ML17321A732

Updated QA Program for DC Cook Nuclear Plant,Units 1 & 2

ML17321A732
Person / Time
Site:	Cook
Issue date:	07/31/1985
From:	INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17321A728	List: ML17321A727 ML17321A732
References
NUDOCS 8507260242
Download: ML17321A732 (123)

Text

DONALD C. COOK NUCLEAR PLANT UNIT NUMBERS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 LICENSE NOS. DPR-58 AND DPR-74 Updated Quality Assurance Program Description for the Donald C. Gook Nuclear Plant July, 3985 07i'8 85O72602gg 85o Control Copy No.

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1

DONALD C. COOK NUCLEAR PLANT U NUMB 1 N DOCK N S. 50-315 AND 50-316 LICENSE N S. DPR-58 AND DPR-74 UPDATED QUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE DONALD C. COOK NUCLEAR PLANT JULY, 1985 Prepared by the AEPSC Quality Assurance Department p

APPROVED BY: 'L sag Ef A PS Mana r of Qua it Assurance

OUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE DONALD C. COOK NUCLEAR POWER PLANT TABLE OF CONTENTS Section Title ~Pa e 8 Table of Contents 1.7 guality Assurance Policy for the Donald C. Cook Nuclear Plant guality Assurance Program................ 1.7-1 1.7.1 0 rganization...........................................

0 1.7-3 1.7.2 equality Assurance Program.............................. 1.7-33 1.7.3 D esign Control......................................... 1.7-40 1.7.4 Procurement Document Control........................... 1.7-45 1.7.5 Instructions, Procedures, and Drawings................. 1.7-48 1.7.6 Document Control....................................... 1.7-50 1.7.7 Control of Purchased Material, Equipment, and Services 1.7-53 1.7.8 Identification and Control of Items.................... 1.7-57 1.7.9 Control of Special Processes........... 1.7-58 1.7.10 I nspection............................................. 1.7-61 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 Materials, Parts, or Components.......... 1.7-72 1.7.16 Corrective Action...................................... 1.7-73 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 Appendix A Regulatory and Safety Guide/ANSI Standards. 1.7.A-93 Appendix B AEPSC/I&MECo Exceptions to Operating Phase Standards and Regulatory Guides...................... 1.7.8-97 July, 1985

1.7 UALITY ASSU."(ANCE AgERlCAN ELECTRlC POWER Company. Inc.

(614) 223-1000 AKP I Riverside Pla:a P.O. Box 16631 Columbus. Ohio 43216-6631 iV. S. lV11ITE, JR.

Chairman of ehe 8oard and Chief E.reeurire Officer rdlA "s I!00 S TAT EMEiV T OF POL ZC Y FOR THE DONALD C. COOK NUCLEAR PLAiVT QUALZTY ASSURANCE PROGRAM POEZCY American Electric Power Company, Znc., recognizes the fundamental importance of contzolling the design, modification and operation of Zndiana a Michigan Electric Company's Donald C. Cook Nuclear Plant (Cook Plant) by implementing a planned and documented Quality Assurance Program, including Quality Control, that complies with applicable regulations, codes and standards.

The Quality Assurance Progzam has been established for safety-related activities oerformed during the ooerations ofr or in support of the Cook Plant. The Quality Assurance P ogram supports the goals of maintaining the safety and reliability of the Cook Plant at the highest Level, and conducting safety-related acti ri t's 'n compliance with appl'cable regulations, codes, standards and establ'shed corporate oolicies and practices.

As Cha'..an of the Board and Ch'ef Executive Of icer of American Electr'c Power Company, Znc., Z maintain the ultimate responsibility for the Quality Assurance Program assoc:ated with the 'Cook P'ant. Z have delegated f uncti onal responsibility for the Qual 'y Assurance Program to the American Electric power Service Corporation (AEpSC) Vice Chairman- Engineering and Const"uct'on. He has, with my approval, delegated further responsibiIities as ou tl 'ned in th 's s ta temen t.

ZMPLEMEiVTATZOV The AEPSC Manage of Quality As-urance, under the d'rect'on or the AE?SC Voce Chairman- Engineering and Construction, has been assigned the overall responsibility for specifying the Quality Assurance Program equire-ments foz the Cook Plant and verifying tneir implementation. The AEPSC Vice Chai "man- Engineering and Construction has given the AEPSC Manager of Quality Assurance author'ty to stop work on any quality-related activity that does not meet appl'cable administrative, technical and/or regulatory requirements. The AEPSC Manager "of Qual'ty Assurance does not have the author'ty to stop unit operations, but shall notify appzopriate plant and/or corporate management oz conditions not meeting the aforementioned criteriar and recommend that unit operations be terminated.

Revised 4-I5-85 1.7-1 July, 1985

~ ~ ~ ~ Page 2 The ".vice President- vuclear operations and che Executi re v'ce President and Chief Engineer, under ehe direction of the AEPSC V'ce Chai man- Engineering and Constzuction, have been delegated responsibility zor e=fecei rely implement-ing the QualiCy Assurance P og am.

The Donald C. Cook Plane 8anager, under Che di " ction of ehe AFPSC Vice president - nuclear Operations, is delegated che responsibili cy f'r establish'..g Cook plant Qual 'ey Conerol and implementing the Quality Assurance Program ae ehe Cook Plant.

The AEPSC Ãanager of QuaLity Assurance is responsible for oroviding technical direction to ehe Plant Manager for maeeers relating to the Qualiey Assurance Program at the Cook PLant. The AEPSC Ãanager of Quali ty Assurance is also responsible for maineaining a Quality Assurance SecCion at the Cook plane eo oerform required revievs and audits, and to orov'de technical Lia'son services to ehe Plant .'fanager.

The inplementat'on of ehe Quality Assurance Program is described in Che AEPSC Cenerai Procedures and subti er department/di vi si on procedures, D. C. Cook plane Hanager's Znstructions (P8Z) and subtier Department iYead Znseructiors and Procedures, vhich in cotal, docurent che requizements for impIementaeion of the Program.

Each AEPSC ard Cook Plant organization that 's, or becomes, inrolved in safety-related acti:ities f'r the Cook Plant has the responsibility to implement ehe polic'es ard "equir ments of the Quality Assurance Program ehae are applicable to the'r respect're a ea(s) of'esponsibiliCy. AEPSC and Cook Plant personnel 'nvolved in sarety-related acti rities shall be fam'liar vith, and compLy vieh, the .equ'" ments of ehe aoplicable Quality Assurance Program require...ents.

CO.YP 2 ZA.VCE The AEPSC .Vanager or Quality Assu "ance shal: mon'tor the conpl'ance ehe estab'ished Qual 'ty Assurance Prog am. Aud't programs shall be estaoshed eo nsure ehae AEPSC and Cook Plant ace'"ities comply viti:

estaosi ed program equizenents, ident'"y defic'encies or noncomp 'ances, and obta'n e =ece've and timely cor ect'v act"ons.

Any emoloyee engaged in safety- elated activie'es vho believes that Che Quali Cy Assurance?rogzam is not being compl'ed vi eh, or Chat a de ic'ency

'n quality exists, should notify his or her suoe risor, the AEPSC Manager o Quality Assurance and/c" the Plant .Yanag~r. Zf Ci:e notification does not 'n the employee's opinion "eceive prompe aeeene'on, ehe employee should contact successivel y h'gi:er Ierel s of management. Employees reporting such cond'tions shall not be d'scz'...'naCed against by companies of the Ame"ican Electric Paver system. Discr'minaeion includes d'scharge or other aceions relat've to conpensae'on, tezms, cond'C'ons or privileges of employmenC.

4

v. S. White, Zz.

Chairman oi ehe Board American Electric Pover Company, Znc.

Revised 4-L5-85

1. 7-2 July, '.SCAN

1.7. 1 ORGANIZATION 1.7. 1. 1 SCOPE American Electric Power Service Corporation (AEPSC) is responsible for establishing and implementing the guality Assurance Program for the operational phase of the D.C. Cook Nuclear Plant (Cook Plant). Although authority for development and execution of various portions of the program may be delegated to others, such as contractors, agents or consultants, AEPSC retains overall responsibility. AEPSC shall evaluate work delegated to such organizations. Evaluations shall be based on the status of safety importance of the activity being performed and shall be initiated early enough to assure effective quality assurance during the performance of the delegated activity and annually thereafter as a minimum.

This section of the guality Assurance Program Description identifies the AEPSC 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 guality Assurance Program, and verifying that activities affecting the quality of safety-related items are performed in accordance with gA Program requirements.

1.7. 1. 2 IMPLEMENTATION 1.7.1.2.1 Source of Authorit The Chairman of the Board and Chief Executive Officer of American Electric Power Company, Inc. (AEP) and AEPSC is responsible for safe operation of the Donald C. Cook Nuclear Plant. Authority and responsibility for effectively implementing the gA Program for plant modifications, operations and maintenance are delegated through the AEPSC Vice Chairman - Engineering and Construction, to the AEPSC Vice President

- Nuclear Operations (Manager of Nuclear Operations) and the AEPSC Executive Vice President and Chief Engineer (reference John E. Dolan 1.7-3 July, 1985

letter'dated November 1, 1984

Subject:

"Support Organization for Donald" C. Cook Nuclear Plant).

In the operation of a nuclear power plant the licensee is required to tabilityy. clear establish and direct lines of responsibility, authority and accoun-This requirement is applicable to the organization providing support to the plant, as well as to the plant staff. While the AEPSC organization changes effective on September 1, 1984, have not affected the responsibility and authority of the Manager of Nuclear Operations, these changes in the AEPSC engineering organization require a new direc-tive for the support of the Cook Plant.

The AEPSC corporate support of the Cook Plant is the responsibility of the entire organization under the direction of the Manager of Nuclear Operations who maintains primary responsibility for the Cook Plant within the corporate organization. The AEPSC Vice President - Nuclear Operations is the Manager of Nuclear Operations. All other AEPSC divisions"and departments, other than the guality Assurance Department, having a supporting role for the Cook Plant are functionally responsible to the Manager of Nuclear Operations (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 responsibilities, of the Manager of Nuclear Operations shall be dedicated to the area of nuclear plant operations and support.

2) The Manager of Nuclear Operations shall be responsible for, and has the authority to direct all nuclear operational and support matters within the corporation and shall make or concur in all final decisions regarding significant nuclear safety matters.

