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{{#Wiki_filter:INDIANA 5 HlCHlGAN ELECTRiC COMPANY P O. BOX 18 BOWLlHG GR E EH ST AT1OH NEW YORK, N. Y. 10004 8une 15,'978 Indiana   a Mich'n lectric           Co.
{{#Wiki_filter:INDIANA 5 HlCHlGAN ELECTRiC COMPANY P
and Indiana   & Mi higan P wer Co.
O. BOX 18 BOWLlHG GR E EH ST AT1OH NEW YORK, N. Y. 10004 8une 15,'978 Indiana a Mich'n lectric Co.
Donald C. Co k Nucle         Plant, Units 1 and 2 (Docket Nos. 50-315     d 50-316)
and Indiana
  ., Dr; Ernst Volgenau
& Mi higan P wer Co.
. Director Office of Inspection       and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Donald C.
Co k Nucle Plant, Units 1 and 2
(Docket Nos.
50-315 d 50-316)
., Dr; Ernst Volgenau
. Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555


==Dear Dr. Volgenau:==
==Dear Dr. Volgenau:==
CD This is in reply to your letter of May 30, 1978~anI its three appendices referring to the results of an mRCc investigation conducted during December, 1977 and JaLa~,
CD This is in reply to your letter of May 30, 1978~anI its three appendices referring to the results of an mRCc investigation conducted during December, 1977 and JaLa~,
1978, into the testing of electrical cables, conne+Ws~nd penetrations at the Donald C. Cook Nuclear: Plant, UaYt Nos. 1-..
1978, into the testing of electrical cables, conne+Ws~nd penetrations at the Donald C. Cook Nuclear: Plant, UaYt Nos. 1-..
and 2. No response to Appendix C of your letter is tt.eqiKLred.
and 2.
In response to Appendix B, enclosed herewith is a checkgn
No response to Appendix C of your letter is tt.eqiKLred.
'o Appendix the amount of Ten Thousand Dollars ($ 10,000.00). Oug response --'.
In response to Appendix B, enclosed herewith is a checkgn the amount of Ten Thousand Dollars
A follows..                                   r With respect to the subject matter of the'irst allegation which related to electrical penetrations, our statement in the. October, 1977 PSAR amendment that the penetrations had been tested "to the requirements of IEEE 323, Appendix A, Combined requirements of Tables Al and A2" was a
($10,000.00).
  . mistake. It resulted from a misunderstanding during a tele-phone conversation between a member of our electrical engineerinc division and an employee of the test. laboratories of Conax Corporation. =This misunderstanding was incorporated into a draft of our amendment submittal. Unfortunately           it discovered in the course of the review of that draft prior to was not its finalization within AEP           and its submittal to NRC. The second   allegation in Appendix A related to the testing of instrument cable. Here too the draft of our October, 1977 submittal was prepared based on the results of t'esting (whi h, ply, H 782430137
Oug response
'o Appendix A follows..
r With respect to the subject matter of the'irst allegation which related to electrical penetrations, our statement in the. October, 1977 PSAR amendment that the penetrations had been tested "to the requirements of IEEE 323, Appendix A, Combined requirements of Tables Al and A2" was a
. mistake.
It resulted from a misunderstanding during a tele-phone conversation between a member of our electrical engineerinc division and an employee of the test. laboratories of Conax Corporation.
=This misunderstanding was incorporated into a draft of our amendment submittal.
Unfortunately it was not discovered in the course of the review of that draft prior to its finalization within AEP and its submittal to NRC.
The second allegation in Appendix A related to the testing of instrument cable.
Here too the draft of our October, 1977 submittal was prepared based on the results of t'esting (whi h, ply, H 782430137


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Dr. Ernst Volgenau Page 2
Dr. Ernst Volgenau Page 2
                                    's.NRC correctly observes, involved in one. instance testing of cable materials versus. the as-installed cable itself, and in another instance testing of 12-.gauge control-size single conductor cable versus the as-installed 16-gauge quad configured instrument cable itself). and was not determined, .during the review of, that draft prior to its finalization within AEP and
~
          .I
P
                                ..',-'its submittal to NRC, to be an inappropriate or incorrect
.I I
>>                  ,:-.'","-.>=". description of our test data.           Thus we do not. deny these I
L
The events alleged did occur.                  two'llegations.
's.NRC correctly observes, involved in one. instance testing of cable materials versus. the as-installed cable itself, and in another instance testing of 12-.gauge control-size single conductor cable versus the as-installed 16-gauge quad configured instrument cable itself). and was not determined,.during the review of, that draft prior to its finalization within AEP and
As we discussed, during our meeting on April 12, 1978, our m*anagement,at the highest levels of AEP and, I&M Electric,
..',-'its submittal to NRC, to be an inappropriate or incorrect
* and, IaM Power,has involved, itself directly to ensure that future submittals to NRC are completely accurate and sufficientl
,:-.'","-.>=". description of our test data.
                                    'etailed.
Thus we do not. deny these two'llegations.
                              '. New York andToatthis        end, I personally have met at. our offices in the Cook Plant, with our cognizant, engineers who have the responsibility to draft documents for submittal to NRC. They understand. the importance of the information we provide to NRC and the need. for unerring accuracy.         Further,.
The events alleged did occur.
                                    .we have formally instituted, upon our new quality assurance                       .
As we discussed, during our meeting on April 12, 1978, our m*anagement,at the highest levels of AEP and, I&M Electric, and, IaM Power,has involved, itself directly to ensure that future submittals to NRC are completely accurate and sufficientl
L                          manager's recommendation, a change in our procedures to directly 'involve quality assurance personnel in the review of materials proposed for submittal to NRC. Thus, in addition to the technical and administrative. review formerly- given drafts of submittals to NRC, under the modification an additiona
'etailed.
                                . 'independent check of all such drafts by quality assurance, personnel will be performed. A copy .of our new procedure is enclosed for your 'information.. Finally, we are undertaking a program for computerization of our commitments to NRC.
To this end, I personally have met at. our offices in New York and at the Cook Plant, with our cognizant, engineers who have the responsibility to draft documents for submittal to NRC.
                                          ..While we are proud of the excellent record         have establis in connection with. the design, construction and we    operation of the Donald C. Cook nuclear units, we appreciate the importance of complete accuracy and sufficient detail in all our submittals of .technical information to NRC. While we are disappointed events discussed         ever transpired, .we are dedicated to that'he
They understand. the importance of the information we provide to NRC and the need. for unerring accuracy.
                              -~'aking them a trigger above      to ever better performance on our part.
Further,.
.we have formally instituted, upon our new quality assurance manager's recommendation, a change in our procedures to directly 'involve quality assurance personnel in the review of materials proposed for submittal to NRC.
Thus, in addition to the technical and administrative. review formerly-given drafts of submittals to NRC, under the modification an additiona
. 'independent check of all such drafts by quality assurance, personnel will be performed.
A copy.of our new procedure is enclosed for your 'information.. Finally, we are undertaking a
,, program for computerization of our commitments to NRC.
..While we are proud of the excellent record we have establis in connection with. the design, construction and operation of the Donald C. Cook nuclear units, we appreciate the importance of complete accuracy and sufficient detail in all our submittals of.technical information to NRC.
While we are disappointed that'he events discussed above ever transpired,
.we are dedicated to
-~'aking them a trigger to ever better performance on our part.
We assure you there will be no recurrence of such events.
We assure you there will be no recurrence of such events.
I Very truly yours, Indiana 6 Michigan"Electric                       C g  SZ ice President JT p enc.. 2 cc: Mr. J.
I Very truly yours, Indiana 6 Michigan"Electric C
enc. 1 Q. Keppler,   USNRC Region III
JT p enc.. 2 g
SZ ice President cc: Mr. J.
Q. Keppler, USNRC Region III enc.
1


                                                                    ~q)+AN Kl Pg )
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AMERICAH ELECTRIC POWER SERVICE CORPORATIOH OLVEA SVSTE Divi.sion         Procedure No. 32-pre aration of Organization and Procedures Manual            Submittals to the U.S. Nuclea!
AMERICAH ELECTRIC POWER SERVICE CORPORATIOH OLVEA SVSTE Divi.sion Organization and Procedures Manual Section Procedure No.
Section            Re ulato     'Commission REVISION RECORD Issue Revision    Date                 Affected Pages                Approved By 0      6/1/78     Initial Issue                           John Tillinghas
32-pre aration of Submittals to the U.S. Nuclea!
Re ulato
'Commission REVISION RECORD Revision 0
Issue Date 6/1/78 Affected Pages Initial Issue Approved By John Tillinghas


AEPSC GENERAL PROCEDURE NO. 32 PBEPABATXON OF SUBMXTTAL TO THE
AEPSC GENERAL PROCEDURE NO.
                                                                          ~ .P U. S - NUCLEAR REGULATORY COMNXSSXON XNXTXAL XSSUE BEUXSXON 0 Prepared By-                                           Date: 5  I 8 78
32 PBEPABATXON OF SUBMXTTAL TO THE U.
              . AEP C   anager   f QA Reviewed By:                               7           Date:,
S -
Head, AE   S Nuclea     a ety &
NUCLEAR REGULATORY COMNXSSXON
Licensing Section Date:
~.P XNXTXAL XSSUE BEUXSXON 0 Prepared By-
ief Nu   ar   gineer Senz.or Vz,ce Pres~dent,   Construction Sen'xecutive       Vice Pres@dent, Engi   ering Approved Bv.:                                          Date:
. AEP C
ha   an, Engin e     ng and C nstruction AEPSC General Procedure No 32 Rev. 0   Date JUg 0 ]   '197I
anager f QA Date: 5 I8 78 Reviewed By:
7
: Head, AE S
Nuclea a ety Licensing Section Date:,
ief Nu ar gineer Date:
Senz.or Vz,ce Pres~dent, Construction Sen'xecutive Vice Pres@dent, Engi ering Approved Bv.:
ha an, Engin e
ng and C nstruction Date:
AEPSC General Procedure No 32 Rev.
0 Date JUg 0 ] '197I


t U AEPSC GENERAL PROCEDU PREPARATION OF SUBiMXTTA NO  32 TO THE S- NUCLEAR REGULATORY COISiXSSXON Table of Contents SECTION                                                         PAGE NO.
t AEPSC GENERAL PROCEDU NO 32 PREPARATION OF SUBiMXTTA TO THE U
1.00     Purpose 2.00     Policy 3.00     Exceptions to Procedure 4.00    Submittal Preparation Procedure 4.01 Genera1 4.02 Verbal Commitments to the     NRC 4.03 Draft Submittal Preparation Assignment 4.04 Draft Submittal Preparation 4.05 Supervisory Review and Approval 4.06 Site Originated Draft Submittal     Verification 4.07 AEPSC   Nuclear Engineering Division Review           10 4.08 AEPSC   Quality Assurance Verification 4.09 Final Submittal Preparation, Review and Transmittal to the NRC                               12 5.00    Procedure Revision                                         13 FIGURES No. 1   Flow Diagram No.- 2 NRC,Submittal Routing Form   GE 55 No. 3 NRC Submittal Source Document   List AEPSC General Proced No. 32
S-NUCLEAR REGULATORY COISiXSSXON Table of Contents SECTION 1.00 2.00 3.00 4.00 Purpose Policy Exceptions to Procedure Submittal Preparation Procedure PAGE NO.
5.00 4.01 Genera1 4.02 Verbal Commitments to the NRC 4.03 Draft Submittal Preparation Assignment 4.04 Draft Submittal Preparation 4.05 Supervisory Review and Approval 4.06 Site Originated Draft Submittal Verification 4.07 AEPSC Nuclear Engineering Division Review 4.08 AEPSC Quality Assurance Verification 4.09 Final Submittal Preparation, Review and Transmittal to the NRC Procedure Revision 10 12 13 FIGURES No.
1 Flow Diagram No.- 2 NRC,Submittal Routing Form GE 55 No.
3 NRC Submittal Source Document List AEPSC General Proced No. 32


