ML20196F957

Rev 20 to QA Program Description,Ufsar 17.2 for Daec

ML20196F957
Person / Time
Site:	Duane Arnold
Issue date:	11/24/1998
From:	IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:
Shared Package
ML20196F956	List: ML20196F957 NG-98-1850, Forwards Rev 20 to QA Program Description,Ufsar 17.2 for DAEC IAW Requirements of 10CFR50.54(a)(3).Submittal Updates UFSAR to Reflect Listed Changes in Organization,None of Which Is Reduction in Commitment
References
NUDOCS 9812070170
Download: ML20196F957 (84)

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l Changes to UFSAR 17.2, Quality Assurance Program Description

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i QUALITY ASSURANCE DURING THE OPERATIONS PHASE l

17.

2.0 INTRODUCTION

17.2.0.1 Scope To maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling of the Duane Arnold Energy Center (DAEC), a comprehensive quality assurance program has been implemented. The objective of this l

program is to maintain managerial and administrative control over the operations of and activities relative to safety-related structures, systems, equipment, and components during the operating life of the DAEC. This program is designed to meet the intent of Appendix B to 10 CFR Part 50.

l 17.2.0.2 Corporate Policy IES Utilities Inc. considers the operation of the DAEC to be an extension of the basic policies established and documented for design, construction, and startup.

The policies and procedures identified within this report regarding " operating phase" will form j

the basis for plant-life operation of the DAEC.

Where contractors and suppliers are used during the life of the operating DAEC, their function t

l will be controlled by the Operational Quality Assurance Program.

1 It is the objective of IES Utidies Inc. that the DAEC shall be operated effectively, efficiently, and in such a manner as not to jeopardize the health or safety of the public.

17.2.1 ORGANIZATION l

17.2.1.1 Scope IES Utilities Inc. has established an operating organization that is structured to support DAEC operating requirements as well as meet corporate needs in other areas. This overall organization is described in UFSAR Chapter 13, Conduct of Operations, Section 13.1,

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Organizational Structure for IES Utilities Inc. The organization chart, which identifies both the l

"on-site" and "off-site" organizational elements that function under the cognizance of the quality assurance program, appears as Figure 13.1-1, IES Utilities Inc. Corporate Organization.

Chapter 13 describes the quality assurance responsibilities of each of the organizational elements noted on the organization chart.

Additional detail concerning the Quality Assurance Department is presented in Chapter 17 2, Section 17.2.1.2.

17.2-1 I

Revision 20 TBD

The responsibility and authority for the establishment and execution of the Operational Quality Assurance Program for the operation of the DAEC will be retained by lES Utilities Inc.

17.2.1.2 Manager, Regulatory Performance The Manager, Regulatory Performance reports to the Vice President, Nuclear and is responsible for quality assurance, emergency planning and nuclear licensing functions.

i Reporting to the Manager, Regulatory Performance are the Manager, Quality Assurance, Manager, Emergency Planning and Manager, Licensing.

17.2.1.3 Manager, Quality Assurance l

The Manager, Quality Assurance reports to the Manager, Regulatory Performance and is l

J assigned primary responsibility for ensuring that quality requirements relative to the safe operation of the DAEC are identified and met. The Manager, Quality Assurance also has the l

authority and organizational freedom to directly access the Vice President, Nuclear regarding quality matters. The Manager, Quality Assurance is responsible for elevating conflicts regarding quality matters with the Manager, Regulatory Performance to the Vice President, Nuclear for resolution.

i Fulfilling the responsibilities of the Quality Assurance Department requires significant l

communication with the DAEC, the Nuclear Licensing Department, the Emergency Planning Department, the Nuclear Business Unit, the Engineering Department, and the Training Department.

The Manager, Quality Assurance is responsible for preparing, approving and maintaining the l

Operational Quality Assurance Program and the Quality Assurance Department implementing procedures.

The Manager, Quality Assurance is also responsible for evaluating the effectiveness of the l

Operational Quality Assurance Program and issuing periodic reports to the appropriate levels of management. Effectiveness of the Operational Quality Assurance Program at the DAEC is determined through internal audits and surveillances and through analysis and trending of reported conditions adverse to quality. The Manager, Quality Assurance also provides support l

for the procurement of materials and equipment through rudits, surveillances, and evaluations of suppliers and contractors for quality capabilities and performance and maintains the list of approved suppliers for nuclear procurements.

Training responsibilities include the training of Quality Assurance Department personnel and Nuclear Generation Division personnel relative to the Operational Quality Assurance Program.

The Manager, Quality Assurance provides direct support to the nudear Safety Committee and j

assures that Quality Assurance Department personnel are designated to support the Operations Committee.

17.2-2 Revision 20 TBD

17.2.1.3.1 Stop Work Authority The Manager, Quality Assurance has the authority to issue a stop work instruction to the l

organization that has direct responsibility for the work. Only the Vice President, Nuclear has the authority to override the stop work instruction.

17.2.2 OPERATIONAL QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope IES Utilities Inc. has established an Operational Quality Assurance Program that applies to those structures, systems, and components, that are safety-related and those activities that affect those structures, systems, and components that are safety-related. Safety-related structures, systems, and components are those that ensure the integrity of the reactor coolant pressure boundary, shut down the reactor, and maintain the reactor in a safe shut down condition, or prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

17.2.2.2 Basis 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and certain regulatory guides, form the basis for the Operational Quality Assurance Program. Appendix A to UFSAR Chapter 17.2 identifies the particular regulatory guides to which IES Uti!ities Inc. is committed and which are included in the basis for the Operational Quality Assurance Program.

17.2.2.3 Identification of Safety-Related Structures, Systems, Components and items The pertinent requirements of the Operational Quality Assurance Program apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. A current list of safety-related structures, systems and components is contained in Section 3.2 of the DAEC Updated Final Safety Analysis Report. This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.

The list of safety-related structures, systems and components from Section 3.2 of the DAEC Updated Final Safety Analysis Report is further defined in data bases through the assignment of plant specific unique identifiers. These data bases include items in addition to safety-related structures, systems and components and are maintained by the Manager, Engineering.

l 17.2.2.4 Operational Quality Assurance Program implementation 17.2-3 Revision 20 TBD

The implementation of the Operational Quality Assurance Program by lES Utilities Inc. is i

directed toward the assurance that operating phase activities and maintenance activities are conducted under controlled conditions and in compliance with applicable regulatory requirements, including 10 CFR Part 50, Appendix B. Management personnel responsible for the conduct of safety related activities are responsible for providing approved procedures before initiating the activity.

The IES Utilities Inc. Operational Quality Assurance Program is irnplemented via four levels of documents:

1. Quality Assurance Manual, t

2. Nuclear Generation Division Manual,

3. Departmental Procedures, and i

4. Departmental Instructions.

17.2.2.4.1 Quality Assurance Manual 1

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The Quality Assurance Manual is the highest level internal quality program document that implements UFSAR/DAEC-1 Chapter 17.2, Quality Assurance During the Operations Phase. It is directed to those IES Utilities Inc. organizations responsible for safety-related activities. The Quality Assurance Manual presents upper management philosophy and concepts to the middle j

management level, defines organizational responsibilities, and identifies organizational interfaces.

t 17.2.2.4.2 Nuclear Generation Division Manual The Nuclear Generation Division Manual contains administrative procedures that are common to the Nuclear Generation Division. These divisional administrative procedures eliminate the need for separate departmental procedures addressing the same subject.

17.2.2.4.3 Departmental Procedures The Departmental Procedures are organizationally unique documents that describe the activities of each department within IES Utilities Inc. that has responsibilities for the operation, maintenance, or modification of the DAEC. The Departmental Procedures specify how to l

accomplish a specific activity.

17.2.2.4.4 DepartmentalInstructions l

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5 The Departmental Instructions are unique to the department and activity for which they have been prepared. DepartmentalInstructions provide the specific, detailed information necessary to perform an activity. DepartmentalInstructions are issued at the discretion of the responsible manager and are not required for all activities.

17.2.2.5 Control of IES Utilities Inc. Suppliers IES Utilities Inc. may employ the services of architect-engineers, NSSS suppliers, fuel fabricators, constructors, and consultants to augment IES Utilities Inc. capabilities. These organizations are required to work under a quality assurance program to provide the control of quality activities consistent with the scope of their assigned work. The quality assurance programs of such organizations are subject to review, evaluation, and acceptance by the IES Utilities Inc. Quality Assurance Department before the initiation of activities affected by the l

program.