3) AEPSC division and department managers responsible for nuclear matters shall be familiar with activities within their scope of responsibility that affect plant safety and reliability. They shall 1.7-4 July, 1985

'e cognizant of and sensitive to internal and external factors that might affect the operations of the Cook Plant.

4) AEPSC division and department managers responsible for nuclear matters have a commitment to seek and identify problem areas and take corrective action to eliminate unsafe conditions, or to improve trends that will upgrade plant safety and reliability.

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

6) AEPSC division and department managers having nuclear support responsibilities as well as the Plant Manager and plant department managers shall be familiar with the policy statements from higher management concerning nuclear safety and operational priorities.

They shall be responsible for ensuring that activities under their direction are performed in accordance with these policies and the referenced subject letter.

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

~0eratioas The 'American Electric Power Company, Inc., (AEP) Chairman of the Board and Chief Executive Officer has delegated the functional responsibility of the quality Assurance Program to the American Electric Power Service Corporation (AEPSC) Vice Chairman - Engineering and Construction.

The AEPSC Manager of guality Assurance, under the direction of the AEPSC Chairman - Engineering and Construction, is responsible for

'ice specifying guality Assurance Program requirements and verifying their implementation.

1.7-5 July, 1985

The AEPSC~Vice President - Nuclear Operations and AEPSC Executive Vice, President and Chief Engineer, under the direction of the AEPSC Vice Chairman - Engineering and Construction, are responsible for effectively implementing the guality Assurance Program.

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

Management/supervisory personnel receive functional training to the level necessary to plan, coordinate, and administrate those day-to-day verifi-cation activities of the gA Program for which they are responsible.

AEPSC has established an independent off-site Nuclear Safety and Oesign Review Committee (NSORC) which has been established pursuant to the requirements of the Technical Specifications for the Cook Plant. The function of the NSORC is to oversee the engineering, design, operation, and maintenance of the Cook .Plant by performing audits and.,independent reviews of activities which are specified in the Facility Operating Licenses.

The Cook Plant on-site review group is the Indiana 8 Michigan Electric Company (IKMECo) Plant Nuclear Safety Review Committee (PNSRC). This committee has been established pursuant to the requirements of the Cook Plant Technical Specifications. The function of the PNSRC is to review plant operations on a continuing basis and advise the Plant Manager on matters related to nuclear safety.

1.7. 1.2.3 Cor orate Or anization American Electric Power Com an AEP, the parent holding company, wholly owns the common stock of all AEP System subsidiary (operating) companies. The major operating companies and generation subsidiaries are shown in Figure 1.7-2. The Chairman of the 8oard of AEP is the Chief Executive Officer of all operating July, 1985

companies. The responsibility for the functional management of the major operating companies is vested in the President of each operating company reporting to the AEPSC President and Chief Operating Officer who reports to the AEPSC Chairman of the Board and Chief Executive Officer.

American Electric Power Service Cor oration The responsibility for administrative and technical direction of the AEP System and its facilities is delegated to the American Electric Power Service Corporation (AEPSC). AEPSC provides management and technological services to the various AEP System Companies.

0 eratin Com anies The operating facilities of the AEP System are owned and operated by the respective operating companies. The responsibility for executing the engineering, design, construction, specialized technical training, and certain operations supervision is vested in AEPSC while all or part of the administrative function responsibility is assigned to the operating companies. In the case of Cook Plant, 18MECo provides only public affairs, accounting and industrial safety direction.

The Donald C. Cook Nuclear Plant is owned and operated by Indiana 5 Michigan Electric Company ( ISMECo) which is part of the AEP system.

1.7. 1.2.4 ualit Assurance Res onsibi lit of AEPSC

1) AEPSC provides the technical direction of the Cook Plant, and as such makes the final decisions pertinent to safety-related changes in plant design. Further, AEPSC reviews NRC letters, bulletins, notices, etc., for impact on plant design, and the need for design changes or modifications.

2) AEPSC furnishes licensing, NRC correspondence, fuel management and radiological support activities.

1. 7-7 July, 1985

3) AEPSC provides additional service in matters such as supplier qualification, and spare and replacement part procurement, to the extent established by AEPSC and plant procedures.

4) The AEPSC gA Department provides technical direction in quality assurance matters to AEPSC and the Cook Plant, and oversees the adequacy and implementation of the gA Programs through review and audit activities.

ualit Assurance Res onsibilit of IEMECo - D.C. Cook Plant I

As owner and operator, ISMECo operates the Cook Plant per licensing requirements, including the Technical Specifications and such other commitments as established by the operating licenses. The Plant Manager Instruction (PMI) system and subtier instructions and procedures describe the means by which compliance is achieved and responsibilities are assigned, including interfaces with AEPSC. Figure 1.7-3 .indicates the organizational relationships within the AEP System pertaining to the operation and support of the Cook Plant.

1.7..1.2.5 Or anization AEPSC The Chairman of the Board and Chief Executive Officer is ultimately responsible for the guality Assurance Program associated with the Cook Plant. This responsibility has been functionally delegated to the AEPSC Vice Chairman - Engineering and Construction. The AEPSC Vice Chairman-Engineering and Construction has further delegated responsibilities which are administered through the following division and department management personnel:

AEPSC Manager of guality Assurance AEPSC Vice President - Nuclear Operations AEPSC Executive Vice President and Chief Engineer 1.7-8 July, 1985

ualit Assurance De artment The AEPSC Manager of Quality Assurance reports to the AEPSC Vice Chairman

- Engineering and Construction and is responsible for the Quality Assurance Department. The Quality Assurance Department consists of the following positions and sections (Figure 1.7-4):

Quality Assurance Engineering Section Audits and Procurement Section Training and Procedures Specialist Quality Assurance Staff Specialist D.C. Cook Plant Site Quality Assurance Section The Quality Assurance Department is organizationally independent and is responsible to perform the following:

Identify quality problems.

Initiate, recommend, or provide solutions through designated channels.

Verify implementation of solutions.

Prepare issue and maintain Quality Assurance Program documents, as required.

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

Review engineering, design, procurement, construction and oper-ational, documents for incorporation of, and compliance with applicable quality assurance requirements to the extent specified by the AEPSC management approved QA Program.

Organize and conduct the QA orientation, training, certification and qualification of AEPSC personnel.

Provide general guidance, when requested, for the collection, storage, maintenance, and retention of quality assurance records.

Establish and maintain a Qualified Suppliers List (QSL) of nuclear (N) items and services.

Identify noncompliances of the established QA Program to the respon-sible organizations for corrective actions and report significant occurrences that jeopardize quality to senior AEPSC management .

1.7-9 July, 1985

Follow up on corrective actions identified by. gA du> ing and after disposition implementation.

Assure that conditions adverse to quality are dispositioned to preclude recurrence.

Conduct in-process gA surveillance at supplier's facilities, as required.

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

- guality Assurance Program.

Maintain a list of nuclear grade items (N-List) for the D.C. Cook Plant.

Establish a mechanism for identifying, tracking and closing out quality-related commitments.

Conduct audits as directed by the Nuclear Safety and Design Review Committee (NSDRC).

Review AEPSC originated nonconformances, noncompliances and associated corrective action recommendations.

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

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

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

Provide AEPSC management with periodic reports concerning the status, adequacy and implementation of the gA Program.

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

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

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

July, 1985

Am lification of S ecific Res onsibilities ualification of the AEPSC Mana er of ualit Assurance The AEPSC Manager of Quality Assurance shall possess the following position requirements:

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

Ten (10) years experience in one or a combination of the following areas: engineering, design, construction, operations, maintenance of fossil or nuclear power gene-ration facilities or utility facilities; Quality Assurance; of which at least four (4) years must be experience in quality assurance related activities.

Knowledge of QA regulations, policies, practices and standards.

The same or higher organization reporting level as the highest line manager directly responsible for performing activities affecting quality such as engineering, procure-ment, 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.

Sto Work Orders The AEPSC Quality Assurance Oepartment is responsible for ensuring that quality related activities are performed in a manner that meets applicable administrative, technical, and regulatory requirements. In order to carry out this responsibility, the AEPSC Vice Chairman - Engineering and Construction has given the AEPSC Manager of Quality Assurance, the authority to stop work on any quality related activity that 1.7-11 July, 1985

" does not meet the aforementioned requirements. Stop work authority has been further delegated by the AEPSC Manager of quality Assurance to the Supervisor - guality Assurance (site).

The AEPSC Manager of guality Assurance and the Supervisor-quality Assurance do not have the authority to stop unit operations, but will notify appropriate plant and/or corporate management of conditions which do not meet the aforementioned criteria, and recommend that unit operations be terminated.

A Orientation, Trainin uglification and Certification

~Pro ram a) AEPSC gA shall, if directed by AEPSC management, be responsible for establishing, maintaining and conducting a general gA orientation and training program for AEPSC personnel engaged in safety-related activities. This program includes the AEPSC gA philosophy and such facility specific programs as may be required by facility or regulatory requirements.

b) AEPSC has established and maintains a gA Auditor training and certification program for all AEPSC gA Auditors.

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

Nuclear 0 erations Oivision The AEPSC Vice President - Nuclear Operations (Manager of Nuclear Oper-ations) reports to the AEPSC Vice Chairman - Engineering and Construction and is responsible for the Nuclear Operations Oivision. Reporting to the AEPSC Vice President - Nuclear Operations are the following:

July, 1985

Donald C. Cook Plant Manager 1

Assistant Division Manager - Nuclear Engineering (not charted)

Assistant Division Manager - Nuclear Operations (not charted)

Consulting Nuclear Engineer - Nuclear Operations (not charted)

Staff Engineer - Nuclear Operations (not charted).

The organization and responsibilities of the Donald C. Cook Plant Manager d i f 0 i li hi <Ihen design verification is done by evaluating standardized or previously proven designs, the applicability of such designs is confirmed. Any 1.7-42 July, 1985

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

gualification testing of prototypes, components, or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated. This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function. gualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented. Results are evaluated to assure that test requirements have been satisfied. Hodifi-cations shown to be necessary through testing are made, and any necessary retesting or other verification is performed. Test configurations are clearly documented.

Oesign reviews are performed by mul ti-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.

1.7.3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience but are not directly responsible for the design.

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

1) The supervisor is the only technically qualified individual.

2) The supervisor has not specified a singular design approach, ruled out design considerations, nor established the design inputs.

1.7-43 July, 1985

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

4) Regularly scheduled gA audits verify conformance to items 1 through 3 above.

Design verification on safety-related design verification shall be completed prior to declaring a design change operational.

