ML17321A289

Rev 1 to General Procedure 15.1, Noncompliance & Corrective Action.

ML17321A289
Person / Time
Site:	Cook
Issue date:	10/24/1984
From:	Kroeger R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17321A286	List: ML17321A285 ML17321A289
References
15.1, NUDOCS 8411280300
Download: ML17321A289 (38)

Text

, FaN'N'.aa as AMERfCA ECTRfC POWER SERVfCECO RAT ON GENERAL PROCEDURE CHANGE SHEET CHANGE SHEET NO.PROCEDURE NQ 15.1 TITLE: REVISION NO.Ac on PREPARED BY: REVIEWED BY: M.P.Al exich CONCURRENCE i<A APPFIOVED BY.John E.Ool an DATE~4 DATE: DATE'ATE'ATE'ATE'ATE:

so.G.1 OF1 TYPE OF CHANGE Q PERMANENT CI TEMPORARY EFFECTIVE DATE: 11~9~84 EXPIRATION DATE'ESCRIPTION OF CH'ANGE Added Para.3.5 settin olic on tICR cancellation.

Added Para.3.6 settin olic on re ortin of Electrical Equipment Environmental 1 fica ion deficiencies.

Renumbered existed.ara.3.5&3.6 n d fi iencies to list of t ical rr 1'an es.REASON(S)FOR CHANGE To establish a olic on cancellation of NCRs, and escalation of concerns if they 2.3.To establish a mechanism for compliance with 10CFR50.49.h Revised Para.6.1.1 to add Equipment gualification deficiencies to list of typical ,>liance.INSTRUCTIONS FOR INCORPORATING CHANGE Pa e 1&2 insert ace 1&2 C.S.l.S.3&Pa e 4 insert Pa e 3 C.S.4&Pa e 4 iai.-:>+<>>Bpga<>'4%12'L"":",,)PDg, ADOCK 7588(5 84)IAE FORM NO.GE 38 AMERICAN ELECTRIC POWER SERVICE CORPORATION GEN~L PROCEDURE CHANGE SHE NDEX AEPSC GENERAL PROCEDURE NO.15 1 REV.NO.1 CHANGE SHEET NO.NO.OF PGS.PROCEDURE SECTIONS AFFECTED TEMP.PERM.TYPE OF CHANG DATE EXPIRATION EFFECTIVE DATE 5.1, 9.0 9.0, Attachment No.2 X 09/T 5/84 10/11/84 6.1.1 5), 6.2.3 3.5 (flew), 3.o (New)6.1.1 11 New X 10/5/84 X 11/9/84'PON ISSUE OF NEXT REVISiON OF THE SUBJECT PROCEDURE AEPSC GE5t>AL PROCEDURE NO.15.1 NCNCCMPLIANCE AND CCK&TIVE ACTION 1.0 PKPQSE~4 This procedure establishes the policy and administrative activities for (1)reporting, (2)corrective and (3)establishing measures to preclude the recusance of noncompliance identified within AEPSC.2.0 2.1 2.2 2'.3 This procedure applies to noncanpliances with the QA Program th implenanting activities are under the direct control and responsibility of AEPSC.Managerrant appraisals/evaluations/reviews which identify intra-division findings are exluded from the reporting requireneats of this procedure unless the finding identifies an apparent discrepancy in the design of a system, caiponent or structure which would prevent or degrade systems, ccmgonents or structures fran per forming their design functions.

-'Nonccmpli.an'ces identified'by'audits conducted in accordance'with

" General Procedure 18.1 are excluded from the reporting requirements of this procedure except as noted therein.3.0 3.1 Any activity known or suspected to contain a noncompliance shall be properly identified, reported and corrected, through the use of the Noncompliance Report (NCR).3.2 3.3 Any noncompliance, identified by AEPSC personnel while at the Donald C.Cook Nuclear Plant, shall be reported in accordance with established Plant procechmes.

The intent of this procedure is to provide the basic re~xsnents and directions for noncanpliances identified within AEPSC.It shall be incunhent upon the involved MPSC Division Manager to review this procedure and to assure that, when necessary, additional procedures are developed for the respective Division to fully implerrent the 3.4 Any individual in AEPSC can originate an NCR.If a member of a sec-tion is the originator, the Section Manager shall sign the NCR to authorize its issuance and confirm that the appropriate person is being assigned the corrective action.Nhere the originator is the Section Manager, only this Manager's signature is reguum2 for issuing~AEPSC General Procedure No.15.1-Rev.1 Page 1 of 11 3.5 Once an NCR has been initiated, it cannot and shall not be cancelled without due cause., Such cause shall be documented either on the NCR.itself, or in a separate memo, and a copy of said documentation for-warded to the AEPSC Manager of Quality Assurance.

The Originator of a cancelled NCR has the obligation and right to escalate his concern to successive levels of management if he feels that a quality related problem still exists, after NCR cancellation.

CS 4 3.6 Deficiencies in electrical equipment environmental qualification shall be documented via an NCR with a mandatory response due 30 days from date of NCR issue.When applicable, such deficiencies shall be reported to the NRC within sixty days of discovery per 10CFR50.49h.

CS 4 3.7 All AEPSC Personnel share equally in the obligation and responsibil-ity to report and identify noncompliances.

3.8 Departures from this procedure shall not be made without the express wzitten consent of the AEPSC Vice Chairman, Engineering and Construction.

4.0 DEFINITIONS 4.1.does not provide'suitable

'direction to mee't establi'shed'requKze-

"'ents.Deficiencies occur where documentation is nonexistent, in-adequate or incorrect.

4.2 4.3 Deviation-An inadequacy in the implementation of an established procedure.

Deviations occur where documentation is correct, ade-quate and acceptable but the implementing organization doers not adhere to the specified directions.

further evaluation.

4.4 procedure or method;or a discrepancy in the design of a system, component or structuze which would prevent or degrade systems, components or structures from performing their design functions.

4.5 Commitment List-A list of promised actions by AEPSC organizations/

personnel that is prepared and maintained in accordance with General Pzocedure No.2.2.4.6 noncompliance.

4.7~Res ender-Person to whom a Noncompliance Report (NCR)is addressed and/or who replies to the NCR originator.