AEPSC GENERAL PROCEDURE       . 32 PREPARATION OF SUBMITTALS TO THE U S . NUCLEAR REGULATORY COPS'tISSION 1 ~ 00   PURPOSE 1.01     To establish a mechanism   for the preparation of submittals to the U. S. Nuclear Regulatory Commission (NRC) 1.02 Typical submittals covered by this procedure include, but
AEPSC GENERAL PROCEDURE 32 PREPARATION OF SUBMITTALS TO THE U
        're   not limited to, the "following (Action Item):
S.
          - Responses.to NRC Office of Inspection and Enforcement Bulletins or Inspection Reports. (External)
NUCLEAR REGULATORY COPS'tISSION 1 ~ 00 PURPOSE 1.01 To establish a mechanism for the preparation of submittals to the U. S. Nuclear Regulatory Commission (NRC) 1.02 Typical submittals covered by this procedure include, but
're not limited to, the "following (Action Item):
- Responses.to NRC Office of Inspection and Enforcement Bulletins or Inspection Reports. (External)
E
E
          - FSAR or Technical Specification Changes.
- FSAR or Technical Specification Changes.
          - Responses'o NRC questions. (External)
- Responses'o NRC questions.
(External)
Responses to special NRC Investigation reports. (External)
Responses to special NRC Investigation reports. (External)
          - Commitments made verbally to the NRC. (External/Internal)
- Commitments made verbally to the NRC. (External/Internal)
          - Transmittal of Vendor furnished information to the NRC, including where appropriate, AEPSC evaluation of said in formation. (External)
- Transmittal of Vendor furnished information to the
(External) - Cause for submittal generated       by parties external to   AEPSC. FSAR and/or Tech. Spec.
: NRC, including where appropriate, AEPSC evaluation of said information.
changes can be generated by   either external or internal causes..
(External)
~ 00 POLICY 2.01   All submittals to     the NRC, with the exception of those listed in Section     3.00 below, shall   be prepared, reviewed, verified and   approved in accordance   with the procedure set forth below.
(External) - Cause for submittal generated by parties external to AEPSC.
2.02   Departures from   this procedure shall not be made without the express written consent of the AEPSC Vice Chairman, Engineexing and Construction.
FSAR and/or Tech.
AEPSC General Procedu No. 32 Rev. 0     Date
Spec.
changes can be generated by either external or internal causes..
~ 00 POLICY 2.01 All submittals to the NRC, with the exception of those listed in Section 3.00 below, shall be prepared,
: reviewed, verified and approved in accordance with the procedure set forth below.
2.02 Departures from this procedure shall not be made without the express written consent of the AEPSC Vice Chairman, Engineexing and Construction.
AEPSC General Procedu No.
32 Rev.
0 Date


r AEPSC GENE                 PROCEDURE   HO..32 (Cont   d) r 2.03             Commitments made   verbally to the NRC, are a form     of   .
r AEPSC GENE PROCEDURE HO..32 (Cont d) r 2.03 Commitments made verbally to the NRC, are a form of "submittal.
                                "submittal. .:In all cases, such commitments should. be             =
.:In all cases, such commitments should. be
=
prefaced with a statement to the effect that the verbal I
prefaced with a statement to the effect that the verbal I
commitment is subject to AEP management concurrence be-
commitment is subject to AEP management concurrence be-h
                        =
=
                              -..fore   it can be considered -a firm commitment. In most h
-..fore it can be considered
                                  'cases,'erbal commitments= will require a followup, written-.',
-a firm commitment.
In most
'cases,'erbal commitments= will require a followup, written-.',
r''ubmittal to the NRC.'Ref. Section 4.02 below) 2.04 The.preparation"of. submittals is to be assigned a high rl priority effort by all involved parties in order that-I
.'ubmittal due dates are met.
In the event of absence
'I of key personnel, the responsible Supervisor shall take I
;" appropriate'teps to assure that submittal preparation is not delayed.'.
Il-2.05, The.ASPSC Nucleanr Safety and Licensing Section.
tNS
& L) t.~AS>>
. 4 shall be responsible for thd overall. administration of
,* e I
the preparation of submittals to the. NRC including I
I
'assignment of responsibi1ity for submittal draft I
r
r
    ''ubmittal                              to the NRC.'Ref. Section 4.02 below) 2.04 The.preparation"of. submittals is to be assigned a high rl priority effort by all involved parties in order that-I
/
                              .'ubmittal due dates are met. In the event of absence *,
                                                        'I of key personnel, the responsible Supervisor shall take I
                              ;"
appropriate'teps to assure that submittal preparation I
is not delayed.'.
l-2.05, The.ASPSC Nucleanr Safety and Licensing Section. tNS & L) t.~AS>> - . 4 shall be responsible for thd overall. administration of
                                                                                ,* e I
the preparation of submittals to the. NRC including .
I I',,                                                      r-,
I
I
                                  'assignment of responsibi1ity for submittal draft I
; preparation, input to commitment program, preparation of the management.
r                    /              I
review copy of submittal; and final-I',,
                                ; preparation,   input to commitment program, preparation of the management. review copy of submittal; and final-r-             ~
r-r-,
tr
~
                                'ubmittal.
'ubmittal.
* 2.06         'he     involved Supervisors shall be responsible for re-viewing all draft submittals, prepared by their personnel,                 .
tr 2.06 'he involved Supervisors shall be responsible for re-viewing all draft submittals, prepared by their personnel, for technical accuracy and completeness.
for technical accuracy and completeness.
2.07 AEPSC Quality Assurance shall be responsible for verifying that draft submittals are factual.
2.07             AEPSC Quality Assurance shall be responsible for verifying that draft submittals are factual. The Plant Nuclear Safety Review Committee (PNSRC) shall be responsible for-AEPSC General           Procedi No     32 Rev. 0 ',   Date.H)N 9   't
The Plant Nuclear Safety Review Committee (PNSRC) shall be responsible for-AEPSC General Procedi No 32 Rev.
0
', Date.H)N 9 't


AEPSC GENERAL PROCEDURE NO;- 32"       (Contin     )
AEPSC GENERAL PROCEDURE NO;- 32" (Contin
2.07   ( Cont verifying that Plant Operations, originated draft. sub-mittals are factual. The Site QA Coordinator shall be responsible for verifying that construction originated draft submittals are factual.
)
                            'I 2.08    All "Action Items" whether NRC, Vendor or in-house initiated which require a submittal to the NRC shall           .
2.07 (Cont verifying that Plant Operations, originated draft. sub-mittals are factual.
be assigned a unique,     identification     number. Said identification shall     be shown on     all submittals to the NRC.   (Ref. Sections 4.03.c   a   4.09.b below) 2.09     This procedure is not intended to provide         all of the detailed submittal preparation procedures         for all involved parties. It shall be incumbent upon the involved AEPSC Engineering and Design Division, Plant Operations Departments, Plant Construction Departments           g or others as may be or may become involved; to develop
The Site QA Coordinator shall be responsible for verifying that construction originated 2.08 draft submittals are factual.
      ',their   own procedures   in order. to   implement the require-ments   of this procedure.
'I All "Action Items" whether NRC, Vendor or in-house initiated which require a submittal to the NRC shall be assigned a unique, identification number.
3.00    EXCEPTIONS FROM THIS PROCEDURE 3.01. The'ollowing submittals to the NRC are exempt from the requirements of this procedure and are to be prepared and submitted in accordance with previously established procedures:
Said identification shall be shown on all submittals to the NRC.
: a. Defect and non-compliance reporting       as required by 10 CFR 21 (AEPSC   General Procedure No.,31.)
(Ref. Sections 4.03.c a 4.09.b below) 2.09 This procedure is not intended to provide all of the detailed submittal preparation procedures for all involved parties. It shall be incumbent upon the involved AEPSC Engineering and Design Division, Plant Operations Departments, Plant Construction Departments g
: b. Licensee Event Reports   (LER's).
or others as may be or may become involved; to develop
: c. Special, plant-originated reports covering unusual AEPSC General Procedur No. 32 Rev.       Date
',their own procedures in order. to implement the require-3.00 3.01.
. ments of this procedure.
EXCEPTIONS FROM THIS PROCEDURE The'ollowing submittals to the NRC are exempt from the requirements of this procedure and are to be prepared and submitted in accordance with previously established procedures:
a.
Defect and non-compliance reporting as required by 10 CFR 21 (AEPSC General Procedure No.,31.)
b.
Licensee Event Reports (LER's).
c.
Special, plant-originated reports covering unusual AEPSC General Procedur No.
32 Rev.
0 Date lflM


0 c'I 4
0 c'I 4


AEPSC GENERAL PROCEDURE NO. 32       (Continued) 3.01   (Canal Operating events that are not reported via the normal event reporting procedures.
AEPSC GENERAL PROCEDURE NO.
4.-00   SUBMITTAL PREPARATION PROCEDURE 4 ~01  GENERAL 4.01a The mechanism     for preparation of submittals to the     NRC is shown in Figure No.'.
32 (Continued) 3.01 (Canal Operating events that are not reported via the normal event reporting procedures.
4.0lb   The Routing form.GE.55 shown     in Figure No. 2 shall be used   for draft submittal preparation assignment and routing for review,. approval, etc. AEPSC NS & L shall retain the original copy of the Routing Form which will become the "master" routing form for AEPSC QA verification and subsequent   management review'.
4.-00 SUBMITTAL PREPARATION PROCEDURE 4 ~ 0 1 GENERAL 4.01a The mechanism for preparation of submittals to the NRC is shown in Figure No.'.
4.01c Each   individual preparing a draft submittal shall attach to said draft, a copy. of the NRC Submittal Source Docu-ment List Form GE.56 (Fig. No. 3) on which. shall be 1'isted all of the source documents (information sources) used in the preparation of the draft.
4.0lb The Routing form.GE.55 shown in Figure No.
4.01d All Routing   and Source Document Forms shalL be attached to the "Acceptable Submittal Draft" Package by NS         & L prior to forwarding'to AEPSC QA for verification.
2 shall be used for draft submittal preparation assignment and routing for review,. approval, etc.
AEPSC NS
& L shall retain the original copy of the Routing Form which will become the "master" routing form for AEPSC QA verification and subsequent management review'.
4.01c Each individual preparing a draft submittal shall attach to said draft, a copy. of the NRC Submittal Source Docu-ment List Form GE.56 (Fig. No.
3) on which. shall be 1'isted all of the source documents (information sources) used in the preparation of the draft.
4.01d All Routing and Source Document Forms shalL be attached to the "Acceptable Submittal Draft" Package by NS
& L prior to forwarding'to AEPSC QA for verification.
4 ~ 82 VERBAL COMMITMENTS TO THE NRC
4 ~ 82 VERBAL COMMITMENTS TO THE NRC
.4.02a Individuals making verbal- commitments to the       NRC shall document the   details of all such commitments. Said documentation shall be done immediately upon making a verbal commitment and copies shall be sent to the         Head; AEPSC NS & L Section and the AEPSC Manager of QA.
.4.02a Individuals making verbal-commitments to the NRC shall document the details of all such commitments.
AEPSC General Proced No. 32 ill-A
Said documentation shall be done immediately upon making a verbal commitment and copies shall be sent to the Head; AEPSC NS
& L Section and the AEPSC Manager of QA.
AEPSC General Proced No.
32 Rev.
h Aw+w kl ill-AA