1.7.3.2.10 Plant implementation of the RFC is accomplished by the Plant Manager assigning a specific plant department the responsibility for coordinating the design change. Material to perform the design change must meet the specifications established for the original system or as specified by the lead engineer. For those design changes where testing after completion is required, the testing documentation'is reviewed by the organization performing the test and, when specified, by the AEPSC lead engineer or cognizant engineer. Further, completed RFCs are reviewed by AEPSC gA (Site) following installation and testing.

1.7.3.2.11 Changes to design documents, including field changes, are reviewed, approved and controlled in a manner commensurate with that used for the original 'design. Such changes are evaluated for impact. Information on approved changes is transmitted to all affected organizations.

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

1.7-44 July, 1985

This mechanism provides for: 1) controlled submission of design changes,

2) engineering evaluation, 3) review for impact, on nuclear safety, 4) review by AEPSC gA, 5) design modification, 6) AEPSC 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 applicable regulatory and industry codes/standards requirements and specify supplier guality Assurance Program requirements to the extent necessary to assure adequate quality.

1.7.4.2 IMPLEMENTATION 1.7.4.2.1 Procure ement documents for safety-related materials/services originating at the plant, except as denoted below, are processed through AEPSC for review and approval. The plant may request the assistance of AEPSC cognizant engineers in any procurement activity.

Procurement control is established by instructions and procedures. These documents require that purchase documents be sufficiently detailed to ensure that purchased materials,> components and services associated with safety-related structures or systems are: 1) purchased to specification and code requirements equivalent to those of the original equipment or service, 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.

Procedures establish the review of procurement documents to determine that: quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance criteria; procurement 1.7-45 July, 1985

~ .4 4 A %J ' 'I 4~

documents have been prepared, reviewed and approved in accordance with established requirements.

Each involved manager is responsible for procurement planning, bid solicitation and bid evaluation.

1.7.4.2.2 The N-List, in conjunction. with other sources, is used to determine equipment classification. Donald C. Cook Nuclear Plant Specifications (OCC Specifications) are used to determine material and documentation requirements, codes or standards that materials must fulfill, and define the documentation that must accompany the material to the plant.

Department heads cognizant of the equipment and its quality assurance requirements review all procurement documents to assure that correct classification is made; that the appropriate plant specifications which identify quality requirements, are referenced or attached; and that the documentation requirements are properly stated. Purchase requisitions for new safety-related equipment are initiated by the AEPSC cognizant engineers who establish the initial equipment quality assurance require-ments. Replacement or spare equipment is procured via the original purchase requirements. In instances where these requirements have been superseded by a revised specification, the replacement/spare part is procured to the revised requirements.

1.7.4.2.3 The contents of procurement documents vary according to the item(s) being purchased and its function(s) in the plant. Provisions of this SWAPO are considered for application to service contractors also. As applicable, procurement documents include:

a) Scope of work to be performed.

1.7-46 July, 1985

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

c) Regulatory, administrative and reporting requirements.

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

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

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

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

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

1.7.4.2.4 The AEPSC gA Department performs off-line reviews of procurement documents to assure that the procurement documents have been prepared, reviewed and approved per the gA program requirements.

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

1.7-47 July, 1985

1.7.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.7.5. 1 SCOPE Activities affecting the quality of safety-related structures, sys-.ems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances, including acceptance criteria for determining if an'ctivity has been satisfactorily completed.

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 specification of and/or implementation of the OA Program receive multiple reviews for technical adequacy and inclusion of. appropriate quality requirements. Top tier instructions and procedures are reviewed and approved by AEPSC gA. Lower tier documents are reviewed and approved, as a minimum by management/

supervisory personnel trained to the level necessary to plan, coordinate and administer those day-to-day verification activities of the OA Program for which they are responsible.

Temporary procedures may be issued for activities'which have short-term appl i ca bi 1 i ty.

1.7.5.2.2 AEPSC activities relative to the D.C. Cook Nuclear Plant are outlined by procedures which provide the controls for the implementation of these activities. AEPSC has two categories of gA program procedures:

1.7-48 July, 1985

1) General Procedures which are applicable to all divisions of the corporation.

2) Division/Section Procedures which apply to the specific division or section involved.

1.7.5.2.3 The Plant Manager Instructions have been classified into the following series:

1000 Organization 2000 Administration 3000 Procurement, Receiving, Shipping and Storage 4000 Operations, fuel Handling, Surveillance Testing 5000 Maintenance, Repair and Modification 6000 Technical Services - Chemistry, Radiological Controls, Engineering and Instrument Maintenance and Calibration 7000 guality Services - Review and Audit, Equipment Classification, Indoctrination and Training, Inspections, etc.

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 proce-dures may either provide the guidance necessary for fhe development of supplemental instructions and/or procedures to implement their require-ments, or provide comprehensive guidance based on the subject matter.

1.7.5.2.4 Plant drawings are produced, controlled and distributed under the control of AEPSC and the plant. AEPSC design drawings are produced by the AEPSC Design Division 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 Divisions.

1.7-49 July, 1985

AEPSC ha's'tationed an on-site design staff to provide for 'the revision of certain types of design drawings to reflect as-built conditions.

1.7.5.2.5 Complex plant procedures are designated as "In Hand" procedures.

Examples of "In Hand" procedures are those developed for extensive or complex jobs where reliance on memory cannot be trusted. Further, those procedures. which describe a sequence which cannot be altered or require the documentation of data during the course of the procedure, are considered. "In Hand" procedures are designed 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 Section 2.0, "guality Assurance Program" are issued and changed according to established procedures. Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for release by authorized personnel and are distributed and used at the location where a prescribed activity is performed.

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

1.7.6.2 IMPLEMENTATION 1.7.6.2.1'ontrols are established for approval, issue and change of documents in the following categories:

1.7-50 July, 1985

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

b) Drawings and related documents.

c) Procurement documents.

d) Instructions and procedures.

e) Final Safety Analysis Report (FSAR).

f) Nuclear Regulatory Commission submittals.

g) Plant Technical Specifications.

h) Safeguards documents.

1.7.6.2.2 The review, approval, issuance and change of documents are controlled by:

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

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

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

Maintenance, modification and inspection procedures are reviewed by AEPSC gA for compliance with established inspection requirements.

1.7.6.2.3 Documents are issued and controlled so that:

a) The documents are available prior to commencing work.

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

July, 1985

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

1.7.6.2.7 A mechanism has been established which controls responses to NRC documents ( I.f. Bulletins, I.E. Inspection Reports, Generic Letters, etc.). These responses, which are uniquely identified by an individual number, require several levels of review and approval.

1.7-52, July, 1985

1,7.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 1.7.7.1 SCOPE Activities that implement approved procurement requests, for material, equipment and services are controlled to assure conformance with procure-ment document requirements. Controls include a system of supplier evaluation and selection, source inspection, audit and acceptance of items and documents upon delivery and periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant site prior to use of equipment, material, or services.

1.7.7.2 IMPLEMENTATION 1.7.7.2.1 AEPSC qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. All material, equipment and services, designated safety-related, are purchased from suppliers whose gA programs have been accepted in accordance with AEPSC requirements. gualification of such suppliers and maintenance of a gualified Supplier List (gSL) is.

accomplished by the AEPSC gA Department. In the discharge of this responsibility, the AEPSC gA Department utilizes information generated by others (such as the CASE Association and ASME) to aid in the supplier qualification process. Distinction is made between suppliers, stocking distributors (warehouses) and sales offices. The supplier or distributor must be on the gSL before procurement can be completed.

AEPSC is a member of CASE and performs audits for submittal to the CASE Register as well as the plant's gualified Supplier List. The CASE Register provides a prescreened list of potential suppliers with gA programs. An evaluation is made if there is an interest in a CASE listed supplier to consider the scope of the qualification audit and the identity of the auditor which are stated in the Register. Additional program surveys will be conducted, as necessary, to meet requirements.

1.7-53 July, 1985

Acceptance is not complete until it has been determined that the supplier can meet the basic gA and technical requirements of the product or service that is required.

1.7.7.2.2 For commercial "off-the-shelf" items where the requirements for a specific guality Assurance Program appropriate for nuclear applications

. cannot be imposed in a practical manner, source verification is used to provide adequate assurance of acceptability.

1.7.7.2.3 In-process surveillance of suppliers'ctivities during fabrication, in'spection,'esting and shipment of items is performed when deemed necessary, depending upon supplier qualification status; complexity and .

importance to safety of the item being furnished,'and/or previous supplier history. This surveillance i,s performed by the cognizant engineering department, responsible plant department, or AEPSC gA, or any combination th'ereof.

1,7.7.2.4 Spare and replacement parts are procured in such a manner that their performance and quality are at least equivalent to those of the parts that will be replaced.

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

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

1.7-54 July, 1985

c) Where quality requi'rements for the original items cannot be deter-mined, requirements and controls are established by engineering evaluation performed by qualified individuals. The evaluation assures there is no adverse effect on interfaces, safety, fit, form, function, or compliance with

'nterchangeability, applicable regulatory or code requirements. Evaluation results are documented.

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

1.7.7.2.5 Instructions and procedures address requirements for supplier selection and control as well as procurement document control. The PMI on receipt inspection of safety-related materials addresses the program for inspection of incoming materials including a review of the"documentation required under the procurement. Receipt inspection provisions apply regardless of whether procurement originates at the plant or at AEPSC.

Additional inspections may apply if requi,red by the procurement document.

Where materials and/or services are safety-related and procurement is accomplished without assistance of AEPSC, supplier selection is limited to those companies identified on the qualified Suppliers List (gSL).

1.7.7.2.6 Materials received at the site are tagged with a "Hold" tag and placed in a designated, controlled area until receipt inspected. During receipt inspection, designated material characteristics and attributes are checked, and documentation is checked against the procurement documents.

If found acceptable, the "Hold" tag is removed and replaced with an "Accepted" tag and the material is placed in a designated area of the storeroom. Material traceability to procurement documents and to end use is maintained through recording of Hold Tag and Acceptance Tag number on applicable documents.

1.7-55 July, 1985

Nonconforming materials, or missing or questionable documentation results in materials being kept on hold and placed in a designated, controlled area of the storeroom. If the nonconformance cannot be cleared, the material is either scrapped, returned to manufacturer, or dispositioned through engineering 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 plant quality assurance program and procedures. Prior to their working at the plant, contractor quality assurance programs and procedures must be reviewed and approved by the AEPSC Site (equality Assurance Supervisor, PNSRC and the Plant Manager.