17.2.2.6 Indoctrination and Training The indoctrination, training, and retraining of personnel who participate in safety-related activities are provided in five broad areas: operator training, quality assurance indoctrination, technical training, radiation safety indoctrination and training, and emergency preparedness training.

The Operator training provided to senior reactor operators and reactor operators is under the cognizance of the Plant Manager and the Manager, Nuclear Training.

l The quality assurance indoctrination provided to IES Utilities Inc. personnel is under the cognizance of the Manager, Quality Assurance and the Manager, Nuclear Training.

l The technical training provided to IES Utilities Inc. personnel is under the cognizance of the Manager, Engineering, the Plant Manager and the Manager, Nuclear Training. The training l

may be provided in a number of ways, from self-study courses to formalized courses at the DAEC and educational institutions.

Indoctrination and training provided to IES Utilities Inc. personnel and contract personnel relative to performing work in areas that are potentially hazardous because of radioactivity are under the cognizance of the Radiation Protection Manager and the Manager, Nuclear Training.

The indoctrination and training provided to IES Utilities Inc. personnel and contract personnel relative to emergency preparedness is under the cognizance of the Manager, Emergency Planning.

17.2.2.7 Management Review and Audit 17.2-5 Revision 20 TBD i

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The status of the IES Utilities Inc. Operational Quality Assurance Program is periodically made known to management. A periodic report is prepared by the Manager, Quality Assurance and l

submitted to the Vice President, Nuclear.

1 An annual audit of the Operational Quality Assurance Program is conducted to evaluate the effectiveness of the overall program. Direction for these audits attemates between the Vice President, Nuclear and the Safety Committee. The Safety Committee audit is in accordance with the requirement for a biennial audit of the quality assurance program as delineated in Section 17.2.18.2.2 of this UFSAR Chapter. These alternating audits complement each other and provide an annual evaluation.

17.2.3 DESIGN CONTROL 17.2.3.1 Scope The design, modification, addition, and replacement of safety-related structures, systems, and components at the DAEC is controlled to ensure that appropriate measures are implemented and to ensure that "as-built" quality is not degraded. The plant design is defined by IES Utilities Inc., the NSSS supplier, architect / engineer, and selected suppliers. Design drawings and specifications illustrate the general arrangement and details of safety-related structures, systems, and components and define the requirements for ensuring their continuing capability to perform their intended operational or safety design function.

Design activities include the correct translation of regulatory requirements and design bases into specifications, drawings, written procedures, and instructions that define the design.

Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident analyses used to produce design output documents are performed when appropriate.

Design verification is performed.

Procedures establish requirements, assign responsibilities, and provide control of design activities to ensure performance in a planned, controlled, and orderly manner.

17.2.3.2 Design Responsibility The design and engineering effort is the responsibility of the Manager, Engineering within the l

Nuclear Generation Division. Assistance may be provided by other engineering organizations; individuals providing that assistance are required to perform their activities in compliance with the IES Utilities Inc. Operational Quality Assurance Program. The design of nuclear fuel reloads is the responsibility of Reactor Engineering.

17.2.3.3 Design Criteria 17.2-6 Revision 20 TBD

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l Design requirements and changes thereto are identified, documented, reviewed, and approved l

to ensure the incorporation of appropriate quality standards in design documents. Design requirements and quality standards are described to an appropriate level of detail in design criteria. Any exception to quality standards will be listed. Criteria for modifications to structures, systems, and components will consider, as a minimum, the design bases desenbed in the UFSAR. All design criteria will be satisfied in the design.

I 17.2.3.4 Design Process Controls i

The organization performing design will have the responsibility for design control unless specified otherwise. The control of design will be specified in procedures. These procedures will include instructions for defining typical design requirements; communicating needed design information across internal and external interfaces; preparing, reviewing, approving, releasing, distributing, revising, and maintaining design documents; performing design reviews; and l

controlling field changes.

l Design control involves measures that include a definition of design requirements; a design l

process that includes design analysis and the delineation of requirements through the issuing of drawings, specifications, and other design documents (design outputs); and design verification.

The design process establishes controls for releasing technically adequate and accurate design documents in a controlled manner with a timely distribution to responsible individuals and groups. Documents and revisions are controlled through the use of written procedures that apply to the issuer, distributor, and user to prevent inadvertent use of superseded documents.

Document control procedures govern the collection, storage, and maintenance of design documents, results of design document reviews, and changes thereto. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, the UFSAR when used as a design document, and drawings, including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations.

17.2.3.5 Design Interface Control l

Design interfaces with external and internal organizations participating in the design are l

controlled. The design interface measures ensure that the required design information is available in a timely fashion to the organization (s) responsible for the design.

17.2.3.6 Design Verification l

l The applicability of previously proven designs, with respect to meeting pertinent design inputs, including environmental conditions, will be verified for each application. Where the design of a particular structure, system, or component for a specific application has been subjected to a previous venfication process, the verification process need not be duplicated for subsequent identical applications. However, the orig:nal design and verification will be documented and referenced for the subsequent application.

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When changes to previously verified designs have been made, design verification will be required for the changes, including an evaluation of the effects of those changes on the overall design.

Design verification will be performed by competent individuals who:

1. have not participated in the original design but may be from the same organizational

entity,

2. do not have immediate supervisory responsibility for the individual performing the

design,

3. have not specified a singular design approach,

4. have not ruled out certain design considerations, and

5. have not established the inputs for the particular design aspect being verified.

I Under exceptional circumstances, the design verification may be performed by the originator's supervisor provided:

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the supervisor is the only technically qualified individual in the organization competent to perform the verification, 2.

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

QA audits cover the frequency of occurrence and effectiveness of the supervisor as design verifier to guard against abuse.

Cursory supervisory reviews do not satisfy the intent of providing a design verification.

If errors or deficiencies in the design process are detected during the design verification cycle or during audits, resolution of errors and deficiencies will be the responsibility of the design engineer, who must provide documented evidence of resolution to the appropriate levels of management.

Acceptable verification methods include, but are not limited to, any one or a combination of the following:

1. Design reviews,

2. Alternative or simplified calculational methods, and

3. Performance of suitable qualification testing.

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l The method selected will consider the item's complexity, previous operational experience, and importance to safety.

l The results of the design verification efforts will be clearly documented, with the identification of the verifier clearly indicated and filed. The documentation of results will be auditable against the verification methods identified by the responsible design organization.

17.2.3.6.1 Design Reviews t

Design reviews will be sufficient to verify the appropriateness of the design input, including assumptions, design bases and applicable regulations, codes and standards, and that the design is adequate for the intended application of the design.

Design reviews can range from multi-organization reviews to single-person reviews. The depth of review can range from a detailed check of the complete design to a limited check of the design approach, calculations, and results obtained.

17.2.3.6.2 Calculations Alternative, simplified calculations can be made, or a check of the original calculations may be performed, to verify the correctness of the original calculation. Where computer programs are I

used, the program verification will be documented and the inputs shall be considered in the l

design review.

17.2.3.6.3 Qualification Testing Design verification for some designs or specific design features may be achieved by suitable qualification testing of a prototype or initial production unit.

In tnose cases where the adequacy of a design is to be verified by a qualification test, the testing will be identified and documented. Testing will demonstrate the adequacy of performance under conditions that simulate the most adverse design conditions.

17.2.3.7 Changes To Design Documents Changes to design documents receive a review and approval process as equivalent to original design documents. Design documents issued by the original architect-engineer, NSSS supplier, and other organizations may be changed and revised by the responsible design organizations within IES Utilities Inc. or contracted by IES Utilities Inc.

17.2.3.8 Independent Review Committees 17.2-9 Revision 20 TBD i

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independent of the responsibilities of the design organization, the requirements of the Operations Committee and the Safety Committee, as specified in UFSAR 17.2 Appenc$ix A, Section 6.4, will be satisfied.

17.2.4 PROCUREMENT DOCUMENT CONTROL 1

17.2.4.1 Scope Procurement document control applies to documents employed to procure safety related materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate the DAEC. IES Utilities Inc. controls procurement documents by written procedures that establish requirements and assign responsibility for measures to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure quality are i

included in or invoked by reference in documents employed for the procurement of safety related materials, parts, components, and services.

17.2.4.2 Procurement Responsibility The responsibility for the initiation of a purchase requisition is that of the organization that l

ultimately has the responsibility for the procurement.