4.8 Software-Documentation or paperwork.

AEPSC General Procedure No.15.1-Rev.1 C.S.4 Page 2 of 11 5.0 5.1 5.2 5.3 5.4 HESPCNSXSILITIES f~'1"!the caaplete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

Qri inator's Section Mana er-Confirms the need to proceed and assures NCR is assigned to appropriate individual or organization.

Responder-The person to whom the NCR is sent.This person is responsible for the preparation of a neaningful, clear response to the Qriginator as well as accarplishing other taslm defined in this pvxxKlure o Re nder's Section Mana er-Authorities corrections to be made.5.5 5.6 NS&L-Responsible for indicating reportability of NCR finding and for performing reporting functions when applicable.

Qualit Assurance-Responsible for maintaining Camnitment List;auditing AEPSC OH ox~zation for caapliance with this procedure; and verifying that preventive measures have succeeded.

6.0'C5CCHPLIANCE'RCCEDURE"'~~6.1 6.1.1 6.1.2 Noncanpliances, typically, include: (1)failure to perform prescribed verification activities; (2)departure.

or inacbn~nt omission fran approved procedure specifications, drawings, etc.;(3)calculational logic or technical docunant error;(4)error in procedural docunant;(5)failure to have adequate or required procedures;

{6)failure to transcribe activities affecting quality into written docunents.

(7)a group of nonconformances that s~a trend requiring correction; P (9)erroneous entry in supplier's docunantation'10) documentation incomplete, missing or illegible.

{11)equipment qualification deficiencies A graphic presentation of the noncompliances cycle is shown in Attache 1.[cs s AEPSC General Procechxre No.15.1-Rev.1-C.S.4 Page 3 of 11 6.1.3 6.2 6.2.1 6.2.2 Noncompliances identified within AEPSC shall be processed j.n accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-cessed under the AEP approved Supplier QA program.AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncompliance (Ori inator)Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance with the instruction on its reverse side.(Ref.Attachment 2).The NCR numbex consists'of four parts as follows:~'I RQA-81-4 9-1 W"-l" is always used in the preparation of an NCR.The-1 designation will be.changed only after one ox more'commitments are made in response to the NCR.If one commitment is made, this part of the number changes to"Cl" from"-1".If two or more commitments are made, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality, Assurance.

To create this part of the NCR number always start with the letter"R" then add the appropriate suffix from the listing below.AEPSC General Procedure.

No.15.1-Rev.1 Page 4 of ll FoA4 N(k GE 35 758 5 84 IAE AMERICA ECTRtC POWER SERVl E CO RATt N GENERAL PROCEDURE CHANGE SHEET CHANGE SHEET NO.PROCEDURE NO.TITLE'EVISION NO.A'on PG 1 OF1 PREPARED BY:~F REVIEWED BY M.P.Alexich CONCURRENCE'PPROVED BY: DATE: DATE: DATE: DATE: DATE'ATE'ATE.

I 0 TYPE OF CHANGE Q PERMANENT Cl TEMPORARY EFFECTIVE DATE 11/9/84 EXPIRATION DATE"'DESCRIPTION'O'F CHA'NGE Added Para.3.5 settin ol ic on WCR canc'ellation.

Added Para.3.6 settin olic on re ortin of Electrical Equipment Environmental 1'fication deficiencies.

Renumbered existed ara.3.5&3.6'd fi iencies to list of t ical i l ian es.REASON(S)FOR CHANGE To establish a olicy on cancellation of NCRs, and escalation of concerns if they 2.3.To establish a mechanism for compliance with 10CFR50.49.h Revised Para.6.1.1 to add Equipment (}ualification deficiencies to list of typical moliances.

INSTRUCTIONS FOR INCORPORATING CHANGE Pa e&2 insert ace 1&2 C.S.1.S.3&Pa e 4 insert Pa e 3 C.S.4&Pa e 4 758@5 84)I AE FORM NO.GK 38 AMERICAN ELECTRIC POWER SERVICE CORPORATION GEN a L PROCEDURE CHANGE SHE NDEX AEPSC GENERAL PROCEDURE NO.15 1 REV.NO.1 CHANGE SHEET NO.NO.OF P GS.PROCEDURE SECTIONS AFFECTED TYPE OF C ANG TEMP.PERM.DATE EFFECTIVE EXP I RATION DATE 5.1, 9.0 9.0, Attachment No.2 X 09/15/84 10/11/84 6.1.1 5), 6.2.3 3.5 (IIew), 3.6 (Hew)6.1.1 11 I'Iew X 10/5/84 ll/9/84~~'PON ISSUE OF NEXT REVISION OF THE SUBJECT PROCEDURE MK'SC GENERAL PROCEDURE NO.15.1 XNKTAtXZ 1.0 PURPOSE This procedure establishes the policy and administrative activities for (1)reporting, (2)conative and (3)establishing measures to preclude the recurrence of noncompliance identified within AEPSC.2.0 2.1 2.2 This procedure applies to nonccmpliances with the QA Program mquirenents of M~C General Procedure No.2.1 while the implementing activities are under the direct control and responsibility of AEPSC.Management appraisals/evaluations/reviews which identify intra-division findings are exluded from the reporting requirements of this procedure unless the finding identifies an apparent discrepancy in the design of a system, cm~nent or structure which would prevent or degrade systems, components or structures fran per forming their design functions.

2;3"'Noncanpli'ances identified by audits"conduct&in'ccordance with'.General Procedure 18.1 are exclu~from the reporting requirem nts of this procedure except as noted therein.3.0 3.1 Any activity known or suspected to contain a noncompliance shall be properly identified, reported and corrected, through the use of the Noncanpliance Report (NCR).3.2 Any noncompliance, identified by AEPSC personnel while at the Donald C.Ccok Nuclear Plant, shall be reported in accordance with established Plant procedures.

3.3 The intent of this procedure is to provide the basic requirements and directions for noncanpliances identified within AEPSC.It shall be incumbent upon the involved AEPSC Division Manager to review this procedure and to assure that, when necessary, additional procedures are developed for the respective Division to fully implement the I 3.4 Any individual in AEPSC can originate an NCR.If a nember of a sec-tion is the originator, the Section Manager shall sign the NCR to authorize its issuance and confirm that the appropriate person is being assigned the corrective action.Where the originator is the Section Manager, only this Manager's signature is required for 3.SSQLIlg, AEPSC General Procedure No.15.1-Rev.1 Page 1 of 11 3.5 Once an NCR has been initiated, it cannot and shall not be cancelled without due cause.Such cause shall be documented either on the NCR itself, or in a separate memo, and a copy.of said documentation for-CS 4 warded to the AEPSC Manager of.Quality Assurance.