Furthe~, periodic audits of site contractor activities are conducted under the direction of the'AEPSC Site guality Assurance Supervisor.

1.7.7.2.8 Suppliers are required to furnish the following records:

a) Applicable drawings and related engineering documentation that identify the purchased item and the specific procurement requirements (e.g., codes, standards and specifications) met by the item.

b) Documentation identifying any procurement requirements that have not been met.

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

d) guality records as specified in the procurement requirements.

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The validity of supplier certificates of conformance is evaluated at the time of supplier resurvey and requalification.

1.7.8 IOENTIFICATION ANO CONTROL OF ITEMS 1.7.8.1 SCOPE Materials, parts and components (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 materials, parts and components (including partially fabricated assemblies).

1.7.8.2.2 Items are identified by physically marking the item or its container, and by maintaining records traceable to the item. The method of identi-fication is such that the quality of the item is not degraded.

1.7.8.2.3 Items are traceable to applicable drawings, specifications or other pertinent documents to ensure that only correct and acceptable items are used. Verification of traceability is performed and documented prior to, release for fabrication, assembly, or installation.

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

1.7.8.2.5 Separate storage is provided for incorrect or defective materials that are on hold, and material which has been accepted for use. All safety-related materials are appropriately tagged or identified (stamping, etc.)

to provide easy identification as to the materials usage status. Records are maintained for the issue of materials, to provide traceability from storage to end use in the plant.

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

1.7.9 CONTROL OF SPECIAL PROCESSES 1.7.9.1 SCOPE Special processes are controlled and are accomplished by qualified personnel using approved procedures and equipment in accordance with applicable codes', standards, specifications, criteria and other special requirements.

1.7.9.2 IMPLEMENTATION 1.7.9.2.1 Processes subject to special process controls are those for which full verification or characterization by direct inspection is impossible or impractical. Such processes include welding, heat treating, chemical 1.7-58 July, 1985

cleaning, application of protective coatings, concrete placement and nondestructive examination.

1.7.9.2.2 Special process requirements for chemical cleaning, application of protective coatings and concrete placement are set forth in AEPSC Specifications and/or directives prepared by the responsible AEPSC Cognizant Engineer. These documents are reviewed and approved by other personnel with the necessary technical competence. AEPSC Specifications are reviewed by the AEPSC gA Department.

Special process requirements for welding, heat treating and nondestruc-tive examination (NDE) are set forth in AEPSC Specifications and the AEPSC Welding and NOE Manuals. These specifications and manuals are prepared by the AEPSC Staff Metallurgist (Corporate Level III NDE Administrator) and are reviewed and approved by other personnel with the necessary technical competence. The AEPSC NDE Manual is reviewed by the AEPSC gA Department.

Special process procedures with the exception of welding and heat treating are prepared by plant personnel with technical knowledge in the discipline involved. These procedures are reviewed by other personnel with the necessary technical competence and are qualified by testing.

Welding is performed in accordance with the procedure contained in the AEPSC Welding Manual. These procedures are qualified by the plant in accordance with applicable codes and standards, and Procedures gualifica-tion Records are prepared. The weld procedure qualification documenta-tion is reviewed and approved by the Plant Maintenance Superintendent or a designated plant engineer, or an AEP System welding representative.

This documentation is also reviewed by either the AEPSC Staff Metallur-gist, Mechanical Engineering Division or Plant Engineering Division.

Weld qualification documentation is retained in the AEPSC Welding Manual.

1.7-59 July, 1985

Contractor welding procedures are qualified by the contractor . These procedures and the qualification documentation is reviewed and approved by the plant.and the AEPSC Staff Metallurgists, Mechanical Engineering Division. This documentation is retained by the contractor.

1.7.9.2.3 Special process personnel qualification and certification, except for welders, is by either a designated Corporate Level III NDE Administrator or by a Plant Level III Inspector who has been qualified and certified by the designated Corporate Level III NDE Administrator. Certification is based on examination results. Personnel qualification is kept current by performance of the special process(es) and/or reexamination at time intervals specified by applicable codes, specifications and standards.

Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals, requires recertification.

Plant welders are qualified by the maintenance and QC Departments utilizing the procedures in the AEPSC Welding Manual. Plant welder qualification records are maintained for each welder by the Maintenance Department. Contractor and craft welders are qualified by the contractor utilizing procedures approved by the plant and the AEPSC Staff Metallurgist, Mechanical Engineering Division. Contractor and craft welder qualification records are maintained by the contractor.

1.7.9.2.4 Quality Control Technicians assigned to the Quali.ty Control Department perform nondestructive testing for work performed by plant and contractor personnel. These individuals are qualified by SNT-TC-lA and records of the qualifications are maintained at the plant.

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For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and specifications.

1.7.9.2.6 gualification records are maintained in accordance with Section 17, "guality Assurance Records".

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

1.7. 10 INSPECTION 1.7. 10. 1 SCOPE Activities affecting the quality of safety-related structures, systems and components are inspected to verify their conformance with requirements. These inspe'ctions 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.

July, 1985

Hold points are provided in the sequence of procedures to allow for the inspection, witnessing, examination, measurement, or review necessary to assure that the critical or irreversible elements of an activity are being performed as required. Note that hold points may not apply to all procedures but each must be reviewed for this attribute.

Hold points specify exactly what is to be done (e.g., type of inspection or examination, etc.), acceptance Criteria, or reference to another procedure, and the individual(s) by job title who must perform or attest to the satisfactory completion of the hold point.

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

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

1.7.10.2.2 Training and gualification Programs for personnel who per form inspections are established, implemented and documented in accordance with Section 1.7. 2, "qua 1 i ty Assurance Program".

1.7. 10.2. 3 Inspection requirements are specified in procedures, instructions, drawings, or checklists as applicable. They provide for the following as appropriate:

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

b) Identification of characteristics and activities to be inspected.

c) Inspection methods.

1.7-62 July, 1985

d) Specification of measuring and test equipment having the necessary accuracy.

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.

1.7.10.2.4 The Plant guality Control Department has been assigned the responsibility for establishing and executing the following programs:

a) In-process verifications and inspections.

b) Inservice inspections.

To ensure the quality of the maintenance, operation, technical, administrative, planning and construction activities at the D.C.

Cook Nuclear Plant, the Plant Quality Control Department will inspect, monitor and verify key attributes that have been deemed necessary to assure the acceptability of:

a) Equipment b) Tests c) Processes d) Materials e) Parts f) Components g) System checks The performance of these inspections, verifications and monitoring will be defined by instructions/procedures written by the responsible plant departments.

1.7-63 July, 1985

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.

1.7.10.2.6 Inspection of work associated with normal operation of the plant, such as surveillance tests and verification of routine maintenance, may be performed by individuals in the same group as that which performed the work, but not by personnel who directly performed or supervised the work.

The qualification of these personnel is described in Appendix B hereto, item no. 9.

1.7.11 'EST CONTROL 1.7. 11. 1 SCOPE Testing is performed in accordance with established programs to demon-strate that structures, systems and components will perform satisfactor-ily in service. The testing's'erformed by qualified personnel in accordance with written procedures that incorporate specified requirements and acceptance criteria. Types of tests are:

Scheduled I

Surveillance, preventive maintenance, post-design, qualification.

Unscheduled Pre- and post-maintenance.

1.7-64 July, 1985,

Test parameters, including any prerequisites, instrumentation require-ments and environmental conditions, are specified in test procedures.

Test results are documented and evaluated.

1.7. 11. 2 IMPLEMENTATION l.7. 11.2. I Tests are performed in accordance with programs, procedures and criteria that designate when tests are required and how they are to be performed.

Such testing'includes the following:

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

b) Acceptance tests of equipment and components to assure their opera-tion prior to delivery or installation.

c) Post-design tests to assure proper and safe operation'f systems and equipment prior to unrestricted operation.

d) Surveillance tests to assure continuing proper and safe operation of systems and equipment. The PMI on surveillance testing controls the periodic testing of equipment and systems to fulfill the surveillance requirements established by the Technical Specifications. The scheduling of these activities is reviewed by an Assistant Plant Manager. 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.

1.7-65 July, 1985

1.7.11.2.2 Test procedures, as required, provide mandatory hold points for witness, or review.

1.7.11.2.3 Testing is accomplished after installation, maintenance, or repair, by surveillance test procedures or performance tests which must be satisfac-torily completed prior to determining the equipment is in an operable status. All data resulting from these tests is retained at the plant after review by appropriate management personnel.

I 1.7.12 CONTROL OF MEASURING AND TEST EQUIPMENT 1.7. 12. 1 SCOPE Measuring and testing equipment used in activities affecfing the quality of safety-related systems, components and structures are properly identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within necessary limits.

1.7. 12. 2 IMPLEMENTATION 1.7.12.2.1 Each involved plant department has established procedures for calibration and control of measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components. These procedures describe calibration techniques and frequencies, and mainte-nance and control of the equipment.

The AEPSC Site Quality Assurance Section periodically assesses the effectiveness of the calibration program via the QA audit program.

1.7-66 July, 1985

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

1.7.12.2.3 A system has been established utilizing labels which are to be attached to measuring and test equipment to display the date calibrated and the next calibration due date. Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.

1.7.12.2.4 Measuring and test equipment is calibrated at specified intervals. These intervals are based on the frequency of use, stability characteristics and other conditions that could adversely affect the required measurement accuracy. Calibration standards are traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions are established to document the basis for calibration.

The primary standards used to calibrate secondary standards have, except in certain instances, an accuracy of at least four (4) times the required accuracy of the secondary standard. In those cases where the four (4) times accuracy cannot be achieved, the basis for acceptance is documented and is authorized by the responsible manager. The secondary standards have an accuracy that assures that the equipment being calibrated will be within the required tolerances and the basis for acceptance is documented and authorized by the responsible manager.

1.7.12.2.5 A series of PMIs define the requirements for the control of standards, test equipment and process equipment.

1.7-67 July, 1985

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.

1.7.13 HANDLING, STORAGE% AND SHIPPING 1.7. 13. 1 SCOPE Activities with the potential for causing contamination or deterioration, by environmental conditions such as temperature or humidity that could adversely affect the ability of an item to perform its safety-related functions and activities necessary to prevent damage or loss are identi-fied 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 l.7. 13.2. 1 Procedures are used to control the cleaning, handling, storing, packaging, preserving and shipping of materials, components and systems in accordance with designated procurement requirements. These procedures include, but are not limited to, the following functions:

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

b) Packaging and preservation - to provide adequate protection against damage or deterioration. When necessary, these procedures provide for special environments such as inert gas atmosphere, specific moisture content levels and temperature levels.