17.2.4.3 Quality Classification Each item or service to be procured is eva!uated by the Engineering Department to determine i

whether or not it performs a safety-related function or involves activities that affect the function of safety-reiated materials, parts, or components and to appraise the importance of this function to plant or public safety. For those cases where it is unclear if an individual piece (that is, part of a safety-related structure, system, component, or service) is govemed by the Operational Quality Assurance Program, an engineering evaluation will be conducted. The evaluation will classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or components.

l 17.2.4.4 Quality Requirements in Procurement Documents Procurement document control measures will ensure that appropriate regulatory requirements, i

design bases, and other requirements are included in the procurement process. Originating l

and reviewing organizations shall require that the following be included or invoked by reference l

in procurement documents, as appropriate:

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1. Requirements that the supplier provide a description of his quality assurance program l

that implements the applicable criteria of 10 CFR Part 50, Appendix B, and that is appropriate for the particular type of item or service to be supplied. Certain items or services will require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases.

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2. Basic administrative and technical requirements, including drawings, specifications, regulations, special instructions, applicable codes and industrial standards, and procedural requirements identified by titles and revision levels; special process instructions; test and examination requirements with corresponding acceptance criteria; and special requirements for activities such as designing, identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and storing.

3. Requirements for supplier surveillance, audit, and inspection, including provisions for IES Utilities Inc. access to facilities and records and for the identification of witness and hold

points, f

4. Requirements for extending applicable requirements to lower-tier suppliers and subcontractors. These requirements willinclude right-of access by lES Utilities Inc. to l

sub-supplier facilities and records.

5. Requirements for the supplier to report certain nonconformances to procurement i

document requirements and conditions of their disposition.

6. Documentation requiren~nts, including records to be prepared, maintained, submitted, l

or made available for reviu, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedural qualifications, i

chemical and physical test results, and instructions for the retention and disposition of records.

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7. Requiiements for supplier-furnished records.

8. Applicability of the provisions of 10 CFR Part 21 for safety-related items, to the extent that a loss of their function may cause potential substantial safety hazards. Certain items, as off-the-shelf items, will be exempt from this requirement.

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9. Requirements for packaging and transportation as necessary to prevent degradation during transit.

17.2.4.5 Acquisition from Other Licensed Nuclear Power Plants items may be procured from another NRC-licensed nuclear power plant provided that the procured item meets the requirements of the DAEC procurement specification. If the item was originally procured by the other utility as a " basic component" as defined in 10 CFR Part 21, then the reporting requirements of the regulation are accepted by lES Utilities Inc. IES Utilities Inc. shall notify the original supplier in writing of this item (s) change in ownership to give the original supplier the opportunity to change the 10 CFR Part 21 notification records.

17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS i

17.2-11 Revision 20 TBD

17.2.5.1 Scope Instructions, procedures, and drawings will be generated to provide direction and guidance to ensure that safety-related activities are performed correctly. The need for, content of, and depth of detail of the instructions, procedures, and drawings will be consistent with the importance and complexity of that activity.

17.2.5.2 Content The content of the instructions, procedures, and drawings will be appropriate to the activities being performed.

Instructions and procedures will include, as appropriate, scope or purpose, responsibilities of individuals performing the work, the information needed, and required output and acceptance criteria.

Drawings will be prepared using industrially accepted standards.

17.2.5.3 Corrpliance Following approval and issuance of instructions, procedures and drawings, respective activities will be performed in accordance with the documents. If an activity cannot be accomplished due to an inadequacy of the document, the document will be formally revised to reflect the manner in which the activity is to be performed.

17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope The organization responsible for the documents will establish measures to ensure that the documents, including changes, are reviewed for adequacy and are approved for release by authorized personnel. The responsible organization also establishes measures to ensure the documents are distributed to and used at the location where the prescribed activity is performed and are controlled.

17.2.6.2 Preparation Administrative techniques will be established that define the documents to be issued and controlled, identify the current revision or issue of the document, and identify the individuals who are to receive the document.

17.2.6.3 Reviev and Approval l

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Documents that are specified as being controlled documents are reviewed to ensure that regulatory, technical, and quality assurance requirements have been appropriately addressed; that review comments have been considered and resolved; and that the document is approved before issuance and use.

i The review and approvals required for instructions, procedures and drawings will be established j

by the organization responsible for those documents. Reviews will be performed by knowledgeable personnel other than the originata Review and approval will occur prior to issuance or implementation of the changed document.

1 17.2.6.4 Distribution and Use Documents will be issued before the commencement of the activity to be controlled by that i

document. The mechanism for distribution will provide assurance that the controlled document i

arrives at the point of use; the user will provide assurance that the document to be used is the proper document and revision.

When formal distribution lists are used to prescribe an established distribution, they will be maintained current to reflect changes in assigned responsibilities.

Document transmittals will be reviewed for accuracy and dated and made suitable for transmittal. The recipient is informed of what is being transmitted and of the status of the documents being transmitted.

An acknowledgment of the receipt of controlled documents by recipients may be required if the organization responsible for the document deems such controls necessary.

The organization responsible for the use of the document will establish administrative controls to provide for positive identification and prevent the loss of such documents. The administrative controls will have provisions to remove obsolete documents, thereby precluding the possibility that toe wrong documents or revisions will be used.

17.2.6.5 Changes to Documents Changes to documents previously released will be reviewed, approved, dated, and distributed in the same raanner as the original document.

Personnel who review changed documents will have access to pertinent background information upon which to base their approval. Reviewers shall have adequate understanding of the requirements and the intent of the original documents, including source documentation.

Revisions will be reviewed and approved by the same organizations that performed the original review and approval untess another qualified organization is designated.

Revised instructions and procedures will reflect the new revision and date and clearly identify the scope or portion of the instruction and procedure being changed.

17.2-13 Revision 20 TBD

I Documents that have been approved by the original designers of the DAEC will be revised by l

the IES Utilities Inc. Engineering Department.

17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Scope Purchased material, equipment, and services are controlled to ensure that the specified technical and quality requirements are obtained. The responsibility for the control of purchased j

material, equipment, and services is that of the Quality Assurance Department in close l

cooperation with the Engineering Department and the DAEC. The technique used for the control of purchased material, equipment and services includes, as appropriate, source evaluation and selection, objective evidence of quality furnished, inspection at the source, supplier's history of providing a satisfactory product, and examination of the product on delivery.

17.2.7.2 Source Evaluation and Selection Potential suppliers are evaluated. These evaluations are performed by qualified personnel to l

rietermine the capability of the supplier to provide the items or sennces.

l Suppliers are evaluated on the basis of one of more of the following-l

1. Capability to comply with the requirements of 10 CFR 50, Appendix B, applicable to the type of material, equipment, or service being procured,

2. Past records and performance for similar procurements to ascertain the capability of supplying a manufactured product or services under an acceptable quality assurance system,

3. Auoits or surveys of supplier's facilities and quality assurance program to determine the capability to supply a product that satisfies the design, manufacturing, and quality requirements,

4. The certification of the supplier by the ASME, and

5. The results of audits performed by other utilities and consultants.

l The supplier's bid proposal is reviewed and evaluated to ensure that the bid is responsive to the procurement documents.

l Depending on the importance of the item or service and its importance to safety, a post-award l

meeting may be held to discuss the requirements of the procurement document.

17.2-14 Revision 20 TBD

17.2.7.3 Inspection or Surveillance at the Source Subsequent to the award of a purchase order, a surveillance / inspection plan may be prepared.

The extent of the plan will consider the complexity and importance of the item or service, supplier's past performance, and those aspects of the manufacturing process that may not be verified at receipt inspection.

The plan will establish, as appropriate, the frequency of surveillance / inspection; processes to be witnessed, inspected, or verified; the method of surveillance / inspection; and documentation requirements.

Activities specified in the plan will be conducted at the supplier's facilitics by qualified personnel using approvad procedures that provide for the following as applicable:

1. Reviewing material acceptability, i

2. Witnessing in-process inspections, tests, and nondestructive examination,

3. Reviewing the qualification of procedures, equipment, and personnel,

4. Verifying that fabrication or construction procedures and processes have been approved and are properly applied,

5. Verifying quality assurance / quality control systems, to the extent necessary,

6. Reviewing document packages for compliance to procurement document requirements, including qualifications, process records, and inspection and test records,

7. Reviewing Certificates of Compliance for adequacy, and

8. Verifying that nonconformances have been properly controlled.

Hold points specified in the procurement document will be complied with and IES Utilities Inc.

will be notified in a timely manner when hold points are reached.

A method will be established to provide information relative to the characteristics that have been inspected at the source and the characteristics that are to be inspected on receipt.

