes made to procedures or equipment or review of tests and experiments pursuant to 10 CPR 50.59.
- k. Records of theetings of the PNSRC and the NSDRC.
1
- 1. Records of radioactive shipments.
- m. keeords of the vervice liven of hydraulic snubbers including the date at which service life commences and annociated installation and maintenance recordo,
- n. Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.
Cu D PPOCESS COllTROL PP.QGPAM (PCP) l 6.13.1 Changes to the PCPt
- a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.n. This documentation shall containt
- 1. (retained in technical specifications)
- 2. (retained in te:chnical -specifications)
- b. Shall becomo of f ective af ter review and acceptance by the PNSRC and approval of the Plant Manager.
6.14 OFFSITE DOSE CtsLCULAT10'l MANUAL (ODCM) 6.14.1 Changen to the ODCM:
- a. Shall be documented and record of reviews performed shall be retained as required by Specification 6.10.2 a. This accumentation shall contain:
- 1. (retained in technical ~npocifications)
- 2. (retainedLin technical cpecificationn)
- b. Shall become effective after review and acceptance by the PNSRC and the approval of_the Plant Manager.
- c. '(retained-in technical-specifications) 1.7 - 152- July 1997 J