The Originator of a cancelled NCR has the obligation and right to escalate his concern to successive levels of management if he feels that a quality related problem still exists, after NCR cancellation.

3.6 Deficiencies in electrical equipment environmental qualification shall be documented via an NCR with a mandatory response due 30 days from date of NCR issue.When applicable, such deficiencies shall be reported to the NRC within sixty days of discovery per 10CFR50.49h.

CS 4 3.7 3.8 All AEPSC Personnel share equally in the obligation and responsibil-ity to report and identify noncompliances.

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

4.0 DEFINITIONS

.4..1 h 4.2 does not prov'ide"suieable direction tomeet established require-ments.Deficiencies occur where documentation is nonexistent, in-adequate or incorrect.

Deviation-An inadequacy in the implementation of an established procedure.

Deviations occur where documentation is correct, ade-quate and acceptable but the implementing organization does not adhere to the specified directions.

further evaluation.

4,4 Noncomoliance'-

A deviation from, or deficiency in, an approved procedure or method;or a discrepancy in the design of a system, component or structure which would prevent or degrade systems, components or structures from performing their design functions.

4.5 Commitment List-A list of promised actions by AEPSC organizations/

personnel that is prepared and maintained in accordance with General Procedure No.2.2.4.6 noncompliance.

4'~Res ender-Person to whom a Noncompliance Report (NCR)is addressed and/or who replies to the NCR originator.

4.8 Software-Documentation or paperwork.

AEPSC General Procedure No.15.1-Rev.1 C.S.4 Page 2 of ll 5.0.5.1 the complete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

5.2 5.3 Ori inator's Section Mana-Confirms the need to proceed and assures NCR is assigned to appropriate individual or organization.

I Resider-The person to whom the NCR is sent.'1M.s person is responsible for the preparation of a meaningful, clear response to the Originator as well as accarplishing other tasks defined in this procedure.

5.4 Re nder's Section Mana er-Authorities corrections to be made.5.5 NSSZ-Responsible for indicating reportability of NCR finding and for perfoxming reporting functions when applicable.

5.6 6.0 Qualit Assurance-Responsible for maintair~g Gxmitment List;auditing AKPSC CH organization for ccxnpliance with this procedure; and verifying that preventive measures have succeechd.

NCNCCN?LIAl'KZ'RCCEOUBE 6.1 6.1.1 6.1.2 General Noncanpliances, typically, include: (1)failure to perform prescribed verification activities; (2)departure or inadvertent omission fran approved procedure specifications,*drawings, etc.;(3)calculational logic or technical doc+rent error;(4)error in procedural docunent;(5)failure to have adequate or required pxocedures; (6)failure to transcxibe activities affecting quality into written donm~ts;(7)a group of nonconfoxmances that show a trend requiring correction; (8)supplier's report does not address requirements; (9)erroneous entry in supplier's documentation'10) documentation inccxnplete, missing or illegible.

(11)equipnent qualification deficiencies A graphic presentation of the noncompliances cycle is shown in Attachnent 1.[cs z AEPSC General Pxocedure No.15.1-Rev.1-C.S.4 Page 3 of 11 6.1.3 6.2 6.2.1 6.2.2 Noncompliances identified within AEPSC shall be processed in accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-cessed under the AEP approved Supplier QA program.AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncom liance (Ori inator)Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance with the instruction on its reverse side.(Ref.Attachment 2).The NCR number consists of four parts as follows: RQA-81-, 4 9-1~"-l" is always used in the ptepasation of an NCR.The-1 designation will be changedonly after one or more commitments are made in response to the NCR.Xf one commitment is made, this part of the number changes to"Cl" from"-1".If two or more commitments are made, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality Assurance.

To create this part of the NCR number always start with the letter"R" then add the appropriate suffix from the listing below.AEPSC General Procedur~No.15.1-Rev.1 Page 4 of ll 7589(S 841IAE FORM NO.OE 35 AMERlCA LECTRIC POWER SERY)CE CO ORATION GENERAL PROCEDURE CHANGE SHEET CHANGE SHEET NO.PROCEDURE NO.15 1 TITLE: REVISION NO 1 A ion PG.1 OF1 PREPARED BY: F REVIEWED BY: CONCURRENCE.

iI A APPROVED BY: DATE'ATE'ATE'ATE'ATE:

DATE: DATE: I o TYPE OF CHANGE Q PERMANENT CI TEMPORARY EFFECTIVE DATE: EXPIRATION DATE: DESCRIPTION OF'CHANGE'dded Para.3.5 settin olic on NCR cancellation.

Added Para.3.6 settin olic on re ortin of Electrical Equipment Environmental 1 fication deficiencies.

Renumbered existed ara.3.5&3.6 n d fi iencies to list of t ical 11 l anc s.REASON{S)FOR CHANGE To establish a: olic on cancellation of tICRs, and escalation of concerns if they 2.3~To establish a mechanism for compliance with 10CFR50.49.h Revised Para.6.1.1 to add Equipment gualification deficiencies to list of typical n.1ol'ances.

INSTRUCTIONS FOR INCORPORATIN'G CHANGE Pa e 1&2 insert oaoe 1&2 C.S.1.S.3&Pa e 4 insert Pa e 3 C.S.4&Pa e 4 75805 84)IAE FORM NO.QB 38 AMERICAN ELECTRIC POWER SERVICE CORPORATION GEN L PROCEDURE CHANGE SHEL.NDEX AEPSC GENERAL PROCEDURE NO.15.1 REV.NO.I CHANGE SHEET NO.NO.OF PGS.PROCEDURE SECTIONS AFFECTED TYPE OF=CHANG TEMP.PERM.DATE EFFECTIVE EXPIRATION DATE 5.1, 9.0 X 09/1 5/84 9.0, Attachment No.2 10/11/84 6.1.1(5), 6.2.3 3.5 (I'ew), 3.6 (New)6.1.1 11 I'Iew 10/5/84 X 11/9/84~~'PON ISSUE OF NEXT.REVISION OF THE SUBJECT PROCEDURE AEPSC GENERAL PEKCEDUHE NO.15.1 NCNCCM?LIANCE AND CCK~ZVE ACTICN 1.0 PURPOSE This procedure establishes the policy and achunistrative activities for (1)reporting, (2)corrective and (3)establishing measures to preclude the rectu~ce of noncampliance identified within AEPSC.2.0 APPLICABILITY 2.1 This procedure applies to noncaapliances with the QA Pxogram!!., M!!'implenenting activities aze under the direct control and'esponsibility of AEPSC.2.2 Management appraisals/evaluations/reviews which identify intra-division findings are exluded from the reporting xequi~nents of this procedure unless the findling identifies an apparent discrepancy in the design of a system, cmponent or structure which would prevent or degrade systems, ccxaponents or structures fran per forming their design functions.