17.2.7.4 Receipt inspection items purchased by IES Utilities Inc. are controlled at the final destination by the performance of a receipt inspection. The extent of the receipt inspection depends on the importance to l

safety, the complexity, the quantity of the product or service, and the extent of source l

inspection, source surveillance or audit that was performed.

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Receipt inspection is performed by trained and qualified personnel in accordance with approved l.

procedures and acceptance criteria before the installation or use of the item (s) to preclude the l

placement or use of nonconforming item (s).

Documentary evidence will demonstrate that materials and equipment conform to the l

procurement requirements.

l If receipt inspection indicates that the item is unacceptable, the item is treated as nonconforming.

17.2.7.5 Post-installation Testing i

Acceptance by post-installation test may be used following one of the preceding verification l

methods. Post-installation testing is used as the prime means of acceptance verification when j

it is difficult to verify item quality characteristics, the item requires an integrated system check out or test, or the item cannot demonstrate its ability to perform when not in use. Post-i installation test requirements and acceptance documentation are established by IES Utilities l

Inc.

l 17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS l

l 17.2.8.1 Scope l

Materials, parts, and components will be identified and controlled to ensure that the correct materials, parts, and components are used during fabrication, manufacture, modification, repair, and replacement.

It is the responsibility of the organization responsible for the engineering design and l

procurement to include the requirements for proper identification and control in the procurement documents.

l It is the responsibility of the supplier for maintaining the traceability of materials, parts, and l

components throughout fabrication and shipment.

It is the responsibility of the DAEC for maintaining the traceability of materials, parts, and components throughout repair, replacement, modification, and installation.

17.2.8.2 Identification identification will be applied in locations and by methods that will not affect the fit, function, or quality of the item.

17.2-16 Revision 20 TBD

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The identification of the item will be maintained by a unique method such as heat number, part

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number, serial number, batch number, or other appropriate means in a form that is durable and legible.

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The identification may be on the item or on records traceable to the item. Where feasible, t

direct placement of the identification on the item will be by stamping, marking, tags, labels, or l

l other similar methods.

I Where direct placement of identification on the item is not feasible, proper controls will be established that ensure direct positive identification of the item. Where physicalidentification is either impractical or insufficient, physical separation, procedural control, or other approved means will be employed.

l Receipt inspection will verify that identification for received items is complete and accompanied l

by appropriate documentation.

When an item is subdivided, the identification will be immediately transferred to the sub-parts so that all sub-parts contain the appropriate identification label.

Any identification that will be obliterated or hidden by surface coatings or surface treatments will

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be reestablished or will be traceable by administrative means.

l Standard catalog items or off-the-shelf items may be identified by catalog number or other appropriate designation.

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17.2.8.3 Verification and Control I

The items will be controlled and the identity of the item verified.

Inventory and storage controls will be established at the DAEC to ensure proper traceability of items.

l The correctness of the item will be verified on withdrawal from storage and before the initiation of the repair, replacement, and modification.

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17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope Special processes are those controlled fabrications, tests, and final preparation processes that require the qualification of procedure, technique, and personnel and that are performed in accordance with appbcable codes and standards. Certain special processes require interim in-process controls in addition to final inspection to ensure quality.

17.2-17 Revision 20 TBD l

The control of special processes is the joint responsibility of the Engineering Department, the DAEC, and the Quality Assurance Department.

l The Engineering Department is responsible for providing technical expertise relative to l

materials, metallurgy, welding, brazing, special processes and nondestructive examination (NDE). Nondestructive examinations will be performed under the direction of the Engineering Department by personnel independent of the activity and qualified in accordance with SNT-TC-1A.

l 17.2.9.2 General Requirements Measures will be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with app licable codes, standards, specifications, criteria, and other special requirements.

Written procedures will be reviewed or prepared before use to ensure that special processes are controlled and accomplished.

These procedures will describe the operations to be performed, the sequence of operations, the characteristics involved, the limits of these characteristics, measuring and test equipment to be used, acceptance criteria, and documentation requirements.

Special processes will be accomplished in accordance with written procedures and process sheets, or their equivalent.

Personnel will be trained and qualified in accordance with applicable codes and standards.

Equipment used to perform special processes or measure or test the product will be qualified, before use, in accordance with applicable codes, standards, specifications, or procedures.

The extent and period of training, qualification. and testing of personnel and equipment will be in accordance with applicable codes, standards, specifications, or procedures.

17.2.9.3 Personnel Qualification The personnel who perform nondestructive examinations will be certified to the precise technique to be used and for the proper level of expertise.

A Level 111 Examiner will be responsible for qualifying and certifying, in accordance with the IES Utilities Inc. written practice, the IES Utilities Inc. personnel who perform nondestructive examinations.

l 17.2.9.4 Verification and Control 17.2-18 Revision 20 TBD 1

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The procedures, process sheets, personnel, and equipment will be verified as appropriate, before the initiation of work at the DAEC.

The Quality Assurance Department will determine that suppliers performing special processes l

l at the DAEC have sufficient controls before the initiation of the work.

The Engineering Department will determine that personnel performing special processes have current quali'ications.

i 17.2.9.5 Special Protective Coatings (Paint)

The application of a special protective coating shall be controlled as a special process when the failure (i.e. peeling or spalling) of the coating to adhere to the substrate can cause the 2

malfunction of a safety-related structure, system or component. Special process coatings shall i

be applied by qualified personnel using qualified materials and equipment, and approved procedures. Documentation shallinclude identification of the following:

1. person applying the coating (and qualification),

2. material used, 4

3. procedure used (and qualifying procedure if different),

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4. tests performed and results, 2

5. date of application of coating, and l

6. traceability of coating location.

i 17.2.10 INSPECTION

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17.2.10.1 Scope 1

i A program for the inspection of safety-related activities at the DAEC will be established and executed to verify conformance with applicable documer,ted instructions, procedures, drawings, i

and specifications.

The responsibility for the receipt, in-process and final inspection of materials, parts, and components affecting quality is that of the Maintenance Department. The responsibility for the performance of nondestructive examinations is that of the Engineering Department.

17.2.10.2 General Requirements 17.2-19 i

Revision 20 TBD

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l A program for the inspection of activities affecting quality will be established and executed by or for the organization performing the activity to verify conformance with the documented l

instructions, procedures, and drawings for accomplishing the activity.

Inspection will be performed by individuals other than those who performed the activity being inspected. Inspections will be performed by personnel using appropriate equipment in accordance with applicable codes, standards, and procedures.

Procedures, instructions, or checklists will be established and used that identify the characteristics to be inspected, inspection methods, special devices, acceptance and rejection criteria, methods for. recording inspection results, and grouos responsible for the inspection.

Special preparation, cleaning, and the use of measuring devices will be included.

Inspections will be planned to identify where in the sequence of work each inspection activity will be performed, to what extent, procedures to be used, and mandatory hold or witness points.

Repairs, modifications, or replacements will be inspected in accordance with the original inspection requirements or acceptable alternatives.

Sampling methods and process monitoring will be used when inspection is impossible or disadvantageous.

17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and personnel will be used as a control if inspection of processed items is impossible or disadvantageous. Both inspection and process monitoring will be provided when controlis inadequate without both. As an alternative, a suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed will be attained by inspection. As appropriate, an augmented inspection program will be implemented until such time as a suitable level of performance has been demonstrated.

The monitoring of processes will be performed to verify that activities affecting quality are being performed in accordance with documented instructions, procedures, drawings, and specifications.

i 17.2.10.4 In-Service inspection Required in-service inspection, including nondestructive examination, pressure tests, and in-service tests of pumps and valves, will be planned and executed. The results of these examinations and tests shall be documented, including corrective actions required and the actions taken.

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The basis for the in-service inspection program is the ASME Boiler and Pressure Vessel Code,Section XI,1989 Edition with no Addenda. The specific issue and addendum of requirements beyond the base commitment is as specified in 10 CFR Part 50, Section 50.55s(g), except where specific exemptions have been granted by the NRC.

The Engineering Department has the overall responsibility for developing the inspection program, for ensuring compliance with the ASME Code Section XI rules, and for evaluating the inspection results. The inspection plans shall be updated as required to accommodate the as-built condition of the DAEC.

17.2.10.4.1 Ten Year inspection Program The Ten-Year Inspection Program includes inspections and tests of those pressure boundary welds and materials as defined in ASME Boiler end Pressure Vessel Code,Section XI. Also included are the pressure boundary welds and materials that are defined as " Augmented"in-service inspections. The Ten-Year Inspection Program identifies the welds and items to be examined, the frequency of such examinations, the methods, and confirms the continuing acceptability of the selected welds and items.

