ML17334B509

Forwards Updated QA Program Description for DC Cook Nuclear Plant, for Jul 1994

ML17334B509
Person / Time
Site:	Cook
Issue date:	05/23/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17334B510	List: ML17334B509 ML17334B511
References
AEP:NRC:0847Z, AEP:NRC:847Z, NUDOCS 9406020312
Download: ML17334B509 (32)

Text

z ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM

' i REGULATORY INFORMATXON DISTRXBUTION SYSTEM (RIDS)

ACCESSION NBR:9406020312 DOC.DATE: 94/05/23 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFXLIATION FXTZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFXLIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards "Updated QA Program Description for DC Cook Nuclear Plant," for Jul 1994.

D DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR +ENCL SIZE: Q'//Q TITLE: QA Topical Report, Change, Amendment, or Corres ondence (Doc et/Utili NOTES: 1 RECIPIENT COPIES RECIPIENT COPIES A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL HICKMAN,J 1 1 D INTERNAL: NRR/DRIL/RPEB 1 1 OC/LFDCB 1 1 D EG FILE 01 2 2 RGN3 FILE 1 1 EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE V4rASTE! CONTACT THE DOCUMENT CONTROL DESK ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 9 ENCL 9

0

à INSSANA NlCHISAb" PSf'EP:NRC:0847Z

=

10CFR50.54(A)(3)

Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-73 PROPOSED REVISION TO THE 1993 UPDATED EQUALITY ASSURANCE PROGRAM DESCRIPTION (OAPD)

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Attn: W. T. Russell May 23, 1994

Dear Mr. Russell:

This letter and its attachments constitute a proposed revision to the 1993 Updated equality Assurance Program Description (gAPD).

Most of the.- proposed changes are (1) a result of organizational adjustments which focus resources on present and future needs of Cook Nuclear Plant or (2) editorial. As discussed in Attachment 1 to this letter, one of the organizational changes involves the reporting authority of the director-quality assurance. We believe that this change does not constitute a reduction in a previous gA program commitment and is consistent with previously approved gA programs.

Attachment 1 to this letter addresses each of the specific changes (other than the general repagination and changes in capitalization). The proposed changes can readily be identified by the highlighting in Attachment 2, which is the proposed gAPD.

I~ %~ 'V A 5'406020312 S'40523 PDR ADOCL 050003i5 PDR

4, ~

Mr. W. T. Russell AEP,:NRC:0847Z As provided by IOCFR 50.54(a) (3) (iv)', the proposed changes shall be regarded as accepted by the Commission upon receipt of a letter to this effect, or 60 days after submittal, whichever occurs first unless otherwise notified by the Commission.

Sincerely, E. E. Fitz a rick Vice President

/1 j Attachments cc: A. A. Blind Bridgman J. R. Padgett G. Charnoff NFEM Section Chief J..B. Martin Region III NRC Resident Inspector Bridgman

.ELERATED DEMONS TION SYSTEM DISTRIBUTION g

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9406020312 DOC.DATE: 94/05/23 NOTARIZED: NO DOCKET g FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION R Document Control Branch (Document Control Desk)

SUBJECT:

Forwards "Updated QA Program Description for DC Cook Nuclear Plant," for Jul 1994. g~

DISTRIBUTION CODE: Q004D TITLE: QA Topical Report, Change, COPIES RECEIVED:LTR Amendment, or+ENCL SIZE: +//Q Corres ondence (Docket/Utili NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL HICKMAN,Z 1 1 D INTERNAL: ~N

~RE~

/ RXL/ PEB 01 1

2 1

2 OC/LFDCB RGN3 FILE 1

1 1

1 D

EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 9 ENCL 9

indiana Michigan Power Company P.O., Box 16631 Columbus, OH 43216 8

AEP:NRC:0847Z 10CFR50.54(A)(3)

Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-73 PROPOSED REVISION TO THE 1993 UPDATED OUALITY ASSURANCE PROGRAM DESCRIPTION (OAPD)

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Attn: W. T. Russell May 23, 1994

Dear Mr. Russell:

This letter and its attachments constitute a proposed revision to the 1993 Updated guality Assurance Program Description (gAPD).