2.3'Non'ccxrpliances'.

identified by audi.ts conducted in:acco69ahce'ith

!~W of this procedure except as noted therein.~~~3.0 3.1 Any activity known or suspected to contain a noncompliance shall be properly identified, reported and corrected, through the use of the Noncanpliance Report (NCR).3.2 Any nonccmpliance, identified by AEPSC personnel while at.the Donald C.Cook Nuclear Plant, shall be reported in accordance with established Plant procedures.

3.3 The intent of this procedure is to provide the basic requirements and directions for noncampliances identified within AEPSC.It shall be incumbent upon the involved AEPSC Division Manager to review this procedure and to assure that, when necessaxy, additional procedures are developed for the respective Division to fully implement the requirements of this procedure.

3.4 Any individual in AEPSC can originate an NCR.If a manber of a sec-tion is the originator, the Section Manager shall sign the NCR to authorize its issuance and confirm that the appropriate person is being assigned the corrective action.Nhere t1a originator is the Section Manager, only this Manager's signature is required for 1SSllkllg.

AEPSC General Procedure No.15.1-Rev.1 Page 1 of 11 3.5 Once an NCR has been initiated, it cannot and shall not be cancelled without due cause.Such cause shall be documented either on the NCR itself, or in a separate memo, and a copy of said documentation for-CS 4 warded to the AEPSC Manager of Quality Assurance.

The Originator of a cancelled NCR has the obligation and right to escalate his concern to successive levels of management if he feels that a quality related problem still exists, after NCR cancellation.

3.6 Deficiencies in electrical equipment environmental qualification shall be documented via an NCR with a mandatory response due 30 days from date of NCR issue.When applicable, such deficiencies shall be CS 4 reported to the NRC within sixty days of discovery per 10CFR50.49h.

3.7 All AEPSC Personnel share equally in the obligation and responsibil-ity to report and identify noncompliances.

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

4.0 DEFINITIONS

~4..1.Deficienc.-,An inadequacy,, in a.procedure or its methodology.

which oes not provide suitable di'r'ection to meet established require-ments.Deficiencies occur where documentation is nonexistent, in-adequate or incorrect.

4.2 Deviation-An inadequacy in the implementation of an established procedure.

Deviations occur where documentation is correct, ade-quate and acceptable but the implementing organization does not adhere to the specified directions.

4,3 further evaluation.

4.4*procedure or method;or a discrepancy in the design of a system, component or structure which would prevent or degrade systems, components or structures from performing their design functions.

4.5 Commitment List-A list of promised actions by AEPSC organizations/

personnel that is prepared and maintained in accordance with General Procedure No.2.2.4.6 noncompliance.

4'~Res ender-Person to shorn a Noncompliance Report (NCR)ls addressed and/or who replies to the NCR originator.

4.8 Software-Documentation or paperwork.

AEPSC General Procedure No.15.1-Rev.1 C.S.4 Page 2 of 11 5.0 5.1 5.2 RESPONSIBILITIES w 9>>tl d the canplete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

Ori inator's Section Mana-Confirms the need to proceed and assures NCR is assigned to appropriate individual or organization.

5.3 5.4 MsSxinder-The person to whcxn the NCR is sent.This person is responsible for the preparation of a aeaningful, clear response to the Originator as well as acccaplishing other tasks defined in this procedure.

Re nder's Section Mana er-Authorities corrections to be made.5.5 NSaL-Responsible for indicating reportability of NCR finding and for performing reporting functions when applicable.

5.6 Qualit Assurance-Responsible for maintair~Caanitment List;auditing AEPSC OH organization for canpliance with this procedure; and verifying that preventive neasures have succeeded.

6.0'CNCCbPL'IANCE'RCC{K)URE

'eneral 6.1.1 Noncanpliances, typically, include: 6.1.2 (1)failure to perform prescribed verification activities; (2)departure or inadvertent omission fran approved procedure specifications, drawings, etc.;(3)calculational logic or technical document error;(4)error in procedural docunent;(5)failure to have adequate or required procedures; (6)failure to transcribe activities affecting quality into written docungnts;

'7)a group of nonconformances that show a trend requiring correction; (8)supplier's report does not address requirements; (9)erroneous entry in supplier's documentation'10) docunentation incanplete, missing or illegible.

(11)equipnent qualification deficiencies A graphic presentation of the nonccmpliances cycle is shown in Attachment 1.[cs~AEPSC General Procechxre No.15.1-Rev.1-C.S.4 Page 3 of 11 6.1.3 6.2 6.2.1 6.2.2 Noncompliances identified within AEPSC shall be processed in accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-cessed under the AEP approved Supplier QA program.AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncompliance (Ori inator)Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance-with the instruction on its reverse side.(Re f.Attachment 2).The NCR number consists of four parts as follows:~~RQA-81-4 9-1 M"-l" is always used in the preparation or an NCR.The-1 designation will be.chagged l~~~~only after one or more c'ommit'ments are made in response to the NCR.If one commitment is made, this part of the number changes to"Cl" from"-1".If two or more commitments are made,, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality Assurance.

To create this part of the NCR number always start with the letter"R" then add the appropriate suffix from the listing below.AEPSC General Procedure-'o.