The Engineering Department has the responsibility for conducting the planned nondestructive examinations (NDE) and providing the services of the NDE Level lli Examiner as required by l

Code.

17.2.10.4.2 In-service Testing Program The DAEC has the responsibility for conducting the ASME Boiler and Pressure Vessel Code,Section XI, pump and valve tests, system pressure tests, and snubber tests. These performance tests to verify operational readiness are part of the plant performance program.

17.2.10.5 Personnel Qualification Personnel performing inspections and examinations, or accepting the results of inspections and examinations, will be trained and qualified in accordance with governing codes, standards, and regulations. The personnel will be competent and cognizant of the technical requirements of the work activity. Qualification records will be maintained by the organization responsible for the individual (s) performing the inspections.

17.2.10.6 Documentation and Records Inspection and examination activities will be reported on a form that indicates the date of the activity, identification of inspector or examiner, and rejection or acceptance of the item (s).

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l 17.2.11 TEST CONTROL 17.2.11.1 Scope l

Testing will be performed at the DAEC to demonstrate that safety-related structures, systems, and components perform satisfactorily in service. The testing program will include the following, as appropriate:

1. Qualification tests for design verification,

2. Proof tests before installation,

3. Pre-Operational tests, and

4. Operational tests.

17.2.11.2 General Requirements The tests will be performed in accordance with approved written test procedures that incorporate the requirements and acceptance limits. The test procedure will identify the item to be tested and the purpose of the test.

Test procedures will include provisions for ensuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. The test procedure willincorporate directly, or by reference, the following requirements:

1. Performance of tests by trained personnel who are qualified in accordance with applicable codes and standards,

2. Verification of test prerequisites,

3. Identification and description of acceptance or rejection criteria, and

4. Instructions for performing the test.

17.2.11.3 Surveillance Testing Provisions will be established for the performance of surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions of operation can be met. The testing frequency will be at least as frequent as prescribed in the Technical Specifications. The provisions for surveillance testing will include the preparation of schedules that reflect the status of planned j

surveillance tests. Qualified plant staff will perform surveillance tests.

17.2-22 Revision 20 TBD l

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17.2.11.4 Personnel Qualification Personnel performing testing will be trained and qualified. The personnel will be competent and cognizant of the technical requirements of the work activity.

17.2.11.5 Documentation and Records Test procedures and results will be documented and approved by qualified personnel.

Test results shall be documented and indicate that the prerequisites and other test requirements have been met.

17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT i

17.2.12.1 Scope The responsibility for the control of measuring and test equipment and permanently installed plant instrumentation, is that of the DAEC. The control measures willinclude the identification i

and calibration of the equipment to the activity. The requirements contained within this section do not apply to devices for which normal industry practice provides adequate control, that is, tape measures, rulers, and measuring glasses.

17.2.12.2 General Requirements Measures will be established for the control, calibration, and adjustment of measuring and testing devices.

Calibration intervals will be based on required accuracy, the use of equipment, stability characteristics, or other factors affecting the measurement.

The following requirements will be specified in written procedures that are used to control measuring and test equipment:

1.

Identification of equipment and traceability to calibration data,

2. Calibration methods, frequency, maintenance, and control,

3. Labeling and marking of portable equipment to indicate due date for next calibration.

Due dates for permanently installed plant equipment are controlled by means of a central record system, 4.

Provisions for determining the validity of previous measurements when equipment is determined to be out of calibration, and 17.2-23 Revision 20 TBD

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5. Traceability of reference and transfer standards to nationally recognized standards.

When national standards do not exist, the basis for calibration shall be documented.

Calibration may be performed at the DAEC or by qualified laboratories using competent personnel.

Equipment that is consistently found to be out of calibration shall be repaired or replaced.

When the accuracy of the measuring or test device can be adversely affected by environmental conditions, special controls will be prescribed to minimize such effects.

i 17.2.12.3 Traceability The measuring and test equipment will be traceable to the item on which the equipment has been used.

l When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration.

17.2.13 HANDLING, STORAGE, AND SHIPPING l

17.2.13.1 Scope l

The handling, storage, shipping, cleaning, and preservation of material and equipment will be controlled to prevent damage, deterioration, and loss.

it is the responsibility of the organization initiating procurement to specify any special instructions and requirements for packaging and hand!ing, shipping, and extended storage.

It is the responsibility of the DAEC to provide for the proper handling and storage of material and equipment upon receipt and throughout repair, replacement, and modification.

l 17.2.13.2 General Requirements l

Measures will be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.

When necessary for particular products, special protective environments such as inert gas atmosphere, temperature levels, and specific moisture-content levels will be specified and provided.

i 17.2-24 Revision 20 TBD

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Consistent with the need for preservation, material and equipment will be suitably cleaned to prevent contamination and degradation. The cleaning method selected willin itself not damage or contaminate the material or equipment.

l 17.2.13.3 Shipping l

When required to prevent contamination or to prevent damage during shipment, special packaging methods will be specified and implemented.

l Special-handling requirements, if required, will be specified in the shipping instructions. The package should be appropriately marked to indicate that special handling or storage requirements are necessary.

Markings of packages will conform to applicable Federal and state regulations.

17.2.13.4 Radioactive Materials Measures will also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR Part 71. These measures will apply to the use of shipping containers only, and not to the design and fabrication of shipping containers for which an NRC certification is required under Part 71.

17.2.13.5 Handling The requirements for special handling will be considered when the item is moved from the receipt point to the storage area and from the storage area to the point of use.

I Special-handling equipment will be periodically tested and inspected.

17.2.13.6 Storage Materials and equipment will be stored to minimize the possibility of damage or lowering of quality from the time an item is stored on receipt until the time the item is removed from storage.

The manufacturers' recommendations are considered; however, the relaxation of manufacturers' storage requirements may be implemented if the storage recommendations are not reasonably necessary to preclude equipment degradation. Material and equipment will be stored at locations that have a designated storage level. The various storage levels will be defined and will have prescribed environmental conditions. The storage conditions will be in accordance with design and procurement requirements to preclude damage, loss or deterioration due to harsh environmental conditions. Items having limited shelf life will be identified and controlled to preclude the use of items whose shelf life has expired.

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17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 Scope Measures will be established to ensure that necessary inspections of items have not been inadvertently bypassed or that systems or components are not inadvertently operated.

17.2.14.2 General Requirements Measures will be established to indicate, by the use of marking such as stamps, tags, labels, routing cards, log books, or other suitable means, the status of inspection, test and operating q

status of individual structures, systems, or components.

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Procedures will provide for controls to preclude the inadvertent use of nonconforming, inoperative, or malfunctioning structures, systems, or components.

g The procedures will include the following:

1.

Identification of authority for application and removal of status indicators, i

2.

The use of specific status indicators, and 1

3.

Provisions for maintaining the status of the structures, systems, or components until removed by an appropriate authority.

i 17.2.14.3 Inspection and Test Status Measures will be established to provide for the identification of items that have satisfactorily i

passed required inspections and tests.

l Only items that have passed inspection or testing will be used in the manufacture or installation of an item.

Documented procedure requirements will include the following:

1.

Maintenance of the status of the item throughout fabrication and installation, 2.

Use of status indicators such as stamps, tags, markings, or labels either on the items or on documents traceable to the items, and 3.

Provisions for controlling the bypassing of required inspections, tests, and other critical operations.

17.2-26 Revision 20 TBD 4

j Items at the DAEC w!!I be identified by status indicators to indicate whether they are awaiting i

inspection, acceptable for use, unacceptable, or in a hold status pending further evaluation.

17.2.14.4. Operating Status Procedures relating to the operational status of safety-related structures, systems, and components, including temporary modifications, will include the following:

1.

Authorization for requesting that equipment be removed from service, i

2.

Checks that must be made before approving the request, 3.

Approval of the action to remove the equipment from service, l

4.

The actions necessary to isolate the equipment and responsibility for performing these actions, and i

5.

The actions necessary to return the equipment to its operating status and responsibility for these actions.

Equipment and systems in a controlled status will be identified. Plant procedures will establish controls to identify the status of inspection and test activities associated with maintenance, instrumentation, and control system calibration and testing. The status of nonconforming, inoperative, or malfunctioning structures, systems, and components will be documented and identified to prevent inadvertent use.

l The Technical Specifications establish the status required for safe plant operation, including provisions for periodic and non-periodic tests and inspections, c,f various structures, systems, and components. Periodic tests may be operational tests or tests following maintenance, and non-periodic tests may be made following repairs or modifications.