Most of the proposed changes are (1) a result of organizational adjustments which focus resources on present and future needs of Cook Nuclear Plant or (2) editorial. As discussed in Attachment 1 to this letter, one of the organizational changes involves the reporting authority of the director-quality assurance. We believe that this change does not constitute a reduction in a previous gA program commitment and is consistent with previously approved gA programs.

Attachment 1 to this letter addresses each of the specific changes (other than the general repagination and changes in capitalization) . The proposed changes can readily be identified by the highlighting in Attachment 2, which is the proposed gAPD.

94060203i2 940523 PDR

-P .

'ADQCK 05000315, PDR

Mr. W. T. Russell AEP:NRC:0847Z As provided by 10CFR 50.54(a) (3) (iv), the proposed changes shall be regarded as accepted by the Commission upon receipt of a letter to this effect, or 60 days after submittal, whichever occurs first unless otherwise notified by the Commission.

Sincerely, EF E. E. Fitz a rick Vice President

/1 j Attachments cc: A. A. Blind Bridgman J. R. Padgett G. Charnoff NFEM Section Chief J. B. Martin Region III NRC Resident Inspector Bridgman

ATTACHMENT 1

SUMMARY

OF PROPOSED CHANGES TO THE gAPD

to AEP:NRC:0847Z Page 1 Section(s) Proposed Change(s)

Policy Statement Changed to reflect the new corporate management 1.7.1.2.1 structure resulting from the promotion of the senior 1.7.1.2.2 vice president nuclear generation and reorganization 1.7.1.2.3 of resources supporting Cook Nuclear Plant. Also 1.7.1.2.5 reflects the additional authority of E. Linn Draper, 1.7.2.2.1 Jr. as president of American Electric Power. All 1.7.4.2.4 primary resources for Cook Nuclear Plant now report to 1.7.18.2.12 the senior vice president nuclear generation. The Figure No. 1.7-1 alignment of the director-quality assurance under the senior vice president nuclear generation, might be perceived as a reduction from the interim alignment of reporting to the chief executive officer (CEO) . An interim alignment was established to accommodate a transition period (from January Hay, 1993) for the new CEO and the retirement of a senior executive vice president. The newly appointed senior vice president nuclear generation reports to the chief executive officer and has appropriate executive authority to ensure that the persons and organizations performing quality assurance functions have the authority and organizational freedom to fulfill these functions. In addition, the senior vice president nuclear generation reports to the same level (i .e., CEO) as the former senior executive vice president. Thus, there is no reduction from what was previously approved prior to the above mentioned transition period.

Throughout gAPD Vari ous insi gni ficant edi tori al changes, including deleting word "the" when proceeding Cook Nuclear Plant; changes in department names; addition or deletion of commas; etc.

Policy Statement guality control responsibilities that were previously 1.7.1.2.2 under the plant manager are now under the di rector-1.7.1.2.5 quali ty assurance.

Figure No. 1.7-3 Note: These gC responsibi 1 i ties were relocated from pages 1.7-25 and 26 to pages 1.7-12 and 13.

r to AEP:NRC:0847Z Page 2 Section(s) Proposed Change(s)

Policy Statement Procedures used in support of Cook Nuclear Plant are 1.7.2.2.4 being reformatted to reflect the above noted 1.7.5.2.2 organizational changes. No changes are being made to 1.7.5.2.3 the procedures which would conflict with the gA 1.7.5.2.5 program requirements. The reformatted procedures are being assembled in the AEP Nuclear Organization Policy 8 Procedure Manual.