1.7-68 July, 1985

c) Handling - to'preclude damage or safety hazards.

d) Storing - to minimize the possibility of loss, damage, or deterio-ration of items in storage, including consumables.such as chemicals, reagents and lubricants. Storage procedures also provide methods to assure that specified shelf lives are not exceeded.

-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 1'ife expired materials from being used in the plant. Controls are established in PMIs.

1.7.13.2.3 Packaging and shipping requirements are provided to vendors with the DCC Specifications which are a part of the purchase order. Controls for receipt inspection, damaged items and special handling requirements at the plant are established by a PHI. Special controls are provided to assure that stainless steel components and materials are handled with approved lifting slings.

1.7.13.2.4 Storage and surveillance requirements have been established to assure segregation of storage. Special controls have been implemented for critical, high value, or perishable items. Routine surveillance is conducted on stored material to provide inspection for damage, rotation of stored pumps and motors; inspection for protection of exposed surfaces and cleanliness of the storage area.

1.7-69 July, 1985

Special handling procedures have been implemented for the processing of nuclear fuel during refueling outages. These procedures minimize the risk of damage to the new and spent fuel and the possible release of radioactive material when placing the spent fuel into the spent fuel pool.

1.7.14 INSPECTION, TEST, AND OPERATING STATUS 1.7. 14. 1 SCOPE Operating status of structures, systems and components is indicated by tagging of valves and switches, or by other specified means, in such a manner as to prevent inadvertent operation. The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.

1.7. 14. 2 IHPLEHENTATION 1.7.14.2.1 For RFC (Design Change) activities, including item fabrication, instal-lation and test, a PHI exists which specifies the degree of control required for the identification of inspection and test status of struc-tures, systems and components.

Physical identification is used to the extent practical, to indicate the status of items requiring inspections, tests, or examinations. Proce-dures exist which provide for the use of calibration and rejection stickers, tags, stamps and other forms of identification to indicate test and inspection status. The Clearance Permit System uses various tags to identify equipment and system operability status. Another PMI establishes a tagging system for bypassed safety functions. For those items requiring calibration, a PMI exists which requires physical indica-tion of calibration status by calibration stickers.

1.7-70 July, 1985

I.7,14.2.2 Application and removal of inspection and welding stamps, and of such status indicators as tags, marking, labels, etc., are controlled by plant procedures.

The inspection status of materials received at the plant is identified in accordance with instructions established in a PMI. The status is identi-fied as Hold, Hold for guality Control Clearance, Reject, or Accept.

The inspection status of work in progress is controlled by the use of hold points in procedures. Plant guality Control or departmental super-visory personnel inspect an activity at various stages and sign off the procedural steps covered by the inspection.

The status of welding is controlled through the use of a weld data block which identifies the inspection and nondestructive test status of each wel d.

1.7.14.2.3 Required surveillance test procedures are defined in a PMI. This instruction provides for documenting bypassed tests, and for rescheduling of the test. An Assistant Plant Manager reviews the completed and signed off Weekly Surveillance Test Schedule to assure compliance.

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

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

The PMI for plant procedures requires that procedures be followed as written. Alteration to the sequence of a procedure can only be 1.7-71 July, 1985

accomplished by a procedure change which is subject to the same controls as the original review and approval.

1.7.14.2.4 Nonconforming, inoperable, or malfunctioning structures, systems and components are clearly identified by tags, stickers, stamps, etc., and documented to prevent inadvertent use.

1.7.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 1.7.15.2 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 disposi--

tioned. 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 ide'ntified as nonconforming, and any further use is controlled. Nonconformances are documented and dispositioned, and notification is made to affected organizations. Personnel authorized to disposition, conditionally release and close out nonconformances are, designated.

The Job Order System and/or the Condition Report System (refer to Section 16.0) are used at D.C. Cook Nuclear Plant to identify nonconforming items and initiate corrective action. Systems, components, or materials which require repair or inspection are controlled under the Job Order System.

In addition, the various procedures identified in Section 14 provide for identification, segregation and documentation of nonconforming items.

1.7-72 July, 1985

Nonconforming items are identified by marking, tagging, segregating, or by documented administrative controls. Documentation describes the nonconformance, the disposition of the nonconformance and the inspection requirements. It also includes signature approval of the disposition.

Completed Job Orders are reviewed by the supervisor responsible for accomplishing the work and the supervisor of the department/section that originated the Job Order. The gA Department periodically audits the Job Order System, and on a sample basis, Job Orders.

1.7. 15.2. 3 Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alterna-tives that have been documented.

Items that have the disposition of "repair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as-built condition.

When required by established procedures, 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.

1.7.16 CORRECTIVE ACTION 1.7. 16. 1 SCOPE 1.7-73 July, 1985

Conditions adverse to quality, such as failures, malfunctions, deficien-cies, 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, and corrective action is taken to preclude repetition. In these cases, the condition, cause and corrective action taken is docu-mented and reported to appropriate levels of management.

1.7. 16. 2 IMPLEMENTATION 1.7.16.2.1 Procedures are established that describe the plant and AEPSC corrective action programs. These procedures are reviewed and concurred with by the AEPSC gA Oepartment.

AEPSC accomplishes corrective action in the following manner:

- a) Audit reports which require action as a result of a corrective action request.

b) In accordance with established procedures for Condition Reports, Nonconformance Reports, Inspection Reports and Audit Reports.

c) As required by NRC Letters, I.E. Bulletins'and Inspection Reports.

d) As required by 10CFR, Part 21 identified deficiencies.

1.7.16.2.2 Condition Reports provide the mechanism for plant personnel to notify management of conditions adverse to quality. Investigations of reported conditions adverse to quality are assigned by management. The investi-gation report is used to identify the need for changes to instructions or procedures, the initiation of a design change to correct system or equipment deficiencies, or the initiation of job orders to correct minor July, 1985

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

Condition Reports are also used to report violations to codes, regulations and the Technical Specifications. Condition Reports are reviewed by the PNSRC for evaluation of actions taken to correct the deficiency and prevent recurrence.

Noncompliance Reports (NCRs) provide the mechanism for AEPSC personnel to identify noncompliances. Investigation of reported'onditions are assigned to the responsible individual. NCR investigation requires the determination of the cause of the condition and identification of immediate action and action taken to prevent recurrence.

The AEPSC Nuclear Operations Division receives copies of Condition Reports for distribution, on a selected basis, to cognizant engineering departments for review.

I The AEPSC Nuclear Safety and Design Review Committee reviews Condition Reports, NCRs, NRC Inspection Report Responses, 10CFR21, items and gA and NSDRC audits for independent evaluation of the reported conditions and corrective actions.

'he gA Department periodically audits the corrective action systems for compliance and effectiveness.

1.7. 17 (jUALITY 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.

1.7-75 July, 1985

1, 7. 17. 2 IMPLEMENTATION 1.7.17.2.1 Oocuments that furnish evidence of activities affecting quality 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) gualification of personnel, procedures and equipment.

c) Operation logs.

d) Maintenance and modification procedures and related inspection results.

e) Reportable occurrences.

'f) Records required by the plant Technical Specifications.

g) Nonconformance reports.

h) Corrective action reports.

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

1.7.17.2.2 Instructions and procedures establish the requirements for the identi-fication and preparation of records for systems and equipment under the guality Assurance Program, and provides the controls. for retention of these records.

Criteria for the storage location of quality related records and a retention schedule for these records has been established.

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

Controls have been established for limiting access to the Plant Master to prevent unauthorized entry, unauthorized removal and for use of

'ile 1.7-76 July, 1985

the records under emergency conditions. The Accounting Supervisor is responsible for the control and operation of the plant master file room.

1.7. 17.2. 3 Within AEPSC, each department/division manager is responsible for establishing procedures for the identification, collection, maintenance and storage of records generated by his department/division. These procedures shall ensure the maintenance of records sufficient to furnish objective evidence that activities affecting quality are in compliance with the established gA Program.

1.7.17.2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times. Permanent records are maintained for the life of the plant.

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 radio-graphs and some strip charts, records are stored in remote, dual facilities to prevent damage, deterioration, or loss due to natural or unnatural causes. When only the single original can be retained, special fire-rated facilities are used.

107-77 July, 1985

1.7.18 AUOITS 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 guality Assurance Program, including those elements of the program implemented by suppliers and contractors. Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are documented and are reviewed by management. Follow-up action is taken where indicated.

1.7. 18. 2 IMPLEMENTATION 1.7.18.2. 1 AEPSC A Oe artment Res onsibilities The basic responsibility for the assessment of the guality Assurance Programs is vested in the AEPSC gA Oepartment. They are.

primarily responsible for ensuring that proper gA programs are establ.ished and implemented. These responsibilities are discharged in co'operation with the AEPSC and plant'management, and their staffs.

Sto Mork Authorit - Refer to Section 1.7.1.2.4 herein.

1.7.18.2.2 Internal audits are performed in accordance with established schedules that reflect,.the status and importance of safety to the activities being performed. All areas where the requirements of 10CFR50, Appendix 8 apply are audited within a period of two years.

1.7.18.2.3 The AEPSC guality Assurance Oepartment conducts audits to verify the adequacy and implementation of the gA Program at the plant and within AEPSC. gA audit reports are distributed to the Plant Manager and PNSRC (site audits) and the NSORC (all audits).

1.7-78 July, 1985

The independent off-site review and audit organization is the AEPSC Nuclear Safety and Design Review Committee (NSDRC). This committee is composed of AEPSC, 18M and plant management members. A Charter and Procedures Manual has been developed for this committee. The NSDRC conducts periodic audits of plant operations pursuant to established criteria (Technical Specifications, etc.).

NSDRC Audit Reports are submitted for review to the Chairman of the NSDRC" and to the Vice Chairman Engineering and Construction. Corrective Action Requests provide for the recording of actions taken to correct deficiencies found during these audits.

1.7.18.2.5 The plant on-site review group is the Plant Nuclear Safety Review Committee (PNSRC). This committee reviews plant operations as a routine evaluation and serves to advise the Plant Manager on matters related to nuclear safety. The composition of the comnittee is defined in the Technical Specifications.

The PNSRC also reviews instructions and procedures for safety-related systems prior to approval by the Plant Manager. In addition, this committee serves to conduct investigations of violations to Technical Specifications, reviews Condition Reports to determine if appropriate action has been taken and reviews all design changes.