17.2.14.5 Sequence Change Control Procedures will include the control of the sequence of required tests, inspections, and other operations when important to safety. To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.

17.2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS l

17.2.15.1 Scope The nonconformance reporting system is established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation.

17.2-27 Revision 20 TBD I

Nonconforming materials, parts or components shall be identified, documented and segregated, and notification shall be provided to affected organizations. The responsibility for the disposition of the nonconforming materials, parts, or components is that of the Engineering Department, DAEC, and the Quality Assurance Department.

l 17.2.15.2 Identification and Segregation The identification and segregation will be sufficient to prevent inadvertent use or installation of the nonconforming item. Material, parts, or components for which nonconformances have been identified will be immediately segregated, when practical, in areas that are reserved for nonconforming items. When segregation is impractical, administrative measures will be used, such as tagging, roping off the area, etc.

17.2.15.3 Reporting and Disposition The reporting mechanism will provide the means to disposition the nonconforming material, part, or component.

The nonconformance report will identify the item, describe the nonconformance, and contain sufficient information to evaluate the nonconformance. The nonconformance report wul be transmitted to the proper organization (s) for evaluation and disposition.

17.2.15.4 Disposition The disposition will be limited to one of the following: use-as-is, rework to original requirements, repair to an acceptable condition, or reject.

For disposition of use-as-is and repair, a technical justification will provide assurance that the item will function as originally intended.

Items that are to be repaired or reworked will be required to be reinspected or retested to determine that the original or new acceptance criteria have been satisfied.

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17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope Corrective action control measures will be established to ensure that conditions adverse to quality are promptly identified, reported, and corrected.

17.2.16.2 Conditions Adverse to Quality 17.2-28 Revision 20 TBD

j Conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, nonconformances, and abnormal occurrences will be promptly identified and corrected.

j The Nuclear Licensing Department is the responsible for administration of the Corrective Action Program Administrative responsibilities include receipt, tracking, assignment of actions to appropriate personnel for correction, and classification of the reported conditions as a condition adverse to quality or a significant condition adverse to quality.

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The Quality Assurance Department will perform an analysis of reported conditions adverse to l

quality to identify negative trends in quality performance and to determine if there are any broad i

programmatic areas where trending reveals a significant condition adverse to quality. This analysis will be performed at least annually and will be reported to appropriate levels of management. This analysis will be documented and retained as a quality assurance record.

17.2.16.3 Significant Conditions Adverse to Quality Significant conditions adverse to quality that impede the implementation or reduce the effectiveness of the program will be controlled. These conditions will be reported to appropriate management and evaluated. The cause of a significant condition adverse to quality shall be determined, and corrective action will be taken to preclude repetition. Significant adverse conditione may include, but are not limited to, a recurring condition for which past corrective action has been ineffective, significant trends adverse to quality, or significant Operational Quality Assurance Program deficiencies.

17.2.16.4 Reporting of 10 CFR 21 Defects and Non-compliances A 10 CFR 21 defect and noncompliance is defined as one which could reasonably indicate a potential substantial safety hazard.

A procedure has been established, and appropriate posting provided in accordance with the provisions of 10 CFR Part 21, so that IES Utilities Inc. employees will be aware of the methods by which 10 CFR Part 21 defects and non-compliances are reported to the NRC.

The Vice President, Nuclear, is designated as the IES Utilities Inc. officer responsible for reporting defects and non-compliances, as appropriate, to the NRC.

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17.2.16.5 Reportable Events i

Each reportable event shall be reviewed by the Operations Committee and a report shall be submitted to the Safety Committee and the Vice President, Nuclear.

i 17.2.17 QUALITY ASSURANCE RECORDS 17.2-29 Revision 20 TBD

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l 17.2.17.1 Scope l

Quality assurance records will be prepared, identified, collected, and protected so that adequate evidence of activities affecting quality is available.

i 17.2.17.2 Preparation and identification of Quality Assurance Records l

The organization responsible for the activity will also be responsible for the preparation and l

identification of the quality assurance records that attest to the quality of that activity.

As a general criterion, those documents that reflect the as-built condition of an item, component, system, or plant, and those documents that attest to the quality of an activity, item, structure, or system will be treated as quality assurance records. Also, the qualification records of inspection, examination and testing personnel, and quality assurance audit personnel, are classified as quality assurance records.

Quality assurance records will be legible, accurate, and complete.

l 17.2.17.3 Collection and Protection of Quality Assurance Records l

The quality assurance records will be collected, indexed, classified, and protected.

The organization that generates the quality assurance record will be responsible for collecting l

the records. The collected quality assurance records will be classified as either lifetime or non-l permanent quality assurance records. The lack of a classification will mean that the quality assurance record is a lifetime record.

The quality assurance records that have been identified and collected will be suitably protected against fire, theft, and damage. The manner in which the records are protected will be consistent with the retention period.

1 17.2.17.3.1 Retention of Records The following records shall be retained for at least 5 years:

1.

Records and logs of facility operation covering time interval at each power level, 1

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Records and logs of principal maintenance activities, inspections, and repair and j

replacement of principal items of equipment related to nuclear safety, 3.

All Licensee Event Reports, 4.

Records of surveillance activities, inspections and calibrations required by Technical Specification, i

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Records of reactor tests and experiments, 1

6.

Records of changes made to Operating Procedures, 7.

Records of radioactive shipments, I

8.

Records of sealed source leak test and results, 9.

Records of annual physicalinventory verifying accountability of sources on record, and

10. Records of radioactive effluent monitor setpoints and setpoint determinations.

l The following records shall be retained for the duration of the Facility Operating License 1.

Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report, 2.

Records of new and irradiated fuelinventory, fuel transfers and assembly burnup histories, 3.

Records of facility radiation and contamination surveys, 4.

Records of radiation exposure for all individuals for whom monitoring was required, 5.

Records of gaseous and liquid radioactive material released to the environment, 6.

Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles, 7.

Records of training and qualification for current members of the plant staff, 8.

Records of in-service inspections performed pursuant to the Technical Specifications, 9.

Records of Quality Assurance activities required by the QA Manual with the exception of the records to be retained for 5 years as noted above, l

10. Records of reviews performed for changes made to procedures or equipment or reviews for tests and experiments pursuant to 10CFR 50.59,

11. Records of meetings of the Operations Committee and the Safety Committee,

12. Records of the service lives of all safety-related hydraulic and mechanical snubbers including the date at which the service life commences and associated installation and maintenance records, 17.2-31 Revision 20 TBD l

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13. Records of results of analyses required by the radiological environmental monitoring

program,

14. Records of reviews performed for changes made to the Offsite Dose Assessment Manual and the Process Control Program.

17.2.17.4 Record Storage on Optical Disks Records may be stored on an optical disk storage system which utilizes a write once read many (WORM) system. The image of each record shall be placed onto two optical disks, with verification of the image on each record. Should any of the images be illegible, the hard copy record is maintained as the record. One optical disk shall be used for on-line access and the second optical disk shall be stored in a records storage facility meeting the requirements for single copy storage or in a separate remote location meeting the requirements of IES Utilities Inc. commitment to ANSI N45.2.9-1974.

To ensure permanent retention of records, the records stored on an optical disk are acceptably copied onto a new optical disk before the manufacturer's certified usefullife of the original disk is exceeded. Records copied shall be verified.

Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.

Should it become necessary to replace the optical imaging system with a new system which is not compatible, the records stored on the old system shall be converted onto the new system prior to the old system being taken out of service. This conversion process shallinclude a verification of the records converted.

17.2.17.5 Transfer or Destruction of Records The organization responsible for the quality assurance record will be responsible for the transfer of that quality assurance record for the purposes of microfilming and/or lifetime storage.

The transfer of quality assurance records from orie organization to another organization will be accomplished by a formal mechanism that provides for the acceptance of the quality assurance record.

The destruction of quality assurance records will be accomplished only with the approval of the concerned organizations.

l 17.2.18 AUDITS 17.2-32 Revision 20 TBD l

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17.2.18.1 Scope A comprehensive audit program will be established and implemented.

The audit program will be sufficient to verify compliance with the Operational Quality Assurance Program and to determine the effectiveness of the Operational Quality Assurance Program.

The responsibility for the audit system will be that of the Quality Assurance Department, the l

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Safety Committee, and the Vice President, Nuclear.