RAL PROCEDURE NO. 32     (Continued 4.02b Upon re       pt of verbal commitment       umentation, the Head, NS 5 L Section- shall review said commitment to ascertain whether a written submittal to the NRC is required.
4.02b RAL PROCEDURE NO.
32 (Continued Upon re pt of verbal commitment umentation, the Head, NS 5 L Section-shall review said commitment to ascertain whether a written submittal to the NRC is required.
Written submittals shall be prepared and processed in accordance with Section '4.03 thru 4.09 below.
Written submittals shall be prepared and processed in accordance with Section '4.03 thru 4.09 below.
4.02c Verbal commitments, not requiring" a       written submittal to the NRC shall   be entered into the'ommi,tment program by NS &   L and   assigned to AEPSC QA for follow up to assure that the   commitments are met.
4.02c Verbal commitments, not requiring" a written submittal to the NRC shall be entered into the'ommi,tment program by NS
4 ~ 03 DRAFT SUBMITTAL PREPARATION ASSIGNMENE 4.03a In many cases,       "Action Item" documents transmitted by the NRC include copies to several AEP Parties. The initial recipi.ent of the "Action Xtem" shall cause copies to be sent, as a mini-mum,   to the following parties unless said parties are desig-nated for a copy by the original NRC transmittal:
& L and assigned to AEPSC QA for follow up to assure that the commitments are met.
      - AEPSC Senior Vice President - Construction
4 ~ 03 DRAFT SUBMITTAL PREPARATION ASSIGNMENE 4.03a In many cases, "Action Item" documents transmitted by the NRC include copies to several AEP Parties.
      - AEPSC   Chief Nuclear Engineer
The initial recipi.ent of the "Action Xtem" shall cause copies to be sent, as a mini-mum, to the following parties unless said parties are desig-nated for a copy by the original NRC transmittal:
      - Plant Manager
- AEPSC Senior Vice President - Construction
      - Site Construction Manager if item i.nvolves construction
- AEPSC Chief Nuclear Engineer
          .activities
- Plant Manager
      -'ead, AEPSC NS & L Section AEPSC Manager     of Quality Assurance The original copy of the "Action Item" documents shall be dispositioned,,as specified by the initial recipient.
- Site Construction Manager if item i.nvolves construction
4.03b The Head, AEPSC NS & L Section shall,. immediately upon receipt of an "Action Xtem" document, assign said document h
.activities
to an NS & L Engineer for further assignment of submittal draft preparation responsibilities. Similarly, the AEPSC Manager of QA shall assign one of his staf f to follow AEPSC s ubmi ttal  dra ft preparation.
-'ead, AEPSC NS
AEPSC General Procedur No 32
& L Section AEPSC Manager of Quality Assurance The original copy of the "Action Item" documents shall be dispositioned,,as specified by the initial recipient.
4.03b The Head, AEPSC NS
& L Section shall,. immediately upon receipt of an "Action Xtem" document, assign said document h
to an NS
& L Engineer for further assignment of submittal draft preparation responsibilities.
Similarly, the AEPSC Manager of QA shall assign one of his staff to follow AEPSC s ubmittal draft preparation.
AEPSC General Procedur No 32


4.03c The RPhd,       NS & L, or his designated alternate,     shall assign   a   unique, sequential   identification   number   to each",Action Item" document.         NS & L shall maintain     a log of assigned identification numbers. The identifi-cation number shall be- an alpha/numeric combination, eg:   NRC   - 00001.
4.03c The RPhd, NS
: 4. 03d The assigned       NS & L engineer shall review the "Action Item" document and assign the responsibilities for preparation of draft submittals to .the responsible AEPSC Cognizant Engineex(s), and/or Plant Manager(s) and/or Resident Engineer (s) (Construction) and/or other responsible parties including vendors. Said assignments shall be shown on the master copy of the routing form in the space provided.
& L, or his designated alternate, shall assign a unique, sequential identification number to each",Action Item" document.
4.03e The assigned NS & L engineer shall review all assignments for draft, submittal preparation with the responsible parties     and   establish and,document   a schedule   for 'draft and   final submittal preparation.       The schedule   shall provide no less than one working day for execution. of each of the activities described in Sections 4.06, 4.07b 4.08 and 4.09 below. For those cases where the "Action I'tem" requires a response by a specific date (eg: 20 days I
NS
from receipt of "Action Item", etc.), the schedule shall be developed to meet said date.         Xn the event that the above review indicates that the "Action Item" 'response date cannot be met, the assigned         NS & L engineer   shall AEPSC   General. Proced No   32 Rev. 0     Date   Uj p
& L shall maintain a
log of assigned identification numbers.
The identifi-cation number shall be-an alpha/numeric combination, eg:
NRC - 00001.
: 4. 03d The assigned NS
& L engineer shall review the "Action Item" document and assign the responsibilities for preparation of draft submittals to.the responsible AEPSC Cognizant Engineex(s),
and/or Plant Manager(s) and/or Resident Engineer (s)
(Construction) and/or other responsible parties including vendors.
Said assignments shall be shown on the master copy of the routing form in the space provided.
4.03e The assigned NS
& L engineer shall review all assignments for draft, submittal preparation with the responsible parties and establish and,document a schedule for 'draft and final submittal preparation.
The schedule shall provide no less than one working day for execution. of each of the activities described in Sections 4.06, 4.07b 4.08 and 4.09 below.
For those cases where the "Action I'tem" requires a response by a specific date (eg:
20 days I
from receipt of "Action Item", etc.),
the schedule shall be developed to meet said date.
Xn the event that the above review indicates that the "Action Item" 'response date cannot be met, the assigned NS
& L engineer shall AEPSC General. Proced No 32 Rev.
0 Date Uj p


advi4 the   Head,   NS & H Section and/or Chief Nuclear Engineer, and request that an extension be 'obtained from the originator of an "Action Item".         If an ex-tension is granted, the assigned NS 6 L engineer shall assure that the new submittal due date is met.
advi4 the Head, NS
4.03f The assigned NS & L engineer     shall forward a copy of the routing form and     a complete copy of the "Action Item" document to the Section/Department Head and/or Plant Manager and/or   Construction Manager, for review and work assignment.. The assigned NS 8 L engineer shall be responsible for coordinating all aspects of submittal draft prepaxation by parties outside of AEPSC.
& H Section and/or Chief Nuclear
4.03g The assigned   NS a   L Engineer   shall enter or cause to be entered, the assignment of submittal draft preparation responsibilities into the computerized commitment, program.
: Engineer, and request that an extension be 'obtained from the originator of an "Action Item". If an ex-tension is granted, the assigned NS 6 L engineer shall assure that the new submittal due date is met.
4 04 DRAFT SUBMITTAL PREPARATION 4.04a Upon receipt   of the   documents descxibed     in 4.03f above, the Section/Department Head(s) and/or Plant Kanager(s) and/or Constxuction Manager, shall review the'se documents and forward them   to the assign'ed Cognizant Engineers and/or other -responsible parties to initiate preparation of the required submittal draft.
4.03f The assigned NS
& L engineer shall forward a copy of the routing form and a complete copy of the "Action Item" document to the Section/Department Head and/or Plant Manager and/or Construction Manager, for review and work assignment..
The assigned NS 8 L engineer shall be responsible for coordinating all aspects of submittal draft prepaxation by parties outside of AEPSC.
4.03g The assigned NS a L Engineer shall enter or cause to be
: entered, the assignment of submittal draft preparation responsibilities into the computerized commitment, program.
4 04 DRAFT SUBMITTAL PREPARATION 4.04a Upon receipt of the documents descxibed in 4.03f above, the Section/Department Head(s) and/or Plant Kanager(s) and/or Constxuction Manager, shall review the'se documents and forward them to the assign'ed Cognizant Engineers and/or other -responsible parties to initiate preparation of the required submittal draft.
4.04b Preparation of draft submittals is a high priority effort.
4.04b Preparation of draft submittals is a high priority effort.
Parties responsible for draft preparator.on shall assure that their draft meets the requirements of the "Action Item" document and that       it is concise and technically complete and accurate.
Parties responsible for draft preparator.on shall assure that their draft meets the requirements of the "Action Item" document and that it is concise and technically complete and accurate.
AEPSC General Procedu No. 32 Rev. 0     Date JUg p y
AEPSC General Procedu No.
32 Rev.
0 Date JUg p y


d 5
d
AEPSC GENERAL PROCEDURE NO; "32                   (Cont'nued)
 
  '0                      h 4.04c The Preparer               of   a   submittal draft shall document any' ~~
'0 5
AEPSC 4.04c h
- '4.04d h
h
'I GENERAL PROCEDURE NO; "32 (Cont'nued)
The Preparer of a submittal draft shall document any'
~~
criteria, procedures,'echniques, etc. that were estab-lished to obtain information'sed in the preparation of --=
criteria, procedures,'echniques, etc. that were estab-lished to obtain information'sed in the preparation of --=
                                          =
= a submittal draft.
a submittal draft. Said documentation shall. be retained in the preparers 'files and be readily retrievable for use during the Verification portions of this procedure.                 -=
Said documentation shall. be retained in the preparers 'files and be readily retrievable for use during the Verification portions of this procedure.
                                                                  /       h           h
-=
                            '4.04d The Preparer of a submittal draft shall complete .and h
/
h attach to his draft, a copy of the NRC Submittal. Source                 =
h h
Document List, (SSDL) Form No. GE.56. The SSDL shall
The Preparer of a submittal draft shall complete
                  'I h
.and attach to his draft, a copy of the NRC Submittal. Source
list all of the source documents (information sources)
=
I used. by the preparer during the preparation of the draft submittal. The SSDL will reference each source document I
Document List, (SSDL)
  ~,
Form No. GE.56.
                        /
The SSDL shall h
to tl'e appropriate sections of the. draft for which             it   is, a source, the   identification -of the         source document and its Ih
I list all of the source documents (information sources)
                      ''L' current location.
~,
t
I
  ~'
~'
                    .-       4.04e.Upon completion                 of the preparation of a draft submittal, k
used. by the preparer during the preparation of the draft submittal.
The SSDL will reference each source document to tl'e appropriate sections of the. draft for which it is,
/
a source, the identification -of the source document and Ih its current location.
''L' t
.- 4.04e.Upon completion of the preparation of a draft submittal, k
the -preparer shall forward the draft and SSDL. to his
the -preparer shall forward the draft and SSDL. to his
      *;..-,                            . Section/Department Head h
. Section/Department Head for review and approval.
for review     and approval.
h 05.
                      '          05.       SUPERVZSORY REVXEN AND APPROVAL               .*            ~
SUPERVZSORY REVXEN AND APPROVAL
          'hk                                                                                                     k
~
              .:, ...4.05a                 Draft submittals shall h
k
be reviewed and approved. by     the
'hk h
                                        /
.:,...4.05a Draft submittals shall be reviewed and approved. by the
                                      ;     Preparers Section or Department Head, as' minimum. The
/
        ~                    'o          Section/Department Head shall review the submittal draft:
; Preparers Section or Department
and assure that that  where it   is technically" accurate and complete, applicable,establishedcriteria           were adhered to during preparation of the draft.
: Head, as' minimum.
                                                                                                'EPSC General Proced No. 32
The Section/Department Head shall review the submittal draft:
~ 'o assure that it is technically" accurate and complete, and that where applicable,establishedcriteria were adhered to during preparation of the draft.
'EPSC General Proced No.
32