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

1.7-79 July, 1985

Principal contractors are required to audit their suppliers systematically in accordance with the foregoing scheduling criteria.

1.7.18.2.7 Regularly scheduled audits are supplemented by special audits when significant changes are made in the guality Assurance Program, when it is

~

suspected that quality is in jeopardy, or when an independent assessment of program effectiveness is considered necessary.

1.7.18.2.8 Audits include an objective evaluation of quality related practices, procedures, instructions, activities and items; and review of documents and records to confirm that the gA program is effective and properly implemented; 1.7.18.2.9 Audit procedures .and the scope, plans, checklists and results of indivi-dual 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 and to prevent recurrence.

Follow-up is performed by the auditing organization to ensure that the appropriate actions were taken. Such follow-up includes reaudits when necessary.

1.7-80 July, 1985

1.7.18.2.12 The adequacy of the guality Assurance Program is regularly assessed by AEPSC management. The following activities constitute formal elements of that assessment:

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

b) Individuals independent from the guality Assurance Organization, but knowledgeable in auditing and quality assurance, periodically review the effectiveness of the guality Assurance Programs. Conclusions and recommendations are reported to the AEPSC Vice President-Nuclear Operations.

1.7.19 FIRE PROTECTION gA PROGRAM 1.7. 19. 1 Introduction The O.C. Cook Nuclear Plant Fire Protection gA Program has been developed using the guidance of the NRC Branch Technical Position 9.5-1, Appendix II II A

This gA Program is applicable to:

1) Fire protection areas and equipment designed and/or procured after January 31, 1977 that protects safety-related items which appear in the Fire Protection Technical Specifications; and,

2) The balance of plant fire protection areas and equipment designed and/or procured after January 31, 1977.

Implementation of the Fire Protection gA Program is the responsibility of each involved AEP organization.

1.7-81 July, 1985

The QA Program for the Fire Protection Program at O.C. Cook Plant applies to,.the following activities: design, procurement, fabrication, construc-tion, operation, maintenance and modification.

1.7..2 The QA program for fire protection is under the management control of AEPSC. This control consists of:

1) Formulating and verifying that the Fire Protection QA Program incorporates suitable requirements and is acceptable to the manage-ment responsible for fire protection; and,

2) Verifying the effectiveness of the QA program for fire protection through review, surveillance and audits. The QA program for fire protection is part of the overall plant QA program. These QA cri,teria apply to those items within the scope of the Fire Protection Program, such as fire protection systems, emergency lighting, communication and emergency breathing apparatus, as well as the fire protection requirements of applicable safety-related equipment.

AEPSC and plant management has direct functional responsibility for the formulation, implementation and assessment of the O.C. Cook Fire Protec-tion Program.

The AEPSC Fire Protection Supervisor is responsible to the Manager-Plant Engineering Oivision, for aspects of the Fire Protection Program at the G.C. Cook Plant. These responsibilities provide for planning annual inspection schedules for fire and explosion hazards and training, including annual fire fighting instruction to plant personnel, fire brigades and responding fire departments.

The Fire Protection/HVAC Section Manager and the Fire Protection Engineer have coordinated the building layout, the fire suppression and fire detection systems, commensurate wi,th fire areas within the plant. They 1.7-82 July, 1985

have established the design of the overall fire detection/ suppression system and the incremental parts of the system. Maintenance information has been provided to the plant in the form of system descriptions and equipment supplier instruction material.

The Plant Manager has delegated responsibility to various plant depart-ments for the following fire protection activities:

a) Maintenance of fire protection system, b) Testing of fire protection equipment, c) Fire safety inspections, d) Fire fighting procedures, and e) Fire drills.

The Shift Supervisor on duty is designated as the Fire Chief and coordi-nates the fire fighting efforts of shift personnel and the fire brigade.

1.7.19.3 Desi n Control and Procurement Document Control guality standards are specified in the design documents such as appropri-ate fire protection codes and standards, and deviations and changes from these quality standards are controlled.

The plant design was reviewed by qualified personnel to assure inclusion of appropriate fire protection requirements. These reviews include items such as:

1) Reviews to verify adequacy of wiring isolation and cable separation criteria.

2) Reviews to verify appropriate requirements for room isolation (sealing penetrations, floors and other fire barriers).

3) Reviews to determine increase in fire loadings.

1.7-83 July, 1985

4) Reviews to determine the need for additional fire detection and suppression equipment.

A review and concurrence of the adequacy of fire protection requirements and quality requirements stated in procurement documents is performed.

This review determines that fire protection requirements and quality requirements are correctly stated, verifiable and. controllable; there are adequate acceptance and rejection criteria; and the procurement document has'been prepared, reviewed and approved in accordance with gA program requirements.

Design and procurement document changes, including field changes and design deviations are subject to the same -level of controls, reviews and approvals that were applicable to the original document.

1.7.19.4 Instructions Procedures and Orawin s Inspections, tests, administrative controls, fire drills and training that govern the fire Protection Program are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these documents.

Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with documented procedures.

Activities of the fire protection system are prescribed and accomplished in accordance with documented instructions, procedures and drawings.

Instructions and procedures for design installation, inspection, test, maintenance, modification and administrative controls are reviewed to assure that proper fire protection requirements are included.

1.7. 19.5 Control of Purchased Material, E ui ment and Services Measures are established to assure that purchased material, equipment and services conform to the procurement documents. These measures include I;7-84 July, 1985

provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspections at suppliers, or receiving inspections.

I Source or receiving inspection is provided, as a minimum, for those items whose quality cannot be verified after installation.

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

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

The inspections include:

a) Inspection of: I) installation, maintenance and modification of fire protection systems; and, 2) emergency lighting and communication equipment.

b) Inspections of penetration seals and fire retardant coating instal-lations to verify the activity is satisfactorily completed.

c) Inspections of cable routing to verify conformance with design requirements.

d) Inspections to verify that appropriate requirements for room isolation are accomplished following construction or modification 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.

1.7-85 July, 1985

f) Inspection procedures, instructions and/or check lists are provided for inspections.

g) Periodic inspections of fire protection systems, emergency breathing and auxiliary equipment, emergency lighting and communication equipment.

h) Periodic inspections of materials subject to degradation such as fire stops, seals and fire retardant coating.

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, emergency lighting and communication equipment will perform satisfactorily. Written test procedures for installation tests'incorporate the requirements and acceptance limits contained in applicable design documents.

b) Periodic testing - Periodic testing schedules and methods have been implemented and the results documented. Fire protection equipment, emergency lighting and communication equipment are tested periodi-cally to assure that the equipment functions properly.

c) Programs have been established to verify the testing of fire protec-tion systems and to verify that test personnel are effectively trained.

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

1.7.19:8 Ins ection Test and 0 eratin Status The inspection, test and operating status for the Fire Protection System are performed as described in Section 1.7. 14.

1.7-86 July, 1985

1.7.19.9 Nonconformin I tems Nonconforming items for the fire protection components are identified and dispositioned as described in Section 1.7. 15.

1.7.19.10 Corrective Action The corrective action mechanism described in Section 1.7.16 applies to the fire protection system.

1.7.19.11 Records Records generated to support the fire protection system and its components are controlled as described in Section 1.7. 17.

1.7.19.12 Audits Audits are conducted and documented to verify compliance with the Fire Protection Program as described in Section 1.7. 18.

s Audits are periodically performed to verify compliance with the adminis-trative controls and implementation of quality assurance criteria. The audits are performed in accordance with preestablished written procedures or check lists. Audit results are documented and reviewed by management having responsibility in the area audited. Follow-up action is taken by responsible management to correct the deficiencies revealed by the audit.

1.7-87 July, 1985

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~ ~ ~ ~ ~

FUNCTIONAL DIRECTION FOR COOK PLANT ACTIVITIES hl CIKIH NOTES:(I) NOT PART OF AEPSC MANA( IHS ORGANIZATION.SHOWN FOR INFORMATION ONLY.

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COOK NUCLEAA L J GENERATING SUBSIDIARY PLANT (1) JOINTLY OWNED WITH BUCKEYE POWER, INC.

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Figure 1.7-3 CHAIRMANOF THK KOARO ANO CHIEF EXKCUTIVEOFFICEA AEPSC INOIANA4 MICHIGAN ELKCTAIC CO.

ANO OTHEA AEP SUESIOIAAIES VICE CHAIAMAN ENGINE ERINQ VICE PAESIOENT ANO ANO INOIANAA MICHIGAN CONSTRUCTION ELECTRIC COMPANY AEPSC VIC'E PAESIOENT VICE PAESIOENT NUCLEAA ANO INOIANA4 MICHIQAN ~ 0 ~ ~ 0 ~ 00 ~ 0 ~ 0 ~ 00 ~ 0 ~ 0 ~ 0 ~ 0 ~ 0 ~0 ~0 ~0~ 00 OPEAATIONS ELECTAIC COMPANY MANAQEAOF NUCLEAR OPERATIONS EXECUTIVE VICE PAESIOENT

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~ ~ ~ FUNCTIONAL OIRECTION OQNALO C. COOK NUCLEAR PLANT I 1.7-90 Ju1y, 1985

QA ORGANIZATION AEPSC MANAGEA OF QA TRAINING &

PROCEDUAES QA STAFF SPECIALIST SPECIALIST SECRETARIAL AND CLEAICAL STAFF SECTION MANAGER SUPERVISOR AUDITS & SECTION MANAGER QA ENGINEERING QA PROCUREMENT (SITE)

ENGINEEAS ENGINEERING ENGINEEAING TECHNICIAN ENGINEERS AUDITOAS SECRETARIES TECHNICIANS AUDITORS AESEARCH ASSISTANT

ADMINISIRATIVE RESPONSIUILITV Pt ANl --"tUNCTIONAL RESPONSIBILI I V MANAGEH I

I I

I ASSISIANI ASSISTANT I PIANI MANAGLH PL ANl MANAGER I MAINIENANCE OPERATIONS (SRO3 I

I MAINltMANI.'I. PL ANNING OUALIIV I LC II NICAEA I E CHN ICAL ADMINISIHAIIVE OPEHAIIONS

~UPLHINILNDENI LUPI NIHILNDENI CUN I IIOL SUPEHINIENDENI 'UPERINIENDt Nl SUPERINTENDENI SUPERINfENDENI SUPLHINIENDENI ENGINEERING PHYSICAL SCIENCE INOIANA & HICHIGAN ELECTRIC COMPANY ORGANIZATION FOR THE DONALD C. COOK NUCLEAR PLANT