Policy Statement The policy statement has been revised to clarify that AEP does not condone suppliers discriminating against their employees for raising safety concerns.

1.7.1.2.2 Clarification added that each manager, involved with (page 1.7-7) safety-rel ated functi ons i s responsibl e for the implementation of the gA program.

1.7.1.2.3 All procurement activi ti es affecting safety functions "Operating are now the responsibility of organizations reporting Companies" to the senior vice president nuclear generation.

(page 1.7-8) Administrative support is still provided by the Purchasing and Stores Department, as specified on pages 1.7-28 and 29. Thus, procurement support is deleted from this section.

1.7.1.2.4 Added procurement engineer as an additional example of (paragraph 5) cognizant engineer.

1.7.1.2.4 Figure 1.7-3 was deleted and reference to Figure 1.7-1 (page 1.7-9) is made. The previous Figure 1.7-3 was unnecessarily redundant to the updated Figure 1.7-1.

1.7.1.2.5 As stated above, quality control (i nspecti on and (gA Department) nondestructive examination) responsibilities have been 1.7.9.2.3 shifted to the gA Department. On page 1.7-12, the 1.7.9.2.4 responsibility for directing the activities of Figure 1.7-3 contractor gC/NDE personnel has been changed. The word "inspection" has been replaced with the word "oversight" to clarify that the responsibility has been and is to oversee, not reinspect inspection/NDE acti vi ties.

In addition, gA Department responsibilities now include coordination of INPO activities which was previously performed by the old Nuclear Operations Department (reference 1993 gAPD, bottom of page 1.7-16). Coordination of Nuclear Reliability Data System (NPRDS) stays with the newly named nuclear support services department (reference page 1.7-17).

to AEP:NRC:0847Z Page 3 Secti on (s) Proposed Change(s) 1.7.1.2.5 Formerly named the Nuclear Operations Department. The (Nuclear Support manager nuclear support services has also been given Services the title chief operations manager.

Department)

(pages 1.7-14 and 29) 1.7.3.2.3 1.7.3.2.4 1.7.1.2.5 The chief nuclear engineer is also the manager-nuclear (Nuclear engineering department. The nuclear engineering Engineering department has and continues to provide procurement Department) support. This section has been changed to clarify (page 1.7-18) this on-going responsibility.

(page 1.7-19) Consistent with the organization changes, the fossil and hydro generation department is identi fied as providing technical assistance on occasion.

(page 1.7-19) The nuclear engineering department now performs some of the safety reviews previously performed by the Nuclear Operations Department. Appropriate expertise has been transferred to accommodate this change.

(page 1.7-22) The responsibility for maintaining design drawing control has been shifted to the Cook Nuclear Plant organization (reference page 1.7-27). Thus, the Design Drawing Control (DDC) program has been deleted from Nuclear Engineering responsibilities.

(page 1.7-23) Coordination responsibilities for design changes; procurement responsibilities; and material service responsibilities have been shifted from the Cook Nuclear Plant organization (reference July 1993 gAPD pages 1.7-24, 25, and 26) to Nuclear Engineering.

1.7.1.2.5 The plant manager has been elected Indiana Michigan (Cook Nuclear Power site vice president which now provides executive Plant) authority at the site.

(page 1.7-23) to AEP:NRC:0847Z Page 4 Section(s) Proposed Change(s) 1.7.1.2.5 The former Project Management and Construction (Site Nuclear Department has been renamed the Site Nuclear Services Services Department and now reports to the senior vice Department) president nuclear generation.

(page 1.7-27)

Consistent with this organizational change the qualifier "construction" has been dropped from the description of the responsibility to admi ni ster and implement job orders. (Reference first site nuclear service department responsibility on page 1.7-27).

1. 7. 1. 2. 5 The title of the executive vice president has been (Purchasing and changed to "administration and chief accounting Stores Department) officer".