15.1-Rev.1 Page 4 of ll

~V 8>>M V I>>~Y>>EY~4/8 t CONTROLLO DOCUMENT TRANSMITTAL ACIIIILEDGEMENT TO: NRC, Bethesda gA FILE NO>>.'G00002 PATE 10/05/84 CONTROLLED COPY NO.: THIS IS TO ACKNOWLEOGK RECEIPT OF THE CONTROLLED OOCUMKNT ISSUE PACKAGE CONSISTING OF THE FOLLOWING:

DOCUMENT TITLE n ral Pro edure Chan e Sheet No.3 for G.P.15.1 Noncompliance and Corrective Action CDAL: REY.NO.---DATE: 08-16-83 THIS ISSUE IS: Q ORIGINAL ISSUE dI PARTIAL REVISIOK Q RE~ISSUE OF COMPLETE DOCUMENT WITH REVISIONS QA-10-84:~5: 002: ,.4<<: 08.28 84 QA-10-84 OCN: G00002 qA FILE NO: G00002 DOCUMENT TITLE I 4 TRIS ISSUE IS: Q ORIGINAL ISSUE Q PARTIAL REVISION Q RE>>ISSUK OF COMPLETK OOCUMEHT WITH REVISIONS REY.NO.DATE:~OCN: CORAR: REV NO.DATE: COAL: REY>>NO.DATE: OCN'A FILE NO'OCUMENT TITLE THIS ISSUE IS>>Q ORIGINAL ISSUE Q PARTIAL REVISION Q RE>>ISSUE OF COMPLETE DOCUMENT WITH REVISIONS REY.NO.DATE: COAL: REY.NO.DATE: OCN'CN: CORAR: REV..NO.DATE: gA FILE NO: RECEIPT ACKNOWLEDGEMENT SIGNATURE:

DATE: REGISTERED HOLDER RETURN TO:~D i er l Riverside Pleze ORIGINATOR ROOM NO: 20th Eloor (AEPSC Qh) 1~4 y"I r

>>Q~'~g" AMERIC ELECTRIC POWER SERVICE C ORATI N GENERAL PROCEDURE CHANGE SHEET CHANGE SHFET NO.3 PROCEDURE NO.TITLE'REPARED BY: REVIEWED BY: CONCURRENCE'PPROVED BY: 'R F'<roe er REVISION NO.DATE'ATE'ATE'ATE'ATE'ATE'ATE'G.1 OF1 TYPE OF CHANGE K PERMANENT CI TEMPORARY EFFECTIVE DATE'XPIRATION DATE;DESCRIPTION OF CHANGE Correct t o ra hical error in section 6.1.1(5)Change Sheet No.1 R i ection 6.2.3 to rovide or anizational codes for the NSDRC Subcommittee and correct for or anizational chan es.REASON(S)FOR CHANGE INSTRUCTIONS FOR INCORPORATING CHANGE 0 4 f C.S.3 Remove a e 5 and 6 of 11 75545 54RAE FORM NO.GE 38 AMERIC ELECTRIC POWER SERVICE CORPORATION GENERAL PROCEDURE CHANGE SHE INDEX AEPSC GENERAL PROCEDURE NO.15 1 REV.NO.1 CHANGE SHEET NO.NO.OF.PGS.PROCEDURE SECTIONS AFFECTED TYPE OF CHANGE TEMP.PERM.DATE EFFECTIVE EXPIRATION DATE 5.1, 9.0 9.0, Attachment t~o.2 09/15/84 10/11/84 6.1.1 5), 6.2.3 10/5/84'PON ISSUE OF NEXT REVISION OF THE SUBJECT PROCEDURE 5.0 RESPONS I 8 IL I TIES 5.1 5.2 5.3 5.4 Ori inator-Responsible for the determination of the need for and t e comp ete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

Ori inator's Section Mana er-Confirms the need to proceed and assures>s assigne to appropriate individual or organization.

Res onder-The person to whom the NCR is sent.This person is response le for the preparation of a meaningful, clear response to the Originator as well's accomplishing other tasks defined in this procedure.

Res onder's Section Mana er-Authorities corrections to be made.5.5 5.6 NS&L-Responsible for indicating reportability of NCR finding and 7or performing reporting functions when applicable.

ualit Assurance-Responsible for maintaining Commitment List;au iting EPSC H organization for compliance with this procedure; and verifying that preventive measures have succeeded.

'6.0NONCOMPLIANCE'PROCEDURE

"'.1 General 6.1.1 Noncompliances, typically, include: (1)failure to perform prescribed verification activities; (2)departure or inadvertent omission from approved procedure specifications, drawings, etc.;(3)calculational logic or technical document error;(4)error in procedural document;(5)failure to have adequate or reouired procedures; (6)failure to transcribe activities affecting quality into written documents; (7)a group of nonconformances that show a trend requiring correction; (8)supplier's report does not address requirements; (9)erroneous entry in supplier's documentation' 10)documentation incomplete, missing or illegible.

A graphic presentation of the noncompliances cycle is shown in Attachment 1.AEPSC General Procedure No.15.1-Rev.1-C.S.3 Page 3 of 11 6.1.3 6.2~1 6.2.2 Noncompliances identified within AEPSC shall be processed in accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-.cessed under the AEP approved Supplier QA program..AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncompliance (Ori inator)Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance with the in'struction on its reverse side.(Ref.Attachment 2).The NCR number consists of four parts as follows:~~RQA-81-4 9-1~"-1" is always used in the preparation of an NCR.The-1 designation will be changed'"'onl'y"afterone or'or'" commitments are made in response to the NCR.If one commitment is made, this part, of the number changes to"Cl" from"-1".I f two or more commitments are made, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality Assurance.

To create this part of the NCR numbei always start with the letter"R" then add the appropriate suffix from the listing below.AEPSC General Proceduz No.15.1-Rev.1 Page 4 of ll 6.2.3/Codes for other organizations are as follows: CE-Civil Engineering Div.CH-Chemical Engineer ing Sec.00-Design Div.DA-00/Architectural Sec.DC-DD/Control Services Sec.DE-00/Electrical Sec.DM-DD/Mechanical Sec.DS-00/Structural Sec.EE-Electrical Engin.EV-Environmental Div.FP-Fire Protection HP-Heat Ex.&Pumps HV-Heating and Venti 1.IC-Instru.and Control ME-.Mechanical Eng.Staff MH-Materials Handling Sec.NC-NSDRC NE-Nuclear Operations Div.NF-Nuclear Materials&Fuel Management Sec.NL-Nuclear Safety&Licensing NO-Nuclear Operations Sec.NR-Radiological Support Sec.PR-Purchasing Department PV-Piping and Valves Sec.gA-guality Assurance SA-Subcommittee on Audit SC-Subcom.on Proposed Changes SE-Subcom.on Security&Emergency Plan SO-Subcom.on Corp.&Plant Occurrences TB-Turbine Section 6.2.4 Each AEPSC organization shall establish the methods to control unique assignment of numbers to each NCR prepared.6.3'Evaluation

'es onder: 6.4 An evaluation sha11 be conducted by the Responder to determine the cause of the noncompliance.