~ APPENOIX 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) guality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment ANSI N45.2.4 (1972) Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construc-,

tion of Nuclear Power Generating Stations

5. Safety Guide 33, guality Assurance Program Requirements Appendix A (ll/72) (Operation)

ANSI N18-7 (1976) Administrative Controls and guality (ANS 3.2 1976) Assurance for the Operational Phase of Nuclear Power Plants ANSI N45.2 (1977) guality Assurance Program Requirements for Nuclear Facilities

6. Reg. Guide 1.37 (3/73) guality 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 Construc-tion Phase of Nuclear Power Plants 1.7.A-93 July, 1985

L APPENDIX A

7. Reg. Guide 1.38 (10/76) guality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants ANSI N 45.2.2 (1972) Packaging, Shipping, Receiving, Storage and Handling of Items for, Nuclear Power Plants (During the Construction Phase)

8. Reg. Guide 1.39 (10/76) Housekeeping 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) guality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants ANSI N101.4 (1972) guality Assurance for Protective Coatings Applied to Nuclear Facilities

10. Reg. Guide 1.58 (9/80) gualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel ANSI N45.2.6 (1978) gualifications of Inspection, Exami-nation, and Testing Personnel for Nuclear Power Plants

11. Reg. Guide 1.63 (7/78) Electric Penetration Assemblies in Containment Structures for Light-Water-Cooled Nuclear Power Plants

12. Reg. Guide 1.64 (10/73) guality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11 (1974) guality Assurance Requirements for the Design of Nuclear Power Plants 1.7.A-94 July; 1985'.

~ APPENOIX A

13. Reg. Guide 1.74 (2/74) (}uality Assurance Terms and Definitions ANSI N45.2.10 (1973) guality Assurance Terms and Definitions h

14. Reg. Guide 1.88 (10/76) Collection, Storage, and Maintenance of Nuclear Power Plant equality Assurance Records ANSI N45.2.9 (1974) Requirements for Collection, Storage, and Maintenance of guality Assurance Records for Nuclear Power Plants

15. Reg. Guide 1;94 (4/76) guality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N45.2.5 (1974) Supplementary guality Assurance Requirements for Installation, Inspection, and Testing of Strucutral Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants

16. Reg. Guide 1.108 (8/77) Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants

17. Reg. Guide 1.123 (7/77) equal ity Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants ANSI N45.2.13 (1976) (}uality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 1.7.A-95 July, 1985

APPENDIX A equal 18, Reg. Guide 1.144 (1/79) Audi ting, of i ty: Assurance, Programs for Nuclear Power Plants ANSI N45.2.12 (1977) Requiremens for Auditing of gual i ty Assurance Programs for Nuclear Power Plants

19. Reg. Guide 1.146 (8/80) gualification of guality Assurance Program Audit Personnel for Nuclear Power Plants

., ANS I N45.2. 23 ( 1978) gualification of guality Assurance Program Audit Personnel for Nuclear Power Plants

20. ANSI N45.2.8 (1975) Supplementary guality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construc-tion Phase of Nuclear Power Plants 1

21. ANSI N45.4 (1972) Leakage-Rate Testing of Containment Structures for Nuclear Reactors

22. ANSI N510 (1975) Testing of Nuclear Air-Cleaning Systems 1.7.A-96 July, 1985

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

1. GENERAL Re uirement 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.

Exce tion/Inter retation The AEPSC/IEMECo 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 Exce tion/Inter retation AEPSC and ISMECo have established both an on-site and off-site standing committee for independent review activities. Together they form the independent review body.

The standard numeric and qualification requirement may not be met by each group individually. Procedures will be established to specify how each group will be involved in review activities. This exception/interpreta-tion is consistent with the plant's Technical Specifications.

1.7.B-97 July, 1985

APPENDIX B 2a. Sec. 4.3.1 Re uirement "Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas: . . . ."

Exce tion/Inter retation AEPSC Nuclear Safety and Design Review Committee (NSDRC) and Plant Nuclear Safety Review Committee (PNSRC) will not have members specified by number nor by technical disciplines, and its members may not have the.

experience and competence required to review problems in all areas listed in this section. This exception/interpretation is consistent with the plant's Technical Specifications.

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

2b. Sec. 4.3.2.1 Re uirement "When a standing committee is responsible for the independent review program, it shall be composed of no less than five persons of whom no more than a minority are members of the on-site operating organization.

Competent alternatives are permitted if designated in advance. The use of alternates shall be restricted to legitimate absences of principals."

Exce tion/Inter retation See Item 2a.

1.7.8-98 July, 1985

APPENDIX 8 2c. Sec. 4.3.3.1 Re uirement

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

Exce tion/Inter retation Recommendations made as a result of review will generally be conveyed to the on-site or off-site standing committee. Procedures will be maintained specifying how recommendations are to be considered.

2d. Sec. 4.3.4 Re uirement "The following subjects shall be reviewed by the independent review body o ~ ~ ~ ~

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

2e. Sec. 4.3.4(3)

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

1.7.8-99 July, 1985

APPENDIX B Exce tion/Inter retation The NSDRC and PNSRC will not review Technical Specification changes after NRC approval prior to implementation. The basis for this position is the NSDRC and PNSRC review Technical Specification changes prior to submittal to the NRC.

2f. Sec. 4.4 Re uirement "The on-site operating organization shall provide, as part of the normal duties of plant supervisory personnel Exce tion Inter retation Some of the responsibilities of the on-site operating organization described in Section 4.4 may be carried out by the PNSRC and/or NSDRC as described in plant Technical Specifications.

2g. Sec. 5.2.2 Re uirement "Temporary changes, which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operator's license on the unit affected."

Exce tion/Inter retation I5t1ECo considers that this requirement applies only to procedures identi-fied in plant Technical Specifications. Temporary changes to these procedures shall be approved as described in plant Technical Specifications.

I.7. B-100 July, 1985

APPENDIX B 2h. Sec. 5.2.6 Re uirement "In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2. 14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions."

Exce tion/Inter retation I

IENECo 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.

2i. Sec. 5.2.8 Re uirement "A surveillance testing and inspection program . . . shall include the establishment of a master surveillance schedule reflecting the status of all planned in-plant surveillances tests and inspections."

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

1.7.8-101 July, 1985

APPENDIX 8 2j. Sec. 5.2.13.1 Re uirement "To the extent necessary, procurement documents shal-1 require suppliers to provide a guality Assurance Program consistent with the pertinent requirements of ANSI N45.2 - 1971."

Exce tion/Inter retation To the extent necessary, procurement documents require that the supplier has a documented guality Assurance Program consistent with the pertinent requirements of 10CFR50, Appendix 8; ANSI N45.2; or other nationally recognized codes and standards.

2k. Sec. 5.2. 13. 2 Reauirement ANSI N18.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

Exce tion/Inter retation The required documentary evidence is available at the site prior to use, but not necessarily prior to installation. This allows installation to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

1.7.8-102 July, 1985

~ APPENOIX 8

21. Sec. 5.2.16 Re uirement Records shall be made and equipment suitably marked to indicate calibration status.

Exce tion/Inter retation See Item 6b.

2m. Sec. 5.3.5(4)

Re uirement This section requires that where sections of documents such as vendor manuals, operating and maintenance instructions or drawings are incor-porated directly or by reference into a maintenance procedure, they shall receive the same level of review and approval as operating procedures.

Exce tion/Inter retation Such documents are reviewed by appropriately qualified personnel prior to use to ensure that, when used as instructions, they provide proper and adequate information to ensure the required quality of work. Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures.

3. N45.2.1, 3a. Sec. 2 Re uirement N45.2. 1 establishes criteria for classifying items into "cleanness levels", and requires that items be so classified.

1.7.8-103 July, 1985

APPENDIX 8 Exce tion/Inter retation 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 Re uirement "Fitting. and tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed."

Exce tion/Inter retation IQIECo sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection.

4. N45.2.2, General Re uirement N45.2.2 establishes requirements and criteria for classifying safety related items into protection levels.

Exce tion/Inter retation Instead of classifying safety related items into protection levels, controls over the packaging, shipping, handling and storage of such items 1.7.B-104 July, 1985

APPENOIX 8 are established on a case-by-case basis with due regard for the item's complexity, use and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

4a. Sec. 3.9 and Appendix A3.9 "The item and the outside of containers shall be marked."

(Further criteria for marking and tagging are given in the Appendix.)

Exce tion/Inter retation These requirements were originally written for items packaged and shipped to construction projects. Full compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, increase the probability of damage to the item. The requirements are implemented .'to the extent necessary to assure traceability and integrity of the item.

4b. Sec. 5.2.2 Re uirement "Receiving inspections shall be performed in an area equivalent to the level of storage."

Exce tion/Inter retation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item. However, such inspections are performed in a manner and in an environment which do not endanger the required quality of the item.

1.7.8-105 July, 1985

APPENDIX B 4c. Sec. 6.2.4 Re uirement "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted."

Exce tion/Inter retation Packaged food for emergency or extended overtime use may be stored in material stock rooms. The packaging assures that materials are not contaminated. Food will not be "used" in these areas.

4d. Sec. 6.3.4 Re uirement "A11 items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."

Exce tion/Inter retation See N45.2.2, Section 3.9 (Exception 4b.).

4e. Sec. 6.4.1 Re uirement "Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its container

. is being maintained."

1.7.B-106 July, 1985

APPENDIX 8 Exce tion Inter retation The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule. Instead, the inspections and examinations are performed in accordance with material storage procedures which identify the characteristics to be inspected an include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.

5. N45.2.3, 5a., Sec. 2.1 Re uirement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.

Exce tion/Inter retation Instead of the five-level zone designation system referenced in ANSI N45.2.3, ISMECo bases its controls over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions.

Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

However, in preparing these procedures, consideration is also given to the recommendations of Section 2. 1 of ANSI N45.2.3.

6. N45.2.4, 6a. Sec. 2.2 1.7.8-107 July 1985

APPENOIX B Re uirement 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 qualifi-cation, control of design, conforming and protected materials and availability of specified documents.

Exce tion Inter retation Ouri'ng the operations phase, this requirement is considered to be appli-cable to modifications and initial start-up of electrical equipment. For routine or periodic inspection and testing, the prerequisite conditions will be achieved as necessary.

6b. Sec. 6.2.1 Re uirement "Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed calibration."

Exce tion/Inter retation Frequently, physical size and/or location of installed plant instrumenta-tion precludes attachment'f 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.