(page 1.7-28) 1.7.2.1 The clarification of the definition of safety related (page 1.7-30) has been revised to better clarify that some non-safety related items are classified and designed as Seismic Class 1 or Electrical Class 1E.

1.7.2.2.2 Revised to reflect that "management" other than the (page 1.7-32) director-QA or the plant manager may apply QA controls to nonsafety-related activities.

1.7.2.2.4 The AEP Nuclear Organization Policy E Procedure Hanual (page 1.7-33) is now used to define policies and requi rements.

General Procedures are being replaced by the manual.

1.7.5.2.2 In addition, the word "corporate" is being deleted 1.7.5.2.3 since the new manual will govern the plant site and 1.7.5.2.5 corporate.

1.7.3.2.9 Editorial change. The word "and" deleted after (page 1.7-42) paragraph 3.

1.7.4.2.1 Editorial change. The word "purchase" replaced with (page 1.7-43) the word "procurement".

1.7.4.2.2 page 1.7-44)

to AEP:NRC:0847Z Page 5 Secti on (s) Proposed Change(s) 1.7.7.2.2 Two editorial clarifications are proposed. First, the (page 1.7-52) terms "application-specific" and "contractually" are added to clarify the type of requirements and how the requirements are imposed. Second, the phrase "by the AEPSC cognizant engineer" has been moved to qualify only the word "established" and not the word "accomplished". Accomplishment of dedication program requirements is usually via personnel (e.g. receipt testing personnel) other than co nizant engineers.

1.7.7.2.5 The word "vendor" is replaced with "supplier's (page 1.7-54) faci 1 i ty".

1.7.9.2.2 The last sentence of the first two paragraphs is (page 1.7-58) deleted. The sentences unnecessarily state that audits of specifications and the NDE Hanual will be performed. Specifications and, the NDE Hanual will continue to be audited based on performance in these respective areas. However, to note these areas as being audited when many other gA program areas are equally important appears unwarranted. This proposed change does not reduce our commitment to assure both specifications and the NDE Hanual are audited.

st In addition, clarification is made that weld procedure specifications are reviewed and approved by the welding engineer, and not the records which reflect qualification of the weld procedure specifications.

Also, the word "procedure" has been inserted in the phrase "Weld procedure qualification documentation" to clarify the type of documentation being addressed.

1.7.10.2.4.a Revised to clarify that normal or routine activities may be performed by I&N personnel or contract personnel. The peer inspection program may be used for normal or routine activities, regardless of whether I&N or contract personnel performed the activi ties. The focus of thi s section is that peer inspections are used for normal and routine activities.

1.7.10.2.4.b Consistent with the above clarification, this section has been revised to state that all "major modification and nonroutine" work performed by contract personnel is inspected per ANSI N45.2.6.

The above proposed changes are not reductions in the inspections, instead are clarifications of how the inspections will be accomplished.

to AEP:NRC:0847Z Page 6 Section(s) Proposed Change(s) 1.7.13.2.1 Editorial change. The word "cleanliness" is replaced 1.7.13.2.4 with the word "cleanness" which is consistent with Appendix B, ANSI N45.2.2 1972.

paragraph 3a.

(page 1.7-103) 1.7.14.2.3 Revised to clarify'hat a procedure may be used to record the status of testing, as well as, job orders.

1.7.16.1 The word "problem" has been replaced with the word 1.7.16.2.2 "condition" for consistency throughout this section.

1.7.16.2.2 Revised to clarify that in certain cases management is notified of adverse conditions via audit or surveillance reports.

1.7.18.1 Additional clarification provided to recognize that the audit program i s supplemented with imi ted scope 1

surveillances. Those survei llances are used as an input to future audit planning.

1.7.18.2.4 In certain cases, the audit report itself is used to document insi gni fi cant adverse condi ti ons and the associated corrective actions, rather than adding such minor issues to the corrective action system. To document such minor issues in the corrective action system would distract resources inappropriately.