The cause shall be entered on the NCR.The evaluation shall be of sufficient depth so as to develop meaningful corrective and preventive measures based on the cause.Classification (Res onder)6.4.1 The Noncompliance shall be classified for two different features: Type of Noncompliance (deficiency/deviation);

and Reportability of Noncompliance.

Type of Noncompliance:

The Responder shall determine ard indicate on the NCR the type of Noncompliance based on the evaluation performed in paragraph 6.3 above.The noncompliance shall be either a deficiency or deviation as defined in section 4.0 above.6.4.2 Reportabi lity of Noncompliance:

The Responder shall interface with the Nuclear Safety and Licensing Section of the Nuclear Engineering Division (NS&L)and obtain a'lassification of reportabi lity for the noncompliance.

The NS&L assigned classifier shall initiate AEPSC General Procedure No.15.1-Rev.1 C.S.3 Page 5 of 11 4.4.2 (continued)

~reporting activities as required, independent of any action related to the NCR being processed as follows: (1)LER/SPECIAL REPORT-Notify Donald C.Cook Nuclear Plant, Plant Manager immediately by telephone and-follow up by sending a copy of NCR to the Plant Manager.(2)10CFR Part 21-Direct the responder, by letter, to initiate a Part 21 Package in accordance with General Procedure No.31.Follow up by sending a copy of the NCR and letter to the AEPSC Manager of QA for inclusion of this direction as a commitment on the AEPSC Commit-6.5 6.5 II()6.5 6,5 6.5 ment List.(3)OTHER-Initiate, coordinate and perform the action necessary to assure that appropriate reporting require-..,.......:ments.are,.fulf il.led, Disposition (Responder)

The Responder shall identify measures to both: (a)remove the noncompliance; and (b)preclude recurrence of the noncompliance.

.1 Removal of a deficiency type noncompliance shall be accom-plished by revising the associated document(s) or creating a new document(s).

.2 Removal of a deviation type noncompliance shall be accom-plished by the implementing organization enforcing existing documentation and, where necessary, by addition of special measures (e.g.additional surveillance activities; addi-tional and/or more frequent inspections; personnel training;etc.)..3, Preventing recurrence shall be accomplished by removing the.identified cause of the noncompliance.

.4 The Responder's supervisor shall approve the disposition to authorize its implementation.

AEPSC General Procedure No.15.1-Rev.1 Page 6 of 11 75 5'84 fAE Fo RAN N(k GE 35 AMERICELECTRIC POWER SERVI E C ORATI N GENERAL PROCEDURE CHANGE SHEET CHANGE SHEET NO.3 PROCEDURE NO.TITLE: 'REVISION NO.PG.1 OF1 PREPARED BY: REVIEWED BY: CONCURRENCE APPROVED BY: R.F.'<roe er DATE'ATE'ATE'ATE'ATE'ATE:

PATE F X5 8'+TYPE OF CHANGE Kl PERMANENT CI TEMPORARY EFFECTIVE DATE'XPIRATION DATE.DESCRIPTION OF CHANGE Correct t o ra hical error ia section.6.1..1(5)

Change Sheet l<o.1 i section 6.2.3 to rovide or anizational codes for the NSDRC Subcommittee and correct for or anizational chan es.o REASON(S)FOR CHANGE INSTRUCTIONS FOR INCORPORATING CHANGE n 4 f C.S.3 ReIaove a e 5 and 6 of 11 755%5 54)IAE FOAM NO.QE Qd AMERIC ELECTRIC POWER SERVICE CO PORATION GENE RAL PROCEDURE CHANGE SHE INDEX AEPSC GENERAL PROCEDURE NO.15 1 REV.NO.1 CHANGE SHEET NO.NO.OF~PGS, PROCEDURE SECTIONS AFFECTED TEMP.PERM.TYPE OF CHANGE DATE EF F ECTIVE EXPIRATION" DATE 5.1, 9.0 9.0, Attachment No.2 09/15/84 10/ll/84 1 6.1.1(5), 6.2.3 10/5/84 E UPON ISSUE OF NEXT REVISION OF THE SUBJECT PROCEDURE 5.0 RESPONSIBILITIES 5.1 5.2 5.3 5.4 Ori inator-Responsible for the determination of the need for and t e comp ete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

Ori inator's Section Nana er-Confirms the need to proceed and assures ss asssgne to appropriate individual or organization.

Res onder-The person to whom the NCR is sent.This person is response le for the preparation of a meaningful, clear response to the Originator as well as accomplishing other tasks defined in this procedure.

Res onder's Section Mana er-Authorities corrections to be made.5.5 5.6'6.0 NShL-Responsible for indicating reportability of NCR finding and 7or performing reporting functions when applicable.

ualit Assurance-Responsible for maintaining Commitment List;au iting PSC H organization for compliance with this procedure; and verifying that preventive measures have succeeded.

'NONCOMPLIANCE'PROCEOURE

6.1 General 6.1.1 6.'1.2 Noncompliances, typically, include: (1)failure to perform prescribed verif'.cation activities; (2)departure or inadvertent omission from approved procedure specifications, drawings, etc.;(3)calculational logic or technical document error;(4)error in procedural document;(5)failure to have adequate or required procedures; (6)fai lure to transcribe activities affecting quality into written documents; (7)a group of nonconformances that show a trend requiring correction; (8)supplier's report does not address requirements; (9)erroneous entry in supplier's documentation'10) documentation incomplete, missing or illegible.