17.2.18.2 Audit System The audit system will be applied to those organizations, both extemal and internal to IES Utilities Inc., that are involved in safety-related activities.

17.2.18.2.1 External Organizations The audit program for suppliers is the responsibility of the Quality Assurance Department.

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Audits will be scheduled at a frequency commensurate with the status and importance of the activity.

In general, the audit schedule will be responsive to the performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met.

In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.

17.2.18.2.2 Internal Organizations The audit prograrn for the internal IES Utilities Inc. organizations is the responsibility of the following:

1.

The Quality Assurance Department, to determine the compliance of the other l

organizations to the Operational Quality Assurance Program and to evaluate performance, 2.

The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance, and 3.

The Vice President, Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.

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A prominent factor in developing and revising audit schedules will be performance in the subject area. The audit schedule will be revised so that weak or declining areas get increased audit l

coverage and strong areas receive less coverage.

An audit of safety related functions will be performed at least once per 24 months, except where a specific frequency is listed. Other audits will be performed as required by regulations.

Audits of facility activities performed under the cognizance of the Safety Committee include:

1.

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions, I

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The performance, training and qualifications of the facility staff, 3.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety, 4.

The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix "B",10 CFR Part 50, i

5.

The DAEC fire protection program and implementing procedures. An independent l

fire protection and loss prevention inspection and audit will be performed annually l

utilizing either qualified offsite licensee personnel or an outside fire protection firm.

An inspection and audit by an outside qualified fire consultant will be performed at intervals no greater than three years, i

6.

Any other area of facility operation considered appropriate by the Safety Committee or the President, 7.

The radiological environmental monitoring program and the results thereof, 8.

The Offsite Dose Assessment Manual and implementing procedures, 9.

The Process Control Program and implementing procedures,

10. The performance of activities required by the QC Program for effluent and the vendor's QA Program for radiological environmental monitoring, and

11. Design change package safety evaluations.

l Audit reports for audits performed under the cognizance of the Safety Committee will be i

i forwarded to the President and to the management position responsible for the areas audited within 30 days after completion of the audit.

17.2.18.3 Personnel Training and Qualification 17.2-34 Revision 20 i

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The personnel who participate in audits will have sufficient experience and/or training to fulfill their role in the audit.

Personnel who perform as Lead Auditors will be trained, qualified, and certified.

. A Lead Auditor will review the experience of each potential team member, determine their l

acceptability to perform the audit, determine if any additional training is required, and ensure that the additional training is performed if required.

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17 2.18.4 Performance of Audit

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l-Tt e selected audit team shall collectively have experience or training commensurate with the total scope of the audit.

l Audit checklists will be developed for the total scope of the audit.

The audit shall be initiated by a pre-audit conference to introduce the audit team and to confirm the scope and plan of the audit. A pre-audit planning meeting as defined in Appendix A may be l

substituted for the pre-audit conference.

l Audits shall be concluded by the Audit Team with a post-audit conference at which the Audit Team will discuss the audit findings and clarify any misunderstandings.

17.2.18.5 Report and Closeout of Audit Findings

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The audit will be documented by an audit report signed by a Lead Auditor.

The audit report shall be sent to the responsible management of the audited organization.

The audit findings will be tracked to ensure that corrective action has occurred.

The Quality Assurance Department will evaluate the responses to the audit findings. The l

l evaluation will include the necessity for re-audits, submittal of documentation, or any other means of verifying the corrective action. Statements by the audited organization that define the corrective action may be accepted.

l The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings.

Inadequate or unresponsive corrective action will be brought to the attention of appropriate levels of management.

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l IES Utilities Inc.

Appendix A to UFSAR/DAEC-1 Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD) l INTRODUCTION This Appendix describes the manner by which the IES Utilities Inc. Operational Quality Assurance Program for the Duane Arnold Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the June 6,1990, letter from Region 111 (Miller) to lowa Electric (Liu) and certain other commitments previously contained in Table 2-1 of the Quality Assurance Manual.

Comments and clarifications to these specific commitments are identified in this Appendix.

IES Utilities Inc. position on each ANSI standard which is endorsed by a Regulatory Guide to which IES Utilities Inc. is committed is stated in either the UFSAR or the QAPD. Other ANSI standards are not requirements for IES Utilities Inc. even if they are listed as references in a l

standard endorsed by a Regulatory Guide to which IES Utilities Inc. is committed. (Such standards may, of course, be used as guidance.) However, a section of a standard which is specifically referred to in a standard endorsed by a Regulatory Guide to which IES Utilities Inc.

is committed is a requirement for IES Utilities Inc. unless an exception is stated.

IES Utilities Inc. is not committed to ANSI N45.2 for the operational phase. Regulatory Guide 1.33, Revision 2, Section B, " Discussion" states ANSI N18.7-1972, along with ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants", was endorsed by Regulatory Guide 1.33. The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users. To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program " requirements" for the operation phase. This revised standard was approved by the American National Standards Committee N18, Nuclear Design Criteria. It was subsequently approved and designated N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants", by the American National Standards Institute on February 19,1976. Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the use of ANSI N45.2 in conjunction with that Standard, IES Utilities Inc. inserts the ANSI Standard N18.7-1976.

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1.0 REGULATORY GUIDE 1.8. " Personnel Selection and Trainina" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

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1.1 IES Utilities Inc's. commitment is to Regulatory Guide 1.8, Revision 1-R, September 4

1975 (reissued May 1977), which endorses ANSI N18.1-1971. However, the IES Utilities Inc. commitment is to ANSI /ANS 3.1-1978, which is a revision of N18.1-1971.

l 1.2 With respect to selection and training of security personnel, IES Utilities Inc. does not commit to the standard [ ANSI N18.17-1973 (ANS 3.3)] referred to in ANSI /ANS 3.1-1 1978, Sections 1 (Scope) and 6 (References). The IES Utilities Inc. training and l

qualification plan for security personnel complies with 10 CFR Part 73, Appendix B.

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2.0 REGULATORY GUIDE 1.26. " Quality Group Classifications and Standards for Water.

Steam. and Radioactive-Waste-Containina Components of Nuclear Power Plants" l

1 COMMENTS AND CLARIFICATIONS:

I, The IES Utilities Inc. commitment to Safety Guide 26 (3/23/72), Quality Group Classifications and Standards, is stated in UFSAR Chapter 1.8, Conformance to NRC Regulatory Guides.

3.0 REGULATORY GUIDE 1.28. " Quality Assurance Proaram Reauirements (Dasian and Construction)"

COMMENTS AND CLARIFICATIONS:

This Regulatory Guide (Safety Guide 28, dated June 7,1972) endorses ANSI N45.2 and is not applicable to the operating phase. DAEC's operational QA program is based on Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section 1.8.

4.0 REGULATORY GUIDE 1.29. " Seismic Desian Classification" COMMENTS AND CLARIFICATIONS:

The IES Utilities Inc. commitment to Safety Guide 29 (6/7/72), Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.

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5.0 REGULATORY GUIDE 1.30. " Quality Assurance Reauirements for the Installation.

inspection. and Testina of Instrumentation and Electric Eauipment" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

5.1 The IES Utilities Inc. commitment is to Safety Guide 30, dated August 11,1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses.

5.2 For maintenance and modification activities, IES Utilities Inc. shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein (subject to the clarifications below) shall apply.

Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (g1 Code requirements, design and construction specification requirements, and inspection requirements).

5.3 Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971. In lieu of this, IES Utilities Inc. uses ANSI N45.2.4-1972 in conjunction with ANSI N18.7-1976.

5Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..4 Section 2.2(5)(d) of ANSI N45.2.4-1972 requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, before the requirements of ANSI N45.2.4-1972 are implemented. In lieu of this, IES Utilities Inc. may proceed with installation, inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been identified and controlied in accordance with IES Utilities Inc.'s nonconformance reporting system.

5.5 With respect to Section 2.5.2 of ANSI N45.2.4-1972, calibration and control covers two classes of instrumentation used by IES Utilities Inc.: (1) portable equipment and (2) permanently-installed equipment. With respect to permanently-installed instrumentation, in lieu of marking the equipment to indicate the date of the next required calibration, a computer-based preventative maintenance prograrn is used.

Once a permanently-installed instrument is identified as needing control, a calibration frequency is assigned, and the information is entered into the data base. The calibration task is then automatically tracked and tasked by the data base. A "DO NOT USE Until Tested and Calibrated" or equivalent sticker is applied to instruments not calibrated before their due date and to instruments unacceptable for use. The provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment.