Appendix A Previous Item 16 "Reg. Guide 1. 108 (8/77)" has been (page 1.7-95) deleted. This deletion is consistent wi th the NRC position to withdraw Regulatory Guide 1. 108, as stated in Eric S. Beckjord's (NRR) letter dated July 19, 1993. Requirements for diesel generators are specified in Technical Specification 3/4.8.

Appendi x B Item 15 has been added to make the gAPD consistent (page 1.7-118) with the approved Technical Specifications.

Specifically, the NRC previously approved an interpretation in Technical Speci Fication 6.2.2.h that the operations superintendent must hold or have held a senior operator license and that one mid-level operations production supervisor shall hold a current senior operator license.

ATTACHMENT 2 PROPOSED CHANGES TO THE gAPD'

I ~ ~ RIITY ASSURANCE PROORAN OESCRIPl FOR THE COOK NUCLEAR PLANT TABLE OF CONTENTS Section Title ~Pa e No.

1.7 Statement of Policy for the Donald C. Cook Nuclear Plant (}uality Assurance Program . . . . . . . ~ ~ 1.7-1 1.7.1 Organization 1.7-4 1.7.2 guality Assurance Program . . . . ~ ~ ~ ~ ~ ~ ~ ~ 1.7-29 1.7.3 Design Control 1.7-37 1.7.4 Procurement Document Control ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ '

~ ~ ~ 1 ~ 7 4-1.7.5 Instructions, Procedures, and Drawings ~ ~ ~ ~ ~ o ~ ~ 1 ~ 7 46 1.7.6 Document Control 1.7-49 1.7.7 Control of Purchased Items and Services . . . . . 1.7-51 1.7.8 Identification and Control of Items . 1.7-56 1.7.9 Control of Special Processes 1.7-57 1.7.10 Inspection 1.7-60 1.7.11 Test Control ~ ~ 1.7-64 1.7.12 Control of Measuring and Test Equipment 1.7-66 1.7.13 Handling, Storage and Shipping 1.7-68 1.7.14 Inspection, Test and Operating Status . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ 7 70 1.7.15 Nonconforming Items . . . . 1.7.72 1.7.16 Corrective Action . . . . . 1. 7-Q 1.7.17 guality Assurance Records . 1.7-75

.1.7,.18 Adt udl ts ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1.7-~78 1.7.19 Fire Protection gA Program 1.7-81 F figure 1.7-1 1.7-88 Figure 1.7-2 1.7-89 Figure 1.7-3 1.7-90 Figure 1.7-4 1.7-91 Appendix A Regulatory and Safety Guide/ANSI Standards . . 1.7-92 Appendix B AEPSC/IM Exceptions to Operating Phase Standards o

and Regulatory Guides . . . . . . . . . . . . . . ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ 7

~ ~ 94060203) 2 ATTACHMENT 1

SUMMARY

OF PROPOSED CHANGES TO THE gAPD to AEP:NRC:0847Z Page 1 Section(s) Proposed Change(s)

Polic'y Statement Changed to reflect the new corporate management 1.7.1.2.1 structure resulting from the promotion of the senior 1.7.1.2.2 vice president nuclear generation and reorganization 1.7.1.2.3 of resources supporting Cook Nuclear Plant. Also 1.7.1.2.5 reflects the additional authority of E. Linn Draper, 1.7.2.2.1 Jr. as president of American Electric Power. All 1.7.4.2.4 primary resources for Cook Nuclear Plant now report to 1.7.18.2.12 the senior vice president nuclear generation. The Figure No ~ 1.7-1 alignment of the director-quality assurance under the senior vice president nuclear generation, might be perceived as a reduction from the interim alignment of reporting to the chief executive officer (CEO). An interim alignment was established to accommodate a transition period (from January Hay, 1993) for the new CEO and the retirement of a senior executive vice president. The newly appointed senior vice president nucleap generation reports to the chief executive officer and'has appropriate executive authority to ensure that the persons and organizations performing quality assurance functions have the authority and organizational freedom to fulfill these functions. In addition, the senior vice president nuclear generation reports to the same level (i.e., CEO) as the former senior executive vice president. Thus, there is no reduction from what was previously approved prior to the above mentioned transition period.