A graphic presentation of the noncompliances cycle is shown in Attachment I.Ic.s.3 AEPSC General Procedure No.15.1-Rev.1-C.S.3 Page 3 of 11 6.1.6.2 6,2~3 Noncompliances identified within AEPSC shall be processed in accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-.cessed under the AEp approved Supplier QA program.AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncompliance (Ori inator)1 Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance with the instruction on its reverse side.(Ref.Attachment 2).6.2.2 The NCR number consists of four parts as follows: RQA-81-4 9-1~"-1" is always used in the preparation of~an NCR.The-1 designation will be changed only after'ne or more commitments are made in response to the NCR.Ef one commitment is made, this part of the number changes to"Cl" from"-1".Ef two or more commitments are made, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality Assurance.

To create this part of the NCR number always start with the'let'ter"R" then add the appropriate suffix from the listing below.AEPSC General Procedur No.15.1-Rev.1 Page 4 of ll 6.2.3 Codes for other organizations are as follows: CE-Civil Engineering Div.CH-Chemical Engineering Sec.OD-Design Div.OA-00/Architectural Sec.OC-00/Control Services Sec.DE-00/Electrical Sec.DM-DD/Mechanical Sec.DS-DD/Structural Sec.EE-Electrical Engin.EV-Environmental Div.FP-Fire Protection HP-Heat Ex.&Pumps HV-Heating and Ventil.?C-Instru.and Control ME-Mechanical Eng.Staff MH-Materials Handling Sec.NC-NSORC NE-Nuclear Operations Div.NF-Nuclear Materials&Fuel Management Sec.NL-Nuclear Safety&Licensing NO-Nuclear Operations Sec.NR-Radiological Support Sec.PR-Purchasing Department PY-Piping and Valves Sec.gA-guality Assurance SA-Subcommittee on Audit SC-Subcom.on Proposed Changes SE-Subcom.on Security&Emergency Plan SQ-Subcom.on Corp.&Plant Occurrences T8-Turbine Section 6.2.4 6.'3" 6.4 Each AEPSC organization shall establish the methods to control unique assignment of numbers to each NCR prepared.'fialuation

'(Res ohder An evaluation shall be conducted by the Responder to determine the cause of the noncompliance.

The cause shall be entered on the NCR.The evaluation shall be of sufficient depth so as to develop meaningful corrective and preventive measures based on the cause.Classification (Res onder)6.4.1 The Noncompliance shall be classified for two different features: Type of Noncompliance (deficiency/deviation);

and Reportability of Noncompliance.

Type of Noncompliance:

The Responder shall determine and indicate on the NCR the type of Noncompliance based on the evaluation performed in paragraph 6.3 above.The noncompliance shall be either a deficiency or deviation as defined in section 4.0 above..6.4.2 Reportabi lity of Noncompliance:

The Responder shall interface with the'uclear Safety and Licensing Section of the Nuclear Engineering Division (NS&L)and obtain a classification of reportability for the noncompliance.

The NS&L assigned classifier shall initiate AEPSC General Procedure No.15.I-Rev.1 C.S.3 Page 5 of ll 6.4.I (continued) 6 5 6.5.1 6.5.2 6.5.3 6.5a4 reporting activities as required, independent of any action related to the NCR being processed as follows: (1)LER/SPEC1AL REPORT-Notify Donald C.Cook Nuclear Plant, Plant Manager immediately by telephone and follow up by sending a copy of NCR to the Plant Manager.(2)10CFR Part 21-Direct the responder, by letter, to initiate a Part 21 Package in accordance with General Procedure No.31.Follow up by sending a copy of the NCR and letter to the AEPSC Manager of QA for inclusion of this direction as a commitment on the AEPSC Commit-ment List.(3)OTHER-Initiate, coordinate and perform the action necessary to assure that appropriate reporting require-ments are fulf illed.Disposition (Responder)

The Responder shall identify measures to both: (a)remove the noncompliance; and (b)preclude recurrence of the noncompliance.

Removal of a deficiency type noncompliance shall be accom-plished by revising the associated document(s) or creating a new document(s).

Removal of a deviation type noncompliance shall be accom-plished by the implementing organization enforcing existing documentation and, where necessary, by addition of special measures (e.g.additional surveillance activities; addi-tional and/or more frequent inspections; personnel training;etc.).Preventing recurrence shall be accomplished by removing the identified cause of the noncompliance.

The Responder's supervisor shall approve the disposition to authori ze its imp 1 erne nta tion.'EPSC General Procedure No.15.1-Rev.1 Page 6 of 11 FOR4 N3.GE 35 7589 5 84 IAE AMERIC ELECTRIC POWER SERVICE C ORATION GENERAL PROCEDURE CHANGE SHEET CHANGE SHEET NO.3 PROCEDURE NO.TITI.E: ind rr REVISION NO.PG.1 OF 1 PREPARED BY: REVIEWED BY: CONCURRENCE:

APPROVED BY R.F.'<roe er DATE DATE'ATE'ATE'ATE'ATE'ATE'YPE OF CHANGE Kl PERMANENT 0 TEMPORARY EFFECTIVE DATE+4 5 8 EXPIRATION DATE,',.DESCRIPTIOM OF'CHANGE.

": Correct t o ra hical error in section 6.1.1{5)'Change Sheet No.1~R i e section 6.2.3 to rovide or anizational codes for the'NSDRC Subcommittee and correct for or anizational chan es.REASON(S)FOR CHANGE INSTRUCTIONS FOR INCORPORATING CHANGE nd 4 f C.S.3'emove a e 5 and 6 of ll 7588(5 84)IAE FOAM NO.GE 38 AMERIC+ELECTRIC POWER SERVICE CQQPORATION GENERAL PROCEDURE CHANGE SHEET INDEX AEPSC GENERAL PROCEDURE NO.15.1 REV.NO.CHANGE SHEET NO.NO.OF PGS.PROCEDURE SECTIONS AFFECTED TYPE OF CHANGE TEMP.PERM.DATE EFFECTIVE EXPIRATION DATE 5.1, 9.0 09/)5/SC 1 9.0, Attachment Vio.2 10/ll/84 1 6.1.1(5), 6.2.3 10/5/a4'PON ISSUE OF NEXT REVISION OF THE SUBJECT PROCEDURE 5.0 RESPONSIBILITIES 5.1 5.2 5.3 5.4 Ori inator-Responsible for the determination of the need for and t e comp ete processing of an NCR, including notification to affected organizations, in accordance with this procedure.