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5.6 Section 3 of ANSI N45.2.4-1972 regarding " Preconstruction Verification" states it is necessary to verify that the quality of an item has not suffered during the interim period and it is not intended to duplicate inspections but rather verify that items are in a satisfactory condition for installation. Verifications and checks are then required. In lieu of these verifications and checks, IES Utilities Inc. considers the provisions of QAPD Sections 17.2.'8 (identification and Control of Materials, Parts, and Components) and 17.2.13 (Handling, Storage and Shipping) to be equivalent.

5.7 The last paragraph of Section 6.2.1 of ANSI N45.2.4-1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and

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identity of person who performed the calibration. In lieu of this, for permanently-installed instrumentation, the calibration status is reflected in a computerized preventive rnaintenance program as described in Section 5.5 above.

6.0 REGULATORY GUIDE 1.33. " Quality Assurance Procram Reauirements (Ooeration)"

COMMENTS AND CLARIFICATIONS:

l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications-6.1 The commitment is to Regulatory Guide 1.33, Rev. 2, February 1978, and to ANSI N18.7-1976/ANS-3.2 which it endorses.

6.2 Regulatory Guide 1.33 Regulatory Position, Section C.2, also lists fifteen Regulatory Guides and ANSI standards that are referenced in ANSI N18.7-1976/ANS-3.2. The IES Utilities Inc. position with respect to each of these standards is stated elsewhere in this Appendix A.

6.3 Regulatory Guide 1.33 Regulatory Position, Section C.4, refers to Section 4.5, " Audit i

Program", of ANSI N18.7-1976/ANS-3.2 and lists specified audit frequencies for three j

(3) audits. The frequencies for audits are now specified in UFSAR Section 17.2.18.2.2.

6.4 Section 4.3.2, " Standing Committees Functioning as Independent Review Bodies" of ANSI N18.7-1976/ANS-3.2 describes the composition, quorum requirements, and meeting records of the committees functioning as independent review bodies. The Safety Committee and the Operations Committee implement such requirements as

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follows:

6.4.1 The Operations Committee shall function to advise the Plant Manager on all matters l

related to nuclear safety. The committee shall be composed of Managers, Supervisors and personnel selected from the following departments: Operations, Outage Management, Maintenance, Reactor Engineering, Radiation Protection, l

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l Quality Assurance, Systems Engineering and Licensing. The Manager, Outage and l

Support shall act as the Chairman. One or more of the members shall be designated as Vice Chairman. All alternate members shall be appointed in writing by the Plant Manager to serve on a permanent basis; however, no more than three alternates shall participate as voting members in Operations Committee activities at any one time.

The committee shall meet at least once per calendar month and as convened by the Operations Committee Chairman or Vice Chairman. A quorum of the Operations Committee shall consist of the Chairman or Vice Chairman and five members including alternates.

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The Operations Committee shall be responsible for:

l a) review of (1) written procedures, and changes thereto, involving nuclear Fafety, including applicable check off lists and instructions, covering areas Ested below.

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These procedures shall be approved by the Plant Manager or designee prior to implementation, except as provided in Section 6.7.

1 1.

Normal startup, operation, and shutdown of systems and components of the facility.

2. Refueling operation.

3. Actions to be taken to correct specific and foreseen potential malfunctions of systems or components, including responses to alarms, suspected primary system leaks, and abnormal reactivity changes.

4. The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33.

5. Preventive and corrective maintenance operations which could have an effect on nuclear safety of the facility.

6. Surveillance and testing requirements of equipment that could have an effect on the nuclear safety of the facility.

7. Operation of radioactive waste systems

8. Fire Protection Program implementation

9. A preventive maintenance and periodic visual examination program to reduce leakage from systems outside containment that would or could contain highly l

radioactive fluids during a serious transient to as low as practical levels. This l

program shall also include provisions for performance of periodic systems leak j

tests of each system once per Operating Cycle.

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10. Program to ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions, including training of personnel, procedures for monitoring arm provisions for maintenance of sampling and analysis equipment.

11. Administrative procedures for shift overtime for Operations personnel to be consistent with Commission's June 15,1982 policy statement.

12. Offsite Dose Assessment Manual.

13. Process Control Program.

14. Quality assurance for effluent and environmental monitoring l

(2) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety.

b) Review of all proposed tests and experiments that affect nuclear safety.

c) Review of all proposed changes to the Technical Specifications.

d) Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

e) Investigation of all violations of the Technical Specifications including the preparation j and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President, Nuclear and the Chairman of the Safety Committee.

f) Review of all Reportable Events.

g) Review of facility operational to detect potential safety hazards.

h) Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman of the Safety Committee.

i) Review of Plant Security Plan.

j) Review of Emergency Plan.

k) Review of every unplanned release of radioactivity to the environs for which report to the NRC is required.

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l} Review of changes to the Offsite Dose Assessment Manual and changes to the l

Process Control Program.

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m) Review of the Fire Protection Program and implementing procedures.

The Operations Committee has the authority to:

l recommend to the Plant Manager written approval or disapproval items (a) through l

(d) above, render determinations in writing with regard to whether or not each item (a) through e

(e) above constitutes an unreviewed safety question, provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President, Nuclear and the Safety Committee of disagreement between the Operations Committee and the Plant Manager; however, the Plant Manager shall have responsibility for resolution j

for such disagreements.

The Operations Committee shall maintain written minutes of each meeting and copies shall be provided to the Vice President, Nuclear and the Chairman of the Safety Committee.

6.4.2 The Safety Committee shall function to provide independent review and audit of designated activities in the areas of :

a) Nuclear power plant operations b) Nuclear engineering c) Chemistry and radiochemistry d) Metallurgy e) Instrumentation and control f) Radiological safety g) Mechanical and electrical engineering h) Quality Assurance practices i) Non-destructive testing j) Administration 17.2 A-7 Revision 20 TBD l

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The Safety Committee shall be composed of persons who have been appointed in writing by the President, IES Utilities Inc. to serve on a permanent basis and who l

collectively have or have access to applicable technical and experimental expertise in the a. through J. areas above. All attemate members shall be appointed in writing by the President, IES Utilities Inc. to serve on a permanent basis. Consultants shall be l

utilized as determined by the Safety Committee Chairman to provide expert advice to the Safety Committee. The Safety Committee shall meet at least once per calendar quarter during the initial year of facility operation following fuel load and at least once per six months thereafter. A quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maximum of two alternates as voting members. No more than a minority of the voting members shall have line responsibility for operation of the facility.

The Safety Committee shall be responsible for the review of :

a) The safety evaluation for (1) changes to procedures, and (2) tests or experiments completed under the provisions of Section 50.59,10CFR, to verify that such actions did not constitute an unreviewed safety question.

b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10CFR.

c) Proposed tests or experiments which involved an unreviewed safety question as defined in Section 50.59,10CFR d) Proposed changes in Technical Specifications or licenses.

e) Violations of appiicable statutes, codes, regulations, orders, techrdcal specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f) Significant operating abnormahties or deviations from normal and expected performance of plant equipment that affect nuclear safety.

g) All reportable events.

h) All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components.

i) Reports and meeting minutes of the Operations Committee.

The Safety Committee shall report to and advise the President on those areas of responsibility specified for items (a) through (i) above. Records of Safety Committee activities shall be prepared, approved, and distributed as noted below:

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4 a) Minutes of each Safety Committee meeting shall be prepared, approved, and forwarded to the President within 14 days following each meeting.

b) Reports of reviews for items (a) through (i) above shall be prepared, approved and forwarded to the President within 14 days following completion of the review.

l 6.5 With respect to Section 4.3.4 (1), Subjects Requiring Independent Review, of ANSI N18.7-1976/ANS-3.2, the DAEC Safety Committee is not required to review safety evaluations of changes in the facility which are completed under 10 CFR Part 50.59.

6.6 Section 5.1 (Program Description) of ANSI N18.7-1976/ANS-3.2 requires a " summary document" for the Quality Assurance Program. The QAPD and Appendix A thereto fulfill this requirement for IES Utilities Inc.

6.7 Section 5.2.2 (Procedure Adherence) of ANSI N18.7-1976/ANS-3.2 states that temporary procedure changes which do not change the intent of the procedure are l

l required to be approved by two members of the plant staff, of which one shall hold a senior operators license. In lieu of one of these members being the on-shift senior operator, a non-shift senior licensed operator may approve of these temporary changes.

These temporary minor changes shall be documented and promptly reviewed by the Operations Committee and by the Plant Manager