Throughout QAPD Various insignificant editorial changes, including deleting woi d "the" when proceeding Cook Nuclear Plant; changes in department names; addition or deletion of commas; etc.

Policy Statement Quality control responsibilities that were previously 1.7.1.2,.2 under the plant manager are now under the director-1.7.1.2.5 quali ty assurance.

Figure No. 1.7-3 Note: These QC responsibi 1 i ti es were relocated from pages 1.7-25 and 26 to pages 1.7-12 and 13.

to AEP: NRC: 0847l Page 2 Section(s) Proposed Change(s)

Policy Statement Procedures used in support of Cook Nuclear P'lant are 1.7.2.2.4 being reformatted to reflect the above noted 1.7.5.2.2 organizational changes. No changes are being made to 1.7.5.2.3 the procedures which would conflict with the gA 1.7..5.2.5 program requirements. The reformatted procedures are being assembled in the AEP Nuclear Organization Policy 5 Procedure Hanual.

Policy Statement The policy statement has been revised to clarify that AEP does not condone suppliers discriminating against their employees for raising safety concerns.

1.7.1.2.2 Clarification added that each manager, involved with (page 1.7-7) safety-related functions is responsible for the implementation of the gA program.

1.7.1.2.3 All procurement activities affecting safety functions "Operating are now the responsibility of organizations reporting Companies" to the senior vice president nuclear generation.

(page 1.7-8) Administrative support is still provided by the Purchasing and Stores Department, as specified on pages- 1.7-28 and 29. Thus, procurement support is deleted from this section.

1.7.1.2.4 Added procurement engineer as an additional example of (paragraph 5) cognizant engineer.

1.7.1.2.4 Figure 1.7-3 was deleted and reference to Figure 1.7-1 (page 1.7-9) is made. The previous Figure 1.7-3 was unnecessarily redundant to the updated Figure 1.7-1.

1.7.1.2.5 As stated above, quality control (inspection and (gA Department) nondestructive examination) responsibilities have been 1.7.9.2.3 shifted to the gA Department. On page 1.7-12, the 1.7.9.2.4 responsibility for di recting the activities of Figure 1.7-3 contractor gC/NDE personnel has been changed. The word "inspection" has been replaced with the word "oversight" to clarify that the responsibility has been and is to oversee, not reinspect inspection/NDE activities.

In additi on, gA Department responsibilities now include coordination of INPO activities which was previously performed by the old Nuclear Operations Department (reference 1993 gAPD, bottom of page 1.7-

16) . Coordination of Nuclear Reliability Data System (NPRDS) stays with the newly named nuclear support services department (reference page 1.7-17) .

to AEP:NRC:0847Z Page 3 Section(s) Proposed Change(s) 1.7.1.2.5 Formerly named the Nuclear Operations Department. The (Nuclear Support manager nuclear support services has also been given Services the title -chief operations manager.

Department)

(pages 1.7-14 and 29) 1.7.3.2.3 1.7.3.2.4 1.7.1.2.5 The chief nuclear engineer is also the manager-nuclear (Nuclear engineering department. The nuclear engineering Engineering department has and continues to provide procurement Department) support. This section has been changed to clarify (page 1.7-18) thi s on-going responsibi 1 i ty.

(page 1.7-19) Consistent with the organization changes, the fossil and hydro generation department is identified as providing technical assistance on occasion.

(page 1.7-19) The nuclear engineering department now performs some of the safety reviews previously performed by the Nuclear Operations Department. Appropriate expertise has been transferred to accommoda'te this change.