in accordance with requirements as established by individual AEPSC Division Heads, Plant Manager(s).,     and Site Construction Manager(s).
in accordance with requirements as established by individual AEPSC Division Heads, Plant Manager(s).,
and Site Construction Manager(s).
4.05c Upon completion of the review set forth in 4.05a, the Section/Department Head shall sign and date: the Routing Form in the space provided.
4.05c Upon completion of the review set forth in 4.05a, the Section/Department Head shall sign and date: the Routing Form in the space provided.
~ '.05d Submittal. drafts originated within AEPSC are to be routed after Supervisory review and approval to the assigned AEPSC NS
& L engineer.
Site originated sub-mittal drafts are to be routed in accordance with Section 4.06 below.
4'6 SITE ORIGINATED DRAFT SUBMITTAL VLRIFICATION 4.06a Draft submittals originated in Plant Operations or Site Construction Departments shall be forwarded to the PNSRC or Site QA Coordinator, as applicable, for verification.
4.06b The PNSRC or Site QA Coordinator or a-designated alternate/
as.applicable,, shall verify that =any criteria, procedures, techniques, etc., established for use during the develop-ment, of the submittal draft were adhered to.
Sufficient review shall be made to assure that the submittal draft is complete and addresses the "Action Item" document, require-
.ments and that'he submittal factually reflects the con-ditions as they exist at the time of verification.
State-ment of actions taken or proposed will be verified to assure that said actions were in fact taken, or that the schedule for implementation of proposed actions is realistic.
AEPSC General Procedure No.
32 Rev.
0 Date Jgg p ~]9
ERAL PROCEDURE NO.
32 (Continued)
~
~
  '.05d    Submittal. drafts originated within AEPSC are to be routed after Supervisory review and approval to the assigned AEPSC NS & L engineer. Site originated sub-mittal drafts are to be routed in accordance with Section 4.06 below.
~
4 '6  SITE ORIGINATED DRAFT SUBMITTAL VLRIFICATION 4.06a Draft submittals originated    in Plant Operations or Site Construction Departments shall be forwarded to the PNSRC or Site QA Coordinator, as applicable, for verification.
Verification shall be made that the source documents
4.06b The   PNSRC  or Site QA Coordinator or  a- designated alternate/
~ sl listed on the SSDL are readily retrievable and a l
as  .applicable,, shall verify that =any criteria, procedures, techniques, etc., established for use during the develop-ment, of the submittal draft were adhered to. Sufficient review shall be made to assure that the submittal draft is complete and addresses    the "Action Item" document, require-
sample checked to assure that the information in said documents was translat'ed correctly in the draft submittal.
        .ments and    that'he  submittal factually reflects the con-ditions as they exist at the time of verification. State-ment of actions taken or proposed will be verified to assure that said actions were in fact taken, or that the schedule for implementation of proposed actions is realistic.
4.06c Any anomalies discovered., in the submittal draft during.,
AEPSC General Procedure No. 32 Rev. 0     Date Jgg p ~]9
.verification shall be noted on the draft and the draft returned to the responsible supervisor for revision and resubmittal in accordance with Sections 4.05 and 4.06 above.
4.06d PNSRC or Site QA verification shall be indicated by a signature and date in the space provided on the Routing Form.
4.06e Upon completion of PSNRC or Site QA verification, sub-mittal drafts, including SSDL's are to be routed to the assigned AEPSC NS
& L engineer.
4.07 AEPSC NUCLEAR ENGINEERXNG DXVISXON REVIEWS 4.07a The assigned NS
& L engineer 'shall review all submittal drafts and prepare a draft, in proposed final format, for
: 4. 07b internal Nuclear Engineering Divisi,on review.
Xn the case where the final submittal requires input from several
: parties, the NS
& L engineer will prepare a combined sub-mittal draft incorporating all of the involved drafts.
The proposed final submittal draft, including all SSDL's,
~
'hall be routed to the following parties within the Nuclear Engineering Division for review and. approval: AEPSC General Procedure No.
32 Rev.
0 Date


ERAL PROCEDURE NO. 32   (Continued)
AgPSC GENERAL PROCEDURE NO.
              ~                     .. ~
32 (Continued)
Verification shall be    made  that the source documents        ~ sl listed on the SSDL are readily retrievable and a l sample checked to assure that the information in said documents was translat'ed correctly in the draft submittal.
~
4.06c Any anomalies discovered., in the submittal draft during .,
~
      .verification shall be noted on the draft and the draft returned to the responsible supervisor for revision and resubmittal in accordance with Sections 4.05 and 4.06 above.
l.
4.06d  PNSRC  or Site  QA verification shall be indicated by a signature  and  date in the space provided on the Routing Form.
: Head, NS
4.06e Upon completion    of PSNRC or Site QA verification, sub-mittal drafts, including SSDL's are to be routed to the assigned  AEPSC NS  & L engineer.
& L Section.
4.07  AEPSC NUCLEAR ENGINEERXNG DXVISXON REVIEWS 4.07a The assigned    NS & L engineer  'shall review  all  submittal drafts and prepare a    draft, in proposed final format, for internal Nuclear Engineering Divisi,on review. Xn the case where the final submittal requires input from several parties, the NS & L engineer will prepare a combined sub-          .
2.
mittal draft incorporating all of the involved drafts.
Assistant, Head, Nuclear Engineering Division 3., Chief Nuclear Engineer
: 4. 07b The proposed final submittal draft, including all SSDL's,~
'4.07c Once an acceptable, proposed final draft submittal is developed, the draft including all. SSDL's shall be routed to the AEPSC Manager of Quality Assurance for verification.
be routed to the following parties within the      'hall Nuclear Engineering Division for review and. approval:
4.08'EPSC'UALITY ASSURANCE VERIPICATION 4;Osa The AEPSC Manager of,QA, or his designated alternate, shall verify that any criteria, procedures,'echniques, etc., established for use during the development of AEPSC<<originated submittal drafts were adhered to.
AEPSC  General Procedure No. 32 Rev. 0    Date
Sufficient review shall be made to assure that the draft is complete and addresses the "Action Item" docu-ment requirements; and that the submittal factually re' fleets the conditions as they exist or willexist at the time the submittal is made to the NRC.
 
Statements of actions taken or proposed will be verified to assure that P
AgPSC GENERAL PROCEDURE NO. 32        (Continued)
said actions w'ere, in fact> taken, or that the schedule for implementation of proposed action is realistic.
          ~l.                      .      ~
Veri-fication shall be made that the source documents listed on the SSDL, for AEPSC-originated drafts, are readily retrieva and a sample checked to assure that the informatj.on in said documents was translated correctly to the draft submittal.
Head, NS & L Section.
4.08b Any anomalies discovered in the draft during verification shall be noted on the draft and the draft returned to the assigned NS
: 2. Assistant, Head, Nuclear Engineering Division 3., Chief Nuclear Engineer
& L eng'neer for revision and resubmittal in AEPSC General Proced No.
'4.07c Once an acceptable,   proposed   final draft submittal is developed, the   draft including all.     SSDL's shall be routed to the   AEPSC Manager   of Quality Assurance for verification.
4.08'EPSC'UALITY       ASSURANCE VERIPICATION 4;Osa The AEPSC Manager of,QA,       or his designated alternate, shall verify that any criteria, procedures,'echniques, etc., established for use during the development of AEPSC<<originated submittal drafts were adhered to.
Sufficient review shall be made to assure that the draft is complete and addresses the "Action Item" docu-ment requirements; and that the submittal factually re' fleets the conditions as they exist or will exist at the time the submittal is made to the NRC. Statements of actions taken or proposed will be verified to assure that P
said actions w'ere, in fact> taken, or that the schedule for implementation of proposed action is realistic. Veri-fication shall be made that the source         documents   listed on the SSDL, for AEPSC-originated drafts,         are readily retrieva and a sample checked     to assure that the informatj.on in said documents was translated correctly to the draft submittal.
4.08b Any anomalies discovered in the draft during verification shall be noted on the draft and the draft returned to the assigned NS & L eng'neer for revision and resubmittal in AEPSC General Proced No.
Rev.
Rev.


4.08c'AEPSC   QA verification shall be indicated by a signature and date in the space provided on the Routing Form.
4.08c'AEPSC QA verification shall be indicated by a signature and date in the space provided on the Routing Form.
4 4.08d 'Upon completion of .the AEPSC QA verification, the propose<
4 4.08d 'Upon completion of.the AEPSC QA verification, the propose<
final submittal draft shall be routed to the assigned NS & L engineer.
final submittal draft shall be routed to the assigned NS
4.09   FXNAL SUBMITTAL=PREPARATION   REVXEN AND TRANSMITTAL TO THE NRC
& L engineer.
: 4. 09a Upon receipt, of the final submittal draft from AEPSC QA, I
4.09 FXNAL SUBMITTAL=PREPARATION REVXEN AND TRANSMITTAL TO THE NRC
the assigned NS & L engineer shall prepare the submitta1   =
: 4. 09a Upon receipt, of the final submittal draft from AEPSC QA, I
the assigned NS
& L engineer shall prepare the submitta1
=
in final format for transmittal to the NRC.
in final format for transmittal to the NRC.
4.09b The assigned'S & L engineer ~hall assure that the sub-mittal or submittal transmittal. letter bears the same "Action Item", identification number as assigned in Section 4.03c above. In the case where more than one submittal is transmitted in response to an "Action Item",
4.09b The assigned'S
the submittals shall bear the- same identifi'cation number and be sequentially suffixed as follows:
& L engineer ~hall assure that the sub-mittal or submittal transmittal. letter bears the same "Action Item", identification number as assigned in Section 4.03c above.
Action Item Identification ~ NRC-00001 1st submittal                   NRC-0000 1A 2nL submittal                   NRC-000018 a
In the case where more than one submittal is transmitted in response to an "Action Item",
4.09c The assigned NS & L engineer shall route the submittal, in final format, as designated on the= Routing Form GE.55.
the submittals shall bear the-same identifi'cation number and be sequentially suffixed as follows:
4.09d. Ea'ch reviewer shall signify his concurrence with the sub-mittal by crossing off his name and signing and dating the form in the space provided.
Action Item Identification
AEPSC General Proce No. 32 Rev. 0   Date
~
NRC-00001 1st submittal NRC-0000 1A 2nL submittal NRC-000018 a
4.09c The assigned NS
& L engineer shall route the submittal, in final format, as designated on the= Routing Form GE.55.
4.09d. Ea'ch reviewer shall signify his concurrence with the sub-mittal by crossing off his name and signing and dating the form in the space provided. AEPSC General Proce No.
32 Rev.
0 Date