1.7. B-108 July, 1985

APPENDIX B 7.

7a. Sec. 2.5.2 Re uirement "When discrepancies, malfunctions or 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 author-ity and appropriate action taken.

Exce tion/Inter retation IKMECo 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 Re uirement "Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more often if deemed necessary. Impact torque wrenches used for inspection must be calibrated at least twice daily."

Exce tion/Inter retation Torque wrenches are controlled as measuring and test equipment in accor-dance with ANSI N18.7, Section 5.2. 16. Calibration intervals are based on use and calibration history rather than as per N45.2.5.

1.7. 8-109 July, 1985

APPENDIX 8

6. N65.2.6, Sec. 1.2 Re uirement "The requirements of this standard apply to personnel who perform inspec-tions, examinations and tests during fabrication prior to or during receipt of items at the construction site, during construction, during preoperational and start-up testing and during operational phases of nuclear power plants."

Exce tion/Inter retation Personnel participating in testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 but need only be trained to the extent necessary to perform the assigned function.

9. Re . Guide 1.58 - General Re uirement gualification of nuclear power plant inspection, examination and testing personnel.

9a. C.2.6 Re uirement Regulatory Guide 1.58 endorses the guidelines of SNT-TC-1A as an accep-table method of training and certifying personnel conducting leak tests.

Exce tion/Inter retation ISMECo takes the position that the "Level" designation guidelines as recommended in SNT-TC-lA, paragraph 4 do not necessarily assure adequate C

leak test capability. ISMECo maintains that departmental supervisors are 1.7.8-110 Ju.ly, 1985

0 APPENDIX B best able to judge whether engineers and other personnel are qualified to direct and/or perform leak tests. Therefore, IEMECo does not implement the recommended "Level" designation guidelines.

It is I&MECo's opinion that the training guidelines of SNT-TC-1A ( 1975),

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. ISMECo maintains that it meets the essence of these training guidelines. The preparation of leak test procedures and the conduct of leak tests at Cook Plant is under the direct supervisor of Performance Engineers who hold engineering degrees from accredited engineering schools. The basic physics of leak testing have been incorporated into the applicable test procedures. The review and approval of the data obtained from leak tests is performed by department supervisors who are also graduate engineers.

IEMECo does recognize the need to assure that individuals involved in leak tests are fully cognizant of leak test procedural requirements and thoroughly familiar with the test equipment involved. Plant performance engineers receive routing, informal orientation on testing programs, to ensure that these individuals fully understand the requirements of performing a leak test.

9b. C5, C6, C7, C8, C10 Exce tion/Inter retation ISMECo takes the position that the classification of inspection, exami-nation and test personnel (inspection personnel) into "Levels" based on the requirements stated in Section 3.0 of ANSI N45.2.6 does not necessarily assure adequate inspection capability. ISMECo maintains that departmental and first line supervisors are best able to judge the inspection capability of the personnel under their supervision, and that "level" classification would require an overly burdensome administrative work load, could inhibit inspection activities and provides no assurance of inspection capabilities. Therefore, IKMECo does not implement the 1.7.8-111 July, 1985

APPENDIX B "level classification" concept for inspection, examination and test personnel.

The methodology under which inspections, examinations and tests are conducted at the Donald C. Cook Nuclear Plant requires the involvement of first line supervisors, engineering personnel, departmental supervisors and plant management. In essence, the last seven (7) project functions shown in Table 1 to ANSI N45.2.6 are assigned to supervisory and engineering personnel and not to personnel of the inspector category.

These management supervisory and engineering personnel, as a minimum, meet the educational and experience requirements of "Level II and Level III"personnel, as required, to meet the criteria of ANSI 18. 1 which exceeds those of ANSI N45.2.6. In I&MECo's opinion, no useful purpose is served by classification of management, supervisory and engineering personnel into "Levels."

t Therefore, IKMECo takes the following positions relative to regulatory posi,tions C5, 6, 7, 8 and 10 of Regulatory Guide 1.58.

C-5 Based on the discussion in B. 1 above, this position is not applicable to the Donald C. Cook Nuclear Plant.

C-6 Replacement personnel for Donald C. Cook Nuclear 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 N45.2.6.

Replacement inspection personnel will, as a minimum, meet the educational and experience requirements of ANSI N45.2.6, Section 3.5.1 - "Level I".

C-7 ISMECo, as a general practice, complies with the training recommen-dations as set forth in this regulatory position.

1.7. B-112 July, 1985

APPENDIX 8 C-8 All 18MECo inspection, examination and test personnel are instructed in the normal course of employee training in radiation protection and the means to minimize radiation dose exposure.

C-10 18MECo maintains documentation to show that inspection personnel meet the minimum requirements of "Level I" and that management, supervisory and engineering personnel meet the minimum requirements of ANSI 18.1.

10. General Imposition of these Regulatory Guides on AEPSC/IEMECo suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured.

11. N45.2.8, lla. Sec. 2.9e Re uirement Section 2.9e of N45.2.8 lists documents relating to the specific stage of installation activity which are to be available at the construction site.

Exce tion/Inter retation All of the documents listed are not necessarily required at the construc-tion site for installation and testing. AEPSC and ISMECo assure that they are available to the site as necessary.

1.7.8-113 July, 1985

APPENDIX 8 11b. Sec. 2.9e Re uirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.

Exce tion/Inter retation "Equipment may be installed before final approval of engineering or design changes. However, the system is not placed into service until such changes are documented and approved.

llc. Sec. 4.5.1 Re uirement "Installed systems and components shall be cleaned, flushed and condi-tioned according to the requirements of ANSI N45.2. 1. Special considera-tion shall be given to the following requirements: . .

(Requirements are given for chemical conditioning, flushing and process controls.)

Exce tion/Inter retation Systems and components are cleaned, flushed and conditioned as determined on a case-by-case basis. Measures are taken to help preclude the need for cleaning, flushing and conditioning through good practices during maintenance or modification activities.

1.7.8-114 July, 1985

0 APPENDIX 8

12. N45.2.9 12a. Sec. 5.4, Item 2 Re uirement Records shal) not be stored loosely. "They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers." Steel file cabinets are preferred.

Exce tion/Inter retation Records are suitably stored in steel file cabinets or on shelving in containers. Methods other than binders, folders, or envelopes (for example, dividers) may be used to organize the records for storage.

12b. Sec. 6.2 Re uirement "A list shall be maintained designating those personnel who shall have access to the files".

Exce tion/Inter retation Rules are. established governing access to and control of files as pro-vided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms may exist for general use.

1.7. B-115 July, 1985

APPENOIX B 12c. Sec. 5.6 Re uirement When a single records storage facility is maintained, at least the following features should be considered in its construction: etc.

Exce tion/Inter retation The Oonald C. Cook Nuclear Plant Master File Room complies with the requirements of NUREG-0800 (7/81), Section 17. 1. 17.4.

13. Re . Guide 1.144, 13a. Sec C3a(2)

Re uirement Applicable elements of an organization's guality Assurance Program for "design and construction phase activities should be audited at least annually or at least once within the life of the activi ty, whichever is shorter."

Exce tion/Inter retation Since most modifications are straight forward, they are not audited individually. Instead, selected controls over modifications are audited periodically.

13b. Sec. C3b(1)

Re uirement This section identifies procurement contracts which are exempted from being audited.

1.7.B-116 July, 1985

(~

APPENDIX 8 Exce tion Inter retation In addition to the exemptions of Reg. Guide 1.144, AEPSC/IENECo considers that the National Bureau of Standards or other State and Federal Agencies which may provide services to AEPSC/18MECo are not required to be audited.

14., N45.2. 13, 14a. Sec. 3.2. 2 uirement

~b'i Re N45.2. 13 requires that technical requirements be specified in procurement 1 qi 4 . T requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2. 11.

Exce tion/Inter retation For replacement parts and materials, AEPSC/ISNECo follow ANSI N18.7, Section 5.2. 13, Subitem 1, which states: "Where the original item or part is found to be commercially 'off the shelf'r without specifically identified gA requirements, spare and replacement parts may be similarly procured; but care shall be exercised to ensure at least equivalent performance."

14b. Sec. 3.3.2 Re uirement "Procurement documents shall require that the supplier have a documented guality Assurance Program that implements parts or all of ANSI N45.2 as well as applicable guality Assurance Program requirements of other nationally recognized codes and standards."

1.7. B-117 July, 1985

APPENDIX B Exce tion/Inter retation Refer to Item 2j.

14c. Sec. 3.3(a)

Re uirement Reviews of procurement documents shall be performed prior to release for bid and contract award.

Exce tion/Inter retation Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is put into service, or before work has progressed beyond the point where it would be impractical to reverse the action taken:

14d. Sec. 3.3(b)

Re uirement Review of changes to procurement documents shall be performed prior to release for bid 'and contract award.

Exce tion/Inter retation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified in ANSI N18.7, Section 5.2. 13. 1, Subitems 1 through 5). The timing of reviews will be the same as for review of the original procurement documents.

1.7.8-118 July, 1985

APPENDIX B 14e. Sec. 10.1 Re uirement "Where required by code, regulation, or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods."

Exce tion/Inter retation Refer to Item 2j.

Re uirement "Post-instal lation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."

Exce tion/Inter retation In exercising its ultimate responsibility for its guality Assurance Program, AEPSC/ISMECo establishes post-installation test requirements giving due consideration to supplier recommendations.

15. RG 1.58/ANSI N45.2.23 and ANSI N45.2.2.12 15a. ANSI N45.2.23, Sec. 1.1 Re uirement This standard provides requirements and guidance for the qualification of audit team leaders, henceforth identified as "Lead Auditors".

1.7. B-119 July, 1985

ENDIX B 15b. ANSI N45.2.12, Sec. 4.2.2 Re uirement A Lead Auditor shall be appointed team leader.

Exce tion/Inter retation The AEPSC audit program is directed by the AEPSC Manager of gA who is a qualified lead auditor; and is administered by designated gA Department, Section Managers who are also qualified lead auditors.

Audits are, in most cases, conducted 'by individual auditors, not by "audit teams". These auditors are qualified by established procedures and are assigned by the responsible gA Section Manager 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 4EPSC audit procedures require that, in all cases, the audit functions of preparation/organization, reporting of audit findings and evaluation of corrective actions be reviewed by gA Department Section Managers, thereby meeting the requirements of ANSI N45.2.23 relative to "Lead Auditors", and "Audit Team Leaders".

1.7. B-120 July, 1985