(page 1.7-22) The responsibility for maintaining design drawing control has- been shifted to the Cook Nuclear Plant organization (reference page 1.7-27). Thus, the Design Drawing Control (DDC) program has been deleted from Nuclear Engineering responsibilities.

(page 1.7-23) Coordination responsibilities for design changes; procurement responsibilities; and material service responsibilities have been shifted from the'Cook Nuclear Plant organization (reference July 1993 gAPD pages 1.7-24, 25, and 26) to Nuclear Engineering.

1.7.1.2.5 The plant manager has been elected Indiana Nichigan (Cook Nuclear Power site vice p'resident which now provides executive Plant) authority at the site.

(page 1.7-23) to AEP:NRC:0847Z Page 4 Section(s) Proposed Change(s) 1.7.1.2.5 The former Project Management and Construction (Site Nuclear Department has been renamed the Site Nuclear Services Services Department and now reports to the senior vice Department) president nuclear generation.

(page 1.7-27)

Consistent with this organizational change the qualifier "construction" has been dropped from the description of the responsibility to administer and implement job orders. (Reference first site nuclear service department responsibility on page 1.7-27) .

1.7.1.2.5 The title of the executive vice president has been (Purchasing and changed to "administration and chief accounting Stores Department) officer".

(page 1.7-28) 1.7.2.1 The clarification of the definition of safety related (page 1.7-30) has been revised to better clarify that some non-safety related items are classified and designed as Seismic Class 1 or Electrical Class IE.

1.7.2.2.2 Revised to reflect that "management" other than the (page 1.7-32) director-gA or the plant manager may apply gA controls to nonsafety-related activities.

1.7.2.2.4 The AEP Nuclear Organization Policy L Procedure Manual (page 1.7-33) is now used to define policies and requirements.

General Procedures are being replaced by the manual.

1.7.5.2.2 In addition, the word "corporate" is being deleted 1.7.5.2.3 si nce the new manual will govern the plant site and 1.7.5.2.5 corporate.

1.7.3.2.9 Editorial change. The word "and" deleted after (page 1.7-42) paragraph 3.

1.7.4.2.1 Editorial change. The word "purchase" replaced with (page 1.7-43) the word "procurement".

1.7.4.2.2 page 1.7-44) to AEP:NRC:0847Z Page 5 Section(s) Proposed Change(s) 1.7.7.2.2 Two editorial clarifications are proposed. First, the (page 1.7-52) terms "application-specific" and "contractually" are added to clarify the type of requirements and how the requirements are imposed. Second, the phrase "by the AEPSC cognizant engineer" has been moved to qualify only the word "established" and not the word "accomplished". Accomplishment of dedication program requirements is usually via personnel (e.g. receipt testing personnel) other than co nizant engineers.

1.7.7.2.5 The word "vendor" is replaced with "supplier's (page 1.7-54) facility".

1.7.9.2.2 The last sentence of the first two paragraphs is (page 1.7-58) deleted. The sentences unnecessari,ly'tate that audits of specifications and the NDE Hanual will be performed. Specifications and the NDE Hanual will continue to be audited based on performance in these respective areas. However, to note these areas as being audited when many other gA program areas are equally -important appears unwarranted. This proposed change does not reduce our commitment to assure both specifications and the NDE Hanual are audi ted.

In addition, clarification is made that weld procedure specifications are reviewed and approved by the welding engineer, and not the records which reflect qualification of the weld procedure specifications.

Also, the word "procedure" has been inserted, in the phrase "Weld procedure qualification documentation" to clarify the type of documentation being addressed.

1.7.10.2.4.a Revised to clarify that normal or routine activities may be performed by IKH personnel or contract personnel. The peer inspection program may be used for normal or routine activities, regardless of whether I&H or contract personnel performed the activities. The focus of this section is that peer inspections are used for normal and routine activities.