Ori inator's Section Mana er-Confirms the need to proceed and assures R is assigne to appropriate individual or organization.

Res onder-The person to whom the NCR is sent.This person is responsi le for the preparation of a meaningful, clear response to the Originator as well as accomplishing other tasks defined in this procedure.

Res onder's Section Mana er-Authorities corrections to be made.5.5 5.6'6.0'SKL-Responsible for indicating reportability of NCR finding and Vor performing reporting functions when applicable.

ualit Assurance-Responsible for maintaining Commitment List;auditing EPSC H organization for compliance with this procedure; and verifying that preventive measures have succeeded.

NONCOMPLIANCE PROCEDURE 6.1 6.1.1 6.1.2 General Noncompliances, typically, include: (1)failure to perform prescribed verification activities; (2)departure or inadvertent omission from approved procedure specifications, drawings, etc.;(3)calculational logic or technical document error;(4)error in procedural document;(5)failure to have adequate or required procedures; (6)failure to transcribe activities affecting quality into written documents; (7)a group of nonconformances that show a trend requiring correction; (8)supplier's report does not address requirements; (9)erroneous entry in supplier's documentation' 10)documentation incomplete, missing or illegible.

A graphic presentation of the noncompliances cycle is shown in Attachment 1.[c.s.s AEPSC General Procedure No.15.1-Rev.1-C.S.3 Page 3 of 11 6.1.3 6.2 6.2.1 6.2.2 Noncompliances identified within AEPSC shall be processed in accordance with this procedure except noncompliances identi-field at a supplier.Supplier noncompliances shall be pro-, cessed under the AEP approved Supplier QA program.AEPSC's involvement shall be limited to the contractual agreements established in the procurement document.Re ortin and Documentin a Noncompliance (Ori inator)Noncompliances shall be documented and reported in a timely manner.Noncompliances shall be identified and processes on AEPSC form GE-60,"Noncompliance Report" (NCR)and processed in accordance with the instruction on its reverse side.(Ref.Attachment 2).The NCR number consists of four parts as follows: RQA-81-4 9-1~"-1" is always used in the preparation of an NCR.The-1 designation will be.changed~)only after on'e or more commitments are made in response to the NCR.If one commitment is made, this part of the number changes to"Cl" from"-1".If two or more commitments are made, each is assigned to its own number i.e.Cl, C2, etc.indicates seauential number of NCRs written for the year in a specific AEPSC organi-zation.indicates the year in which the NCR was written.indicates a Report (NCR)originated by Quality Assurance.

To create this part of the NCR number always start with the letter"R" then add the appropriate suffix from the listing below.AEPSC General Procedur~>No.15.1-Rev.1 Page 4 of ll 6.2.3 Codes for other organizations are as follows: CE-Civil Engineering Div.CH-Chemical Engineering Sec.00-Design Div.DA-DD/Architectural Sec.OC-00/Control Services Sec.DE-DD/Electrical Sec.DM-DD/Mechanical Sec.DS-00/Structural Sec.EE-Electrical Engin.EV-Environmental Div.FP.-Fire Protection HP-Heat Ex.&Pumps HV-Heating and Ventil.IC-Instru.and Control ME-Mechanical Eng.Staff MH-Materials Handling Sec.NC-NSDRC NE-Nuclear Operations Div.NF-Nuclear Materials&Fuel Management Sec.NL-Nuclear Safety&Licensing NO-Nuclear Operations Sec.NR-Radiological Support Sec.PR-Purchasing Department PV-Piping and Valves Sec.QA-Quality Assurance SA-Subcommittee on Audit SC-Subcom.on Proposed Changes SE-Subcom.on Security&~Emergency Plan SO-Subcom.on Corp.&Plant Occurrences TB-Turbine Section 6.2.4 6.3 6.4 6.4.1 Each AEPSC organization shall establish the methods to control unique assignment of numbers to each NCR prepared.",~Evaluati.on Res onder An evaluation shall be conducted by the Responder to determine the cause of the noncompliance.

The cause shall be entered on the NCR.The evaluation shall be of sufficient depth so as to develop meaningful corrective and preventive.measures based on the cause.Classification (Res onder)The Noncompliance shall be classified for two different features: Type of Noncompliance (deficiency/deviation);

and Reportability of Noncompliance.

Type of Noncompliance:

The Responder shall determine and indicate on the NCR the type of Noncompliance based on the evaluation performed in paragraph 6.3 above.The noncompliance shall be either a deficiency or deviation as defined in section 4.0 above.6.4.2 Reportability of Noncompliance:

The Responder shall interface with the Nuclear Safety and Licensing Section of the Nuclear Engineering Division (NS&L)and obtain a classification of reportability For the noncompliance.

The NS&L assigned classifier shall initiate AEPSC General Procedure No.15.I-Rev.I C.S.3 Page 5 of 11 6.4.2 (continued)

N 4 4~reporting activities as required, independent of any action related to the NCR being processed as follows: (1)LER/SPECIAL REPORT-Notify Donald C.Cook Nuclear Plant, plant Manag(r immediately by telephone and follow up by sending a copy of NCR to the Plant Manager.(2)lQCFR Part 21-Direct the responder, by letter, to initiate a Part 21 Package in accordance with General Procedure No.31.Follow up by sending a copy of the NCR and letter to the AEPSC Manager of QA for inclusion of this direction as a commitment on the AEPSC Commit-ment List.The Responder shall identify measures to both: (a)remove the noncompliance; and (b)preclude recurrence of the noncompliance.

1 Removal of a deficiency type noncompliance shall be ac'com-plished by revising the associated document(s) or creating a new document(s).

2 Removal of a deviation type noncompliance shall be accom-plished by the implementing organization enforcing existing documentation and, where necessary, by addition of special measures (e.g.additional surveillance activities; addi-tional and/or more frequent inspections; personnel training;etc.).3 Preventing recurrence shall be accomplished by removing the identified cause of the noncompliance.

4 The Responder's supervisor shall approve the disposition to authorize its implementation.

6.5.6.5.6.5.6.5.(3)OTHER-Initiate, coordinate and perform the action necessary to assure that appropriate reporting require-ments're

".fulfilled'.

"'.5 Disposition (Res onder)AEPSC General Procedure No.15.1-Rev.1 Page 6 of 11