4.09e Upon comp Cont nued t
C' Cont nuedt 4.09e Upon comp tion of the revie'w, all submittals, with the exception 'of. submittals to NRC Regional Offices, must il be signed by an Officer of the licensee company and notarized if required.
tion of the revie'w, all submittals, with the C'            exception 'of. submittals to NRC Regional Offices, must il be signed by an Officer of the licensee company and notarized if required. Submittals to NRC Regional Offices must be signed           I by the   AEPSC   Senior Executive Vice President     Engineeiing   or an'fficer'' of   the licensee company.
Submittals to NRC Regional Offices must be signed I
4.09f     The signer of   a submittal shall return, the signed submittal to the   Head NS   & L" Section.
by the AEPSC Senior Executive Vice President Engineeiing or an'fficer'' of the licensee company.
4.09g The Head,       NS &   L shall cause the submittal to be transmitted.
4.09f The signer of a submittal shall return, the signed submittal to the Head NS
to the   NRC, and   assure that designated copies are distributed.
& L" Section.
4.09h     The Head, -NS & L shall enter, or cause to be entered, into the commitment'rogram, all commitments made in the sub-
4.09g The Head, NS
            =. mittal'to   the   HRC.
& L shall cause the submittal to be transmitted.
5.'00    PROCEDURE   REVISlON 5.01
to the NRC, and assure that designated copies are distributed.
      ~      AEPSC   Quality Assurance shall prepare
4.09h The Head,
                            ~
-NS
and issue   all revisions to this procedure.
& L shall enter, or cause to be entered, into the commitment'rogram, all commitments made in the sub-5.'00
  , 5 '2      All revisions go this procedure shall       be reviewed by the following:
=. mittal'to the HRC.
              - AEPSC Nanager of Quality Assurance
PROCEDURE REVISlON
              - -Head - AEPSC   Nuclear Safety and Licensing Section Chief Nuclear Engineer AEPSC Seniog Vice President, Construction AEPSC Sjniqr Executive Vice President, Engineering and approved by:
~
AEPSC   Vice ghairman     Engineering and Construction.
~
AEPSC   General Procedure No.
5.01 AEPSC Quality Assurance shall prepare and issue all revisions
Rev. 0
, 5'2 to this procedure.
All revisions go this procedure shall be reviewed by the following:
- AEPSC Nanager of Quality Assurance
- -Head - AEPSC Nuclear Safety and Licensing Section Chief Nuclear Engineer AEPSC Seniog Vice President, Construction AEPSC Sjniqr Executive Vice President, Engineering and approved by:
AEPSC Vice ghairman Engineering and Construction. AEPSC General Procedure No.
Rev.
0


REPSC GENERA+7'ROCEDURE NO;. 32     (Canting) 5.03   All temporary   Changes to New Requirements   for (interim changes)   or Temporary Waiver of and/or part of this     .
REPSC GENERA+7'ROCEDURE NO;. 32 (Canting) 5.03 All temporary Changes to New Requirements for (interim changes) or Temporary Waiver of and/or part of this procedure shall be made using Form GE.27.E "Procedure Temporary Sheet" and Form GE.27.El - "Procedure Temporary Sheet Continuation".
procedure shall be   made using Form GE.27.E "Procedure Temporary Sheet" and Form GE.27.El     - "Procedure Temporary Sheet   Continuation".
5.04 All Procedure Temporary Sheets are to be filed with this procedure until such time as they are cancelled, expire or are incorporated into a permanent revision of'his procedure.
5.04   All Procedure Temporary Sheets are to     be filed with this procedure until such time as they are     cancelled, expire or are incorporated into   a permanent revision   of'his procedure.
5.05 All revisions covered by Procedure, Temporary Sheets, except
5.05   All revisions   covered by Procedure, Temporary Sheets,     except
, for Temporary Waivers, shall be incorporated into each, permanent revision of this procedure..
      , for Temporary Waivers,   shall be incorporated into     each, permanent revision of this procedure..
AEPSC General Procedur No.
AEPSC   General Procedur No. 32
32


~ c HRC 5USMITTAI CKNERATKO BYI~
~ c HRC 5USMITTAI CKNERATKO BYI
IK BULLETIN IK REPORT                               VERBAL COMMITMENT FSAR CHANGE                                 TO THE NRC TECH SPKC. CHAHQK NRC QUESTION VENDOR INFIX tACTION ITEMS)
~
HKAO AEPSC NS& I Bc~ON                               OtHERS AEP5C  .
IK BULLETIN IK REPORT FSAR CHANGE TECH SPKC. CHAHQK NRC QUESTION VENDOR INFIX tACTION ITEMS)
lIQR Of    FOR ASSIGNMENT TO N5 & I                       RKF. 5KCT. 4.OSA OA                  ENGINEER                          QEN. PROC. HO.SB NS &L KNGUIKER ASSIGN RESPOHSIBIUTYtSI fOR         COMMITMKNT PROGRAM ASSIGN OA                                ENTRY SUBMITTAI. PREPARATION KNQINKcct      SUBMITTAL PREPARATION TO FOLLOW AEPSC COG. ENGR.
VERBAL COMMITMENT TO THE NRC AEP5C lIQR Of OA HKAO AEPSC NS& I Bc~ON FOR ASSIGNMENT TO N5 &I ENGINEER OtHERS RKF. 5KCT. 4.OSA QEN. PROC. HO.SB ASSIGN OA KNQINKcct TO FOLLOW NS &L KNGUIKER ASSIGN RESPOHSIBIUTYtSI fOR SUBMITTAL PREPARATION COMMITMKNTPROGRAM ENTRY SUBMITTAI. PREPARATION AEPSC COG. ENGR.
OR CttIKR RKSPCNSIBLc &PARTY     PLANT                CONST.
OR CttIKR RKSPCNSIBLc&PARTY SKCTION/OEPT HEAO FOR WORK ASSIGNMENT PLANT MANAGER CONST.
MANAGER SKCTION/OEPT HEAO FOR       MANAGER l SITE)
MANAGER lSITE) 0EPT HEAO OEPT HEAO VENOOR AKPSC CCQ.ENGR. ANO/OR OTH&t RESPONSIBLE PARTY PREPARE CRAFT SUBMITTAL{5)
WORK ASSIGNMENT 0EPT                 OEPT HEAO                 HEAO        VENOOR AKPSC CCQ.ENGR. ANO/OR         ORAFT OTH&t RESPONSIBLE PARTY                             ORAFT SUBMITTAL          5UBMITTAI PREPARE CRAFT SUBMITTAL{5)
ORAFT SUBMITTAL SUP ERVISORY REVIEW &
SUP ERVI SORY      5 UP KRVISCRY REVIEW &            REVIEW &
APPROVAL ORAFT 5UBMITTAI 5 UP KRVISCRY REVIEW &
APPROVAL            APPROVAI.
APPROVAI.
SUPERVISORY REVIEW &         PN5RC               SITE OA APPROVAL            VERI F              VERIF ICATION              ICATION ASSIQIIED NS & L ENGINEER REVIEW d PRKPARK A FINAL SUBMITTAL CRAFT AEPSC NUCLEAR OIVISION RKVIKW ACCEPTABLE FINAL SUBMITTAL CRAFT AEP5C OA VKRlfICATION N5 &L UPOATE CCMMITM VT PROGRAM FILE TO INOICATE COMPLETION Of CRAFT SUB4ITTAt PREPARATION & OA VERIFICATION AKP5C NS & L ENGINEER p"
SUPERVISORY REVIEW &
    ~
APPROVAL PN5RC VERI F ICATION SITE OA VERIF ICATION ASSIQIIED NS & L ENGINEER REVIEW d PRKPARK A FINAL SUBMITTAL CRAFT AEPSC NUCLEAR OIVISION RKVIKW ACCEPTABLE FINAL SUBMITTAL CRAFT
PREPARE SUBMITTAI IN FINAL FORMAT AEPSC LEGAL &
~
MANAGL4ENT RKVIEW             NS   &L UP&ATE COMMITMK!IT
p" AEP5C OA VKRlfICATION AKP5C NS & L ENGINEER PREPARE SUBMITTAI IN FINAL FORMAT N5 &L UPOATE CCMMITM VT PROGRAM FILE TO INOICATE COMPLETION Of CRAFT SUB4ITTAt PREPARATION & OA VERIFICATION AEPSC LEGAL &
                                                          ~ PROGRAM TO INCLUOE COMMITMKNTS MACK IN SUSMITTAL TRANSMIT TO NRC AEPSC         General Procedure No. 32 Rev. 0 Figure         No ..       l JUz 0-X >
MANAGL4ENT RKVIEW TRANSMIT TO NRC NS &L UP&ATE COMMITMK!IT
~ PROGRAM TO INCLUOE COMMITMKNTS MACK IN SUSMITTAL AEPSC General Procedure No.
32 Rev.
0 Figure No.. l JUz 0-X >


FOR.'4 CE 55                                           IIRC SUBMITTAL ROUTIHG SUBJECT                                                                                                  NRC SUBMITS ACTIOH ITEM IDEHT. NO+                                                                                                                       DUE DATE HRC~
IIRC SUBMITTAL ROUTIHG FOR.'4 CE 55 NRC SUBMITS DUE DATE ACTIOH ITEM IDEHT. NO+
HEAD HSCsL         DATE REC'D.:                     DATE ASSIGH:                      ASSIGN TO:
HRC~
DRAFT SUBMITTAlPREPARATION ASSIGNMENT BY             HSS l ENGINEER HAMK                ACTION ITEM                   NAME                 ACTIOH ITEM                   HANK                    ACTION ASSIGN TO:
SUBJECT DATE ASSIGH:
SECTION/DEPT, HKAO                 DATE REC'Oe               OATK ASSIGNS SUPERVISORY REVIKW 8 APPROVAL                                                                              E   PHSRC/SITE QA VERIFICATI 0
ASSIGN TO:
SECTION/DEPT+ HEAD                 DATE                   OTHER                     DATE                   SICNATURE ASSIGNED NSSL ENCR ~                           DATE DRAFT RKC'Oo                            DATE ROUTED FOR NE     OIT. RETIE'+
HEAD HSCsL DATE REC'D.:
AEPSC NUCLEAR DIVISION REVIEW                                                                 I
0 G
                                            .                                                         I I
(
I. HEAD, HSSL DATE I
H DRAFT SUBMITTAlPREPARATION ASSIGNMENT BY HSSl ENGINEER ACTION HANK ACTIOH ITEM HAMK NAME ACTION ITEM ASSIGN TO:
                                                                                                      "I                                            DATE I
SECTION/DEPT, HKAO DATE REC'Oe OATK ASSIGNS E
G      2. ASST. DIV. HEAD                                                                             I OATK                                                        DATE I
PHSRC/SITE QA VERIFICATI SUPERVISORY REVIKW 8 APPROVAL SECTION/DEPT+
(        3. CHIEF NUCLEAR ENGR.
HEAD SICNATURE DATE DATE OTHER DATE DRAFT RKC'Oo ASSIGNED NSSL ENCR ~
DATE I
DATE ROUTED FOR NE OIT. RETIE'+
DATE I
I I
ASSICNED NfdL ENCR ~
I I"I I
0 REVIEW 8 TYPK         0 REVISE. REDRAFT'ESUBMIT AEPSC QA VERIFICATIOH H
I AEPSC NUCLEAR DIVISION REVIEW.
ENGR'.
I. HEAD, HSSL
AEPSC NRG. OR C*                         DATE REC'0 ~                          5IG'IATURE ASSIGNED Nfdl.                                       OATK REC'D                                DATE ROUTED FOR HCT.     REVIK*
: 2. ASST. DIV. HEAD
A E P5 C MANAGEMENT REVIEW                                                          LEGAI.
: 3. CHIEF NUCLEAR ENGR.
3   HEAD, HSS L SI GNATURE                  DATE                        SIGNATURE                    DATE 2; ASST. DIV. HD. HE DIV                                                         6. SUBMITTALSIGHATURE Sl GNATURE                  DATE R. JOHH E. DOLAH II%I TI ALS
DATE DATE OATK I
: 3. CHIEFHUCLEAR EHGINEER SI GNATURK                   DATE                        OTHER              INITIALS
I DATE I
: 4. AEPSC MGR. OF QA                                                                 b. OFFICER OF UCEHSEK SIGNATURE                   DATE                JOHN TILUNGHAST INITIALS OTHER             INITIALS HEAD NfdL                                     NOTARY                                                      OA AEPSC     General Procedi
0 REVIEW 8 TYPK 0 REVISE. REDRAFT'ESUBMIT DATE DATE ASSICNED NfdL ENCR ~
                                                                                                                'No. 32           Figure No.
AEPSC QA VERIFICATIOH 5IG'IATURE DATE REC'0 ~
OF SUBMITTAL LETTER TO HRC FII.KNO       JUN 0     1 19'ATE
AEPSC NRG.
OR C*
DATE ROUTED FOR HCT. REVIK*
OATK REC'D ASSIGNED Nfdl.ENGR'.
LEGAI.
AE P5 C MANAGEMENTREVIEW 3
HEAD, HSS L 2; ASST. DIV. HD. HE DIV SIGNATURE DATE DATE SI GNATURE
: 6. SUBMITTALSIGHATURE R. JOHH E. DOLAH Sl GNATURE DATE II%I TI ALS
: 3. CHIEFHUCLEAR EHGINEER INITIALS OTHER DATE SI GNATURK
: b. OFFICER OF UCEHSEK JOHN TILUNGHAST
: 4. AEPSC MGR. OF QA DATE SIGNATURE INITIALS OTHER INITIALS OA NOTARY HEAD NfdL AEPSC General Procedi
'No.
32 Figure No.
FII.KNO JUN 0 1 19'ATE OF SUBMITTALLETTER TO HRC


FORM GE~SB                               ~ 4 RRC . $ UBMITTA SOURt'E DOCUMENT           IlST
FORM GE~SB
\ Q ACTlON lTEM IDENT. NO.
~
THE FOLLOWING OOCUMENTS HAVE BEEN USEO AS SOURCES OF INFORMATION FOR PREPARATION OF THE ATTACNEO NRC SUBMITTAL~ COPIES OF THESE OOCUMENTS ARE AVAILABLE FOR REVIEW AT THE LOCATION SPECI FI EOe SUBMITTALSTATEMENT         SOURCE DOCUMENT DESCRIPTION       ~ TITLE,             CURRENT SOURCE PAGE    'ARA+                    NUMBER~ RKVISIONt KTC                           DOC. LOCATION AEP C General Proc Ho. 32 Figure No.
4 RRC
JUN   oa IS-a}}
. $UBMITTA SOURt'E DOCUMENT IlST
\\ Q ACTlON lTEM IDENT. NO.
THE FOLLOWING OOCUMENTS HAVE BEEN USEO AS SOURCES OF INFORMATION FOR PREPARATION OF THE ATTACNEO NRC SUBMITTAL~
COPIES OF THESE OOCUMENTS ARE AVAILABLE FOR REVIEW AT THE LOCATION SPECI FI EOe SUBMITTALSTATEMENT PAGE 'ARA+
SOURCE DOCUMENT DESCRIPTION ~ TITLE, NUMBER~ RKVISIONt KTC CURRENT SOURCE DOC. LOCATION AEP C General Proc Ho.
32 Figure No.
JUN oa IS-a}}

Latest revision as of 15:30, 5 January 2025

Responding to Letter of 5/30/1978 & 3 Appendices, Enclosed Check of $10,000.00, and Listed Responses for Appendix a
ML18219D812
Person / Time
Site: Cook  
Issue date: 06/15/1978
From: Tillinghast J
Indiana & Michigan Electric Co, Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co)
To: Volgeneau E
Office of Nuclear Reactor Regulation
References
Download: ML18219D812 (29)


Text

INDIANA 5 HlCHlGAN ELECTRiC COMPANY P

O. BOX 18 BOWLlHG GR E EH ST AT1OH NEW YORK, N. Y. 10004 8une 15,'978 Indiana a Mich'n lectric Co.

and Indiana

& Mi higan P wer Co.

Donald C.

Co k Nucle Plant, Units 1 and 2

(Docket Nos.

50-315 d 50-316)

., Dr; Ernst Volgenau

. Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Dr. Volgenau:

CD This is in reply to your letter of May 30, 1978~anI its three appendices referring to the results of an mRCc investigation conducted during December, 1977 and JaLa~,

1978, into the testing of electrical cables, conne+Ws~nd penetrations at the Donald C. Cook Nuclear: Plant, UaYt Nos. 1-..

and 2.

No response to Appendix C of your letter is tt.eqiKLred.

In response to Appendix B, enclosed herewith is a checkgn the amount of Ten Thousand Dollars

($10,000.00).

Oug response

'o Appendix A follows..

r With respect to the subject matter of the'irst allegation which related to electrical penetrations, our statement in the. October, 1977 PSAR amendment that the penetrations had been tested "to the requirements of IEEE 323, Appendix A, Combined requirements of Tables Al and A2" was a

. mistake.

It resulted from a misunderstanding during a tele-phone conversation between a member of our electrical engineerinc division and an employee of the test. laboratories of Conax Corporation.

=This misunderstanding was incorporated into a draft of our amendment submittal.

Unfortunately it was not discovered in the course of the review of that draft prior to its finalization within AEP and its submittal to NRC.

The second allegation in Appendix A related to the testing of instrument cable.

Here too the draft of our October, 1977 submittal was prepared based on the results of t'esting (whi h, ply, H 782430137

0

~ '

AI'~ '

I ~ k.>>y,$ -

P

<<"t>>

Dr. Ernst Volgenau Page 2

~

P

.I I

L

's.NRC correctly observes, involved in one. instance testing of cable materials versus. the as-installed cable itself, and in another instance testing of 12-.gauge control-size single conductor cable versus the as-installed 16-gauge quad configured instrument cable itself). and was not determined,.during the review of, that draft prior to its finalization within AEP and

..',-'its submittal to NRC, to be an inappropriate or incorrect

,:-.'","-.>=". description of our test data.

Thus we do not. deny these two'llegations.

The events alleged did occur.

As we discussed, during our meeting on April 12, 1978, our m*anagement,at the highest levels of AEP and, I&M Electric, and, IaM Power,has involved, itself directly to ensure that future submittals to NRC are completely accurate and sufficientl

'etailed.

To this end, I personally have met at. our offices in New York and at the Cook Plant, with our cognizant, engineers who have the responsibility to draft documents for submittal to NRC.

They understand. the importance of the information we provide to NRC and the need. for unerring accuracy.

Further,.

.we have formally instituted, upon our new quality assurance manager's recommendation, a change in our procedures to directly 'involve quality assurance personnel in the review of materials proposed for submittal to NRC.

Thus, in addition to the technical and administrative. review formerly-given drafts of submittals to NRC, under the modification an additiona

. 'independent check of all such drafts by quality assurance, personnel will be performed.

A copy.of our new procedure is enclosed for your 'information.. Finally, we are undertaking a

,, program for computerization of our commitments to NRC.

..While we are proud of the excellent record we have establis in connection with. the design, construction and operation of the Donald C. Cook nuclear units, we appreciate the importance of complete accuracy and sufficient detail in all our submittals of.technical information to NRC.

While we are disappointed that'he events discussed above ever transpired,

.we are dedicated to

-~'aking them a trigger to ever better performance on our part.

We assure you there will be no recurrence of such events.

I Very truly yours, Indiana 6 Michigan"Electric C

JT p enc.. 2 g

SZ ice President cc: Mr. J.

Q. Keppler, USNRC Region III enc.

1

~q)+AN Kl Pg )

AMERICAH ELECTRIC POWER SERVICE CORPORATIOH OLVEA SVSTE Divi.sion Organization and Procedures Manual Section Procedure No.

32-pre aration of Submittals to the U.S. Nuclea!

Re ulato

'Commission REVISION RECORD Revision 0

Issue Date 6/1/78 Affected Pages Initial Issue Approved By John Tillinghas

AEPSC GENERAL PROCEDURE NO.

32 PBEPABATXON OF SUBMXTTAL TO THE U.

S -

NUCLEAR REGULATORY COMNXSSXON

~.P XNXTXAL XSSUE BEUXSXON 0 Prepared By-

. AEP C

anager f QA Date: 5 I8 78 Reviewed By:

7

Head, AE S

Nuclea a ety Licensing Section Date:,

ief Nu ar gineer Date:

Senz.or Vz,ce Pres~dent, Construction Sen'xecutive Vice Pres@dent, Engi ering Approved Bv.:

ha an, Engin e

ng and C nstruction Date:

AEPSC General Procedure No 32 Rev.

0 Date JUg 0 ] '197I

t AEPSC GENERAL PROCEDU NO 32 PREPARATION OF SUBiMXTTA TO THE U

S-NUCLEAR REGULATORY COISiXSSXON Table of Contents SECTION 1.00 2.00 3.00 4.00 Purpose Policy Exceptions to Procedure Submittal Preparation Procedure PAGE NO.

5.00 4.01 Genera1 4.02 Verbal Commitments to the NRC 4.03 Draft Submittal Preparation Assignment 4.04 Draft Submittal Preparation 4.05 Supervisory Review and Approval 4.06 Site Originated Draft Submittal Verification 4.07 AEPSC Nuclear Engineering Division Review 4.08 AEPSC Quality Assurance Verification 4.09 Final Submittal Preparation, Review and Transmittal to the NRC Procedure Revision 10 12 13 FIGURES No.

1 Flow Diagram No.- 2 NRC,Submittal Routing Form GE 55 No.

3 NRC Submittal Source Document List AEPSC General Proced No. 32

AEPSC GENERAL PROCEDURE 32 PREPARATION OF SUBMITTALS TO THE U

S.

NUCLEAR REGULATORY COPS'tISSION 1 ~ 00 PURPOSE 1.01 To establish a mechanism for the preparation of submittals to the U. S. Nuclear Regulatory Commission (NRC) 1.02 Typical submittals covered by this procedure include, but

're not limited to, the "following (Action Item):

- Responses.to NRC Office of Inspection and Enforcement Bulletins or Inspection Reports. (External)

E

- FSAR or Technical Specification Changes.

- Responses'o NRC questions.

(External)

Responses to special NRC Investigation reports. (External)

- Commitments made verbally to the NRC. (External/Internal)

- Transmittal of Vendor furnished information to the

NRC, including where appropriate, AEPSC evaluation of said information.

(External)

(External) - Cause for submittal generated by parties external to AEPSC.

FSAR and/or Tech.

Spec.

changes can be generated by either external or internal causes..

~ 00 POLICY 2.01 All submittals to the NRC, with the exception of those listed in Section 3.00 below, shall be prepared,

reviewed, verified and approved in accordance with the procedure set forth below.

2.02 Departures from this procedure shall not be made without the express written consent of the AEPSC Vice Chairman, Engineexing and Construction.

AEPSC General Procedu No.

32 Rev.

0 Date

r AEPSC GENE PROCEDURE HO..32 (Cont d) r 2.03 Commitments made verbally to the NRC, are a form of "submittal.

.:In all cases, such commitments should. be

=

prefaced with a statement to the effect that the verbal I

commitment is subject to AEP management concurrence be-h

=

-..fore it can be considered

-a firm commitment.

In most

'cases,'erbal commitments= will require a followup, written-.',

rubmittal to the NRC.'Ref. Section 4.02 below) 2.04 The.preparation"of. submittals is to be assigned a high rl priority effort by all involved parties in order that-I

.'ubmittal due dates are met.

In the event of absence

'I of key personnel, the responsible Supervisor shall take I

" appropriate'teps to assure that submittal preparation is not delayed.'.

Il-2.05, The.ASPSC Nucleanr Safety and Licensing Section.

tNS

& L) t.~AS>>

. 4 shall be responsible for thd overall. administration of

,* e I

the preparation of submittals to the. NRC including I

I

'assignment of responsibi1ity for submittal draft I

r

/

I

preparation, input to commitment program, preparation of the management.

review copy of submittal; and final-I',,

r-r-,

~

'ubmittal.

tr 2.06 'he involved Supervisors shall be responsible for re-viewing all draft submittals, prepared by their personnel, for technical accuracy and completeness.

2.07 AEPSC Quality Assurance shall be responsible for verifying that draft submittals are factual.

The Plant Nuclear Safety Review Committee (PNSRC) shall be responsible for-AEPSC General Procedi No 32 Rev.

0

', Date.H)N 9 't

AEPSC GENERAL PROCEDURE NO;- 32" (Contin

)

2.07 (Cont verifying that Plant Operations, originated draft. sub-mittals are factual.

The Site QA Coordinator shall be responsible for verifying that construction originated 2.08 draft submittals are factual.

'I All "Action Items" whether NRC, Vendor or in-house initiated which require a submittal to the NRC shall be assigned a unique, identification number.

Said identification shall be shown on all submittals to the NRC.

(Ref. Sections 4.03.c a 4.09.b below) 2.09 This procedure is not intended to provide all of the detailed submittal preparation procedures for all involved parties. It shall be incumbent upon the involved AEPSC Engineering and Design Division, Plant Operations Departments, Plant Construction Departments g

or others as may be or may become involved; to develop

',their own procedures in order. to implement the require-3.00 3.01.

. ments of this procedure.

EXCEPTIONS FROM THIS PROCEDURE The'ollowing submittals to the NRC are exempt from the requirements of this procedure and are to be prepared and submitted in accordance with previously established procedures:

a.

Defect and non-compliance reporting as required by 10 CFR 21 (AEPSC General Procedure No.,31.)

b.

Licensee Event Reports (LER's).

c.

Special, plant-originated reports covering unusual AEPSC General Procedur No.

32 Rev.

0 Date lflM

0 c'I 4

AEPSC GENERAL PROCEDURE NO.

32 (Continued) 3.01 (Canal Operating events that are not reported via the normal event reporting procedures.

4.-00 SUBMITTAL PREPARATION PROCEDURE 4 ~ 0 1 GENERAL 4.01a The mechanism for preparation of submittals to the NRC is shown in Figure No.'.

4.0lb The Routing form.GE.55 shown in Figure No.

2 shall be used for draft submittal preparation assignment and routing for review,. approval, etc.

AEPSC NS

& L shall retain the original copy of the Routing Form which will become the "master" routing form for AEPSC QA verification and subsequent management review'.

4.01c Each individual preparing a draft submittal shall attach to said draft, a copy. of the NRC Submittal Source Docu-ment List Form GE.56 (Fig. No.

3) on which. shall be 1'isted all of the source documents (information sources) used in the preparation of the draft.

4.01d All Routing and Source Document Forms shalL be attached to the "Acceptable Submittal Draft" Package by NS

& L prior to forwarding'to AEPSC QA for verification.

4 ~ 82 VERBAL COMMITMENTS TO THE NRC

.4.02a Individuals making verbal-commitments to the NRC shall document the details of all such commitments.

Said documentation shall be done immediately upon making a verbal commitment and copies shall be sent to the Head; AEPSC NS

& L Section and the AEPSC Manager of QA.

AEPSC General Proced No.

32 Rev.

h Aw+w kl ill-AA

4.02b RAL PROCEDURE NO.

32 (Continued Upon re pt of verbal commitment umentation, the Head, NS 5 L Section-shall review said commitment to ascertain whether a written submittal to the NRC is required.

Written submittals shall be prepared and processed in accordance with Section '4.03 thru 4.09 below.

4.02c Verbal commitments, not requiring" a written submittal to the NRC shall be entered into the'ommi,tment program by NS

& L and assigned to AEPSC QA for follow up to assure that the commitments are met.

4 ~ 03 DRAFT SUBMITTAL PREPARATION ASSIGNMENE 4.03a In many cases, "Action Item" documents transmitted by the NRC include copies to several AEP Parties.

The initial recipi.ent of the "Action Xtem" shall cause copies to be sent, as a mini-mum, to the following parties unless said parties are desig-nated for a copy by the original NRC transmittal:

- AEPSC Senior Vice President - Construction

- AEPSC Chief Nuclear Engineer

- Plant Manager

- Site Construction Manager if item i.nvolves construction

.activities

-'ead, AEPSC NS

& L Section AEPSC Manager of Quality Assurance The original copy of the "Action Item" documents shall be dispositioned,,as specified by the initial recipient.

4.03b The Head, AEPSC NS

& L Section shall,. immediately upon receipt of an "Action Xtem" document, assign said document h

to an NS

& L Engineer for further assignment of submittal draft preparation responsibilities.

Similarly, the AEPSC Manager of QA shall assign one of his staff to follow AEPSC s ubmittal draft preparation.

AEPSC General Procedur No 32

4.03c The RPhd, NS

& L, or his designated alternate, shall assign a unique, sequential identification number to each",Action Item" document.

NS

& L shall maintain a

log of assigned identification numbers.

The identifi-cation number shall be-an alpha/numeric combination, eg:

NRC - 00001.

4. 03d The assigned NS

& L engineer shall review the "Action Item" document and assign the responsibilities for preparation of draft submittals to.the responsible AEPSC Cognizant Engineex(s),

and/or Plant Manager(s) and/or Resident Engineer (s)

(Construction) and/or other responsible parties including vendors.

Said assignments shall be shown on the master copy of the routing form in the space provided.

4.03e The assigned NS

& L engineer shall review all assignments for draft, submittal preparation with the responsible parties and establish and,document a schedule for 'draft and final submittal preparation.

The schedule shall provide no less than one working day for execution. of each of the activities described in Sections 4.06, 4.07b 4.08 and 4.09 below.

For those cases where the "Action I'tem" requires a response by a specific date (eg:

20 days I

from receipt of "Action Item", etc.),

the schedule shall be developed to meet said date.

Xn the event that the above review indicates that the "Action Item" 'response date cannot be met, the assigned NS

& L engineer shall AEPSC General. Proced No 32 Rev.

0 Date Uj p

advi4 the Head, NS

& H Section and/or Chief Nuclear

Engineer, and request that an extension be 'obtained from the originator of an "Action Item". If an ex-tension is granted, the assigned NS 6 L engineer shall assure that the new submittal due date is met.

4.03f The assigned NS

& L engineer shall forward a copy of the routing form and a complete copy of the "Action Item" document to the Section/Department Head and/or Plant Manager and/or Construction Manager, for review and work assignment..

The assigned NS 8 L engineer shall be responsible for coordinating all aspects of submittal draft prepaxation by parties outside of AEPSC.

4.03g The assigned NS a L Engineer shall enter or cause to be

entered, the assignment of submittal draft preparation responsibilities into the computerized commitment, program.

4 04 DRAFT SUBMITTAL PREPARATION 4.04a Upon receipt of the documents descxibed in 4.03f above, the Section/Department Head(s) and/or Plant Kanager(s) and/or Constxuction Manager, shall review the'se documents and forward them to the assign'ed Cognizant Engineers and/or other -responsible parties to initiate preparation of the required submittal draft.

4.04b Preparation of draft submittals is a high priority effort.

Parties responsible for draft preparator.on shall assure that their draft meets the requirements of the "Action Item" document and that it is concise and technically complete and accurate.

AEPSC General Procedu No.

32 Rev.

0 Date JUg p y

d

'0 5

AEPSC 4.04c h

- '4.04d h

h

'I GENERAL PROCEDURE NO; "32 (Cont'nued)

The Preparer of a submittal draft shall document any'

~~

criteria, procedures,'echniques, etc. that were estab-lished to obtain information'sed in the preparation of --=

= a submittal draft.

Said documentation shall. be retained in the preparers 'files and be readily retrievable for use during the Verification portions of this procedure.

-=

/

h h

The Preparer of a submittal draft shall complete

.and attach to his draft, a copy of the NRC Submittal. Source

=

Document List, (SSDL)

Form No. GE.56.

The SSDL shall h

I list all of the source documents (information sources)

~,

I

~'

used. by the preparer during the preparation of the draft submittal.

The SSDL will reference each source document to tl'e appropriate sections of the. draft for which it is,

/

a source, the identification -of the source document and Ih its current location.

L' t

.- 4.04e.Upon completion of the preparation of a draft submittal, k

the -preparer shall forward the draft and SSDL. to his

. Section/Department Head for review and approval.

h 05.

SUPERVZSORY REVXEN AND APPROVAL

~

k

'hk h

.:,...4.05a Draft submittals shall be reviewed and approved. by the

/

Preparers Section or Department
Head, as' minimum.

The Section/Department Head shall review the submittal draft:

~ 'o assure that it is technically" accurate and complete, and that where applicable,establishedcriteria were adhered to during preparation of the draft.

'EPSC General Proced No.

32

in accordance with requirements as established by individual AEPSC Division Heads, Plant Manager(s).,

and Site Construction Manager(s).

4.05c Upon completion of the review set forth in 4.05a, the Section/Department Head shall sign and date: the Routing Form in the space provided.

~ '.05d Submittal. drafts originated within AEPSC are to be routed after Supervisory review and approval to the assigned AEPSC NS

& L engineer.

Site originated sub-mittal drafts are to be routed in accordance with Section 4.06 below.

4'6 SITE ORIGINATED DRAFT SUBMITTAL VLRIFICATION 4.06a Draft submittals originated in Plant Operations or Site Construction Departments shall be forwarded to the PNSRC or Site QA Coordinator, as applicable, for verification.

4.06b The PNSRC or Site QA Coordinator or a-designated alternate/

as.applicable,, shall verify that =any criteria, procedures, techniques, etc., established for use during the develop-ment, of the submittal draft were adhered to.

Sufficient review shall be made to assure that the submittal draft is complete and addresses the "Action Item" document, require-

.ments and that'he submittal factually reflects the con-ditions as they exist at the time of verification.

State-ment of actions taken or proposed will be verified to assure that said actions were in fact taken, or that the schedule for implementation of proposed actions is realistic.

AEPSC General Procedure No.

32 Rev.

0 Date Jgg p ~]9

ERAL PROCEDURE NO.

32 (Continued)

~

~

Verification shall be made that the source documents

~ sl listed on the SSDL are readily retrievable and a l

sample checked to assure that the information in said documents was translat'ed correctly in the draft submittal.

4.06c Any anomalies discovered., in the submittal draft during.,

.verification shall be noted on the draft and the draft returned to the responsible supervisor for revision and resubmittal in accordance with Sections 4.05 and 4.06 above.

4.06d PNSRC or Site QA verification shall be indicated by a signature and date in the space provided on the Routing Form.

4.06e Upon completion of PSNRC or Site QA verification, sub-mittal drafts, including SSDL's are to be routed to the assigned AEPSC NS

& L engineer.

4.07 AEPSC NUCLEAR ENGINEERXNG DXVISXON REVIEWS 4.07a The assigned NS

& L engineer 'shall review all submittal drafts and prepare a draft, in proposed final format, for

4. 07b internal Nuclear Engineering Divisi,on review.

Xn the case where the final submittal requires input from several

parties, the NS

& L engineer will prepare a combined sub-mittal draft incorporating all of the involved drafts.

The proposed final submittal draft, including all SSDL's,

~

'hall be routed to the following parties within the Nuclear Engineering Division for review and. approval: AEPSC General Procedure No.

32 Rev.

0 Date

AgPSC GENERAL PROCEDURE NO.

32 (Continued)

~

~

l.

Head, NS

& L Section.

2.

Assistant, Head, Nuclear Engineering Division 3., Chief Nuclear Engineer

'4.07c Once an acceptable, proposed final draft submittal is developed, the draft including all. SSDL's shall be routed to the AEPSC Manager of Quality Assurance for verification.

4.08'EPSC'UALITY ASSURANCE VERIPICATION 4;Osa The AEPSC Manager of,QA, or his designated alternate, shall verify that any criteria, procedures,'echniques, etc., established for use during the development of AEPSC<<originated submittal drafts were adhered to.

Sufficient review shall be made to assure that the draft is complete and addresses the "Action Item" docu-ment requirements; and that the submittal factually re' fleets the conditions as they exist or willexist at the time the submittal is made to the NRC.

Statements of actions taken or proposed will be verified to assure that P

said actions w'ere, in fact> taken, or that the schedule for implementation of proposed action is realistic.

Veri-fication shall be made that the source documents listed on the SSDL, for AEPSC-originated drafts, are readily retrieva and a sample checked to assure that the informatj.on in said documents was translated correctly to the draft submittal.

4.08b Any anomalies discovered in the draft during verification shall be noted on the draft and the draft returned to the assigned NS

& L eng'neer for revision and resubmittal in AEPSC General Proced No.

Rev.

4.08c'AEPSC QA verification shall be indicated by a signature and date in the space provided on the Routing Form.

4 4.08d 'Upon completion of.the AEPSC QA verification, the propose<

final submittal draft shall be routed to the assigned NS

& L engineer.

4.09 FXNAL SUBMITTAL=PREPARATION REVXEN AND TRANSMITTAL TO THE NRC

4. 09a Upon receipt, of the final submittal draft from AEPSC QA, I

the assigned NS

& L engineer shall prepare the submitta1

=

in final format for transmittal to the NRC.

4.09b The assigned'S

& L engineer ~hall assure that the sub-mittal or submittal transmittal. letter bears the same "Action Item", identification number as assigned in Section 4.03c above.

In the case where more than one submittal is transmitted in response to an "Action Item",

the submittals shall bear the-same identifi'cation number and be sequentially suffixed as follows:

Action Item Identification

~

NRC-00001 1st submittal NRC-0000 1A 2nL submittal NRC-000018 a

4.09c The assigned NS

& L engineer shall route the submittal, in final format, as designated on the= Routing Form GE.55.

4.09d. Ea'ch reviewer shall signify his concurrence with the sub-mittal by crossing off his name and signing and dating the form in the space provided. AEPSC General Proce No.

32 Rev.

0 Date

C' Cont nuedt 4.09e Upon comp tion of the revie'w, all submittals, with the exception 'of. submittals to NRC Regional Offices, must il be signed by an Officer of the licensee company and notarized if required.

Submittals to NRC Regional Offices must be signed I

by the AEPSC Senior Executive Vice President Engineeiing or an'fficer of the licensee company.

4.09f The signer of a submittal shall return, the signed submittal to the Head NS

& L" Section.

4.09g The Head, NS

& L shall cause the submittal to be transmitted.

to the NRC, and assure that designated copies are distributed.

4.09h The Head,

-NS

& L shall enter, or cause to be entered, into the commitment'rogram, all commitments made in the sub-5.'00

=. mittal'to the HRC.

PROCEDURE REVISlON

~

~

5.01 AEPSC Quality Assurance shall prepare and issue all revisions

, 5'2 to this procedure.

All revisions go this procedure shall be reviewed by the following:

- AEPSC Nanager of Quality Assurance

- -Head - AEPSC Nuclear Safety and Licensing Section Chief Nuclear Engineer AEPSC Seniog Vice President, Construction AEPSC Sjniqr Executive Vice President, Engineering and approved by:

AEPSC Vice ghairman Engineering and Construction. AEPSC General Procedure No.

Rev.

0

REPSC GENERA+7'ROCEDURE NO;. 32 (Canting) 5.03 All temporary Changes to New Requirements for (interim changes) or Temporary Waiver of and/or part of this procedure shall be made using Form GE.27.E "Procedure Temporary Sheet" and Form GE.27.El - "Procedure Temporary Sheet Continuation".

5.04 All Procedure Temporary Sheets are to be filed with this procedure until such time as they are cancelled, expire or are incorporated into a permanent revision of'his procedure.

5.05 All revisions covered by Procedure, Temporary Sheets, except

, for Temporary Waivers, shall be incorporated into each, permanent revision of this procedure..

AEPSC General Procedur No.

32

~ c HRC 5USMITTAI CKNERATKO BYI

~

IK BULLETIN IK REPORT FSAR CHANGE TECH SPKC. CHAHQK NRC QUESTION VENDOR INFIX tACTION ITEMS)

VERBAL COMMITMENT TO THE NRC AEP5C lIQR Of OA HKAO AEPSC NS& I Bc~ON FOR ASSIGNMENT TO N5 &I ENGINEER OtHERS RKF. 5KCT. 4.OSA QEN. PROC. HO.SB ASSIGN OA KNQINKcct TO FOLLOW NS &L KNGUIKER ASSIGN RESPOHSIBIUTYtSI fOR SUBMITTAL PREPARATION COMMITMKNTPROGRAM ENTRY SUBMITTAI. PREPARATION AEPSC COG. ENGR.

OR CttIKR RKSPCNSIBLc&PARTY SKCTION/OEPT HEAO FOR WORK ASSIGNMENT PLANT MANAGER CONST.

MANAGER lSITE) 0EPT HEAO OEPT HEAO VENOOR AKPSC CCQ.ENGR. ANO/OR OTH&t RESPONSIBLE PARTY PREPARE CRAFT SUBMITTAL{5)

ORAFT SUBMITTAL SUP ERVISORY REVIEW &

APPROVAL ORAFT 5UBMITTAI 5 UP KRVISCRY REVIEW &

APPROVAI.

SUPERVISORY REVIEW &

APPROVAL PN5RC VERI F ICATION SITE OA VERIF ICATION ASSIQIIED NS & L ENGINEER REVIEW d PRKPARK A FINAL SUBMITTAL CRAFT AEPSC NUCLEAR OIVISION RKVIKW ACCEPTABLE FINAL SUBMITTAL CRAFT

~

p" AEP5C OA VKRlfICATION AKP5C NS & L ENGINEER PREPARE SUBMITTAI IN FINAL FORMAT N5 &L UPOATE CCMMITM VT PROGRAM FILE TO INOICATE COMPLETION Of CRAFT SUB4ITTAt PREPARATION & OA VERIFICATION AEPSC LEGAL &

MANAGL4ENT RKVIEW TRANSMIT TO NRC NS &L UP&ATE COMMITMK!IT

~ PROGRAM TO INCLUOE COMMITMKNTS MACK IN SUSMITTAL AEPSC General Procedure No.

32 Rev.

0 Figure No.. l JUz 0-X >

IIRC SUBMITTAL ROUTIHG FOR.'4 CE 55 NRC SUBMITS DUE DATE ACTIOH ITEM IDEHT. NO+

HRC~

SUBJECT DATE ASSIGH:

ASSIGN TO:

HEAD HSCsL DATE REC'D.:

0 G

(

H DRAFT SUBMITTAlPREPARATION ASSIGNMENT BY HSSl ENGINEER ACTION HANK ACTIOH ITEM HAMK NAME ACTION ITEM ASSIGN TO:

SECTION/DEPT, HKAO DATE REC'Oe OATK ASSIGNS E

PHSRC/SITE QA VERIFICATI SUPERVISORY REVIKW 8 APPROVAL SECTION/DEPT+

HEAD SICNATURE DATE DATE OTHER DATE DRAFT RKC'Oo ASSIGNED NSSL ENCR ~

DATE ROUTED FOR NE OIT. RETIE'+

I I

I I"I I

I AEPSC NUCLEAR DIVISION REVIEW.

I. HEAD, HSSL

2. ASST. DIV. HEAD
3. CHIEF NUCLEAR ENGR.

DATE DATE OATK I

I DATE I

0 REVIEW 8 TYPK 0 REVISE. REDRAFT'ESUBMIT DATE DATE ASSICNED NfdL ENCR ~

AEPSC QA VERIFICATIOH 5IG'IATURE DATE REC'0 ~

AEPSC NRG.

OR C*

DATE ROUTED FOR HCT. REVIK*

OATK REC'D ASSIGNED Nfdl.ENGR'.

LEGAI.

AE P5 C MANAGEMENTREVIEW 3

HEAD, HSS L 2; ASST. DIV. HD. HE DIV SIGNATURE DATE DATE SI GNATURE

6. SUBMITTALSIGHATURE R. JOHH E. DOLAH Sl GNATURE DATE II%I TI ALS
3. CHIEFHUCLEAR EHGINEER INITIALS OTHER DATE SI GNATURK
b. OFFICER OF UCEHSEK JOHN TILUNGHAST
4. AEPSC MGR. OF QA DATE SIGNATURE INITIALS OTHER INITIALS OA NOTARY HEAD NfdL AEPSC General Procedi

'No.

32 Figure No.

FII.KNO JUN 0 1 19'ATE OF SUBMITTALLETTER TO HRC

FORM GE~SB

~

4 RRC

. $UBMITTA SOURt'E DOCUMENT IlST

\\ Q ACTlON lTEM IDENT. NO.

THE FOLLOWING OOCUMENTS HAVE BEEN USEO AS SOURCES OF INFORMATION FOR PREPARATION OF THE ATTACNEO NRC SUBMITTAL~

COPIES OF THESE OOCUMENTS ARE AVAILABLE FOR REVIEW AT THE LOCATION SPECI FI EOe SUBMITTALSTATEMENT PAGE 'ARA+

SOURCE DOCUMENT DESCRIPTION ~ TITLE, NUMBER~ RKVISIONt KTC CURRENT SOURCE DOC. LOCATION AEP C General Proc Ho.

32 Figure No.

JUN oa IS-a