1.7.10.2.4.b Consistent with the above clarification, this section has been revised to state that all "major modification and nonroutine" work performed by contract personnel is inspected per ANSI N45.2.6.

The above proposed changes are not reductions in the inspections, instead are clarifications of how the inspections will be accomplished.

to AEP:NRC:0847Z Page 6 Section(s) Proposed Change(s) 1.7.13.2.1 Editorial change. The word "cleanliness" is replaced 1.7.13.2.4 with the word "cleanness" which is consistent with Appendix B, ANSI N45.2.2 1972.

paragraph 3a.

(page 1.7-103) 1.7.14.2.3 Revised to clarify that a procedure may be used to record the status of testing, as well as, job orders.

1.7.16.1 The word "problem" has been replaced with the word 1.7.16.2.2 "condition" for consistency throughout this section.

1.7.16.2.2 Revised to clarify that in certain cases management is

-notified of adverse conditions via audit or surveillance reports.

1.7.18.1 Additional clarification provided to recognize that the audit program is supplemented with limited scope survei llances. Those survei llances are used as an input to future audit planning.

1.7.18,2.4 In certain cases, the audit report itself is used to document insignificant adverse conditions and the associated corrective actions, rather than adding such minor issues to the corrective action system. To document such minor issues in the corrective action system would distract resources inappropriately.

Appendix A Previous Item 16 "Reg. Guide 1. 108 (8/77)" has been (page 1.7-95) deleted. This deletion is consistent with the NRC position to withdraw Regulatory Guide 1. 108, as stated in Eric S. Beckjord's (NRR) letter dated July 19, 1993. Requirements for diesel generators are specified in Technical Specification 3/4.8.

Appendix B Item 15 has been added to make the gAPD consistent (page 1. 7-118) with the approved Technical Specifications.

Specifically, the NRC previously approved an

'interpretation in Technical Specification 6.2.2.h that the operations superintendent must hold or have held a seni or operator license and that one mid-level operations production supervisor shall hold a current senior operator license.

ATTACHHENT 2 PROPOSED CHANGES TO THE gAPD

EQUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE COOK NUCLEAR PLANT TABLE OF CONTENTS Title ~Pa e Xe.

o 1.7 Statement of Policy for the Donald C. Cook Nuclear Plant guality Assurance Program . . . . . 1.7-1 1.7.1 Organization 1.7-4 1.7.2 guality Assurance Program . 1.7-29 1.7.3 Design Control 1.7-37 1.7.4 Procurement Document Control 1.7-43 1.7.5 Instructions, Procedures, and Drawings ~ ~ ~ ~ 1.7-46 1.7.6 Document Control 1.7-49 1.7.7 Control of Purchased Items and Services . 1.7-51 1.7.8 Identification and Control of Items . . ~ ~ ~ ~ ~ ~ 1 ~ 7 1.7.9 Control of Special Processes 1.7-57 1.7.10 Inspect>on ~ ~ ~ ~ ~ 1.7-60 1.7.11 Test Control 1.7-.64 1.7.12 Control of Measuring and Test Equipment 1.7-66 1.7.13 Handling, Storage and Shipping 1.7-68 1.7.14 Inspection, Test and Operating Status . 1.7-70 1.7.15 Nonconforming Items . . . . . 1.7.72 1.7.16 Corrective Action . . . . . . . . . . . 17-5 1.7.17 guality Assurance Records . ~ ~ 1.7.-75 1.7.18 A udits 1.7-78 1.7.19 Fire Protection gA Program ~ ~ 1.7-81 Figure 1.7-1 ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ 7 88 Figure 1.7-2 o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ 7 89 o

Figure 1.7-3 1.7-90 Figure 1.7-4 1.7-91 (o:j+>'.

Appendix A Regulatory and Safety Guide/ANSI Standards 1.7-92.

Appendix B AEPSC/ILM Exceptions to Operating Phase Standards and Regulatory Guides . . . . . . . . . . . . . . 1. 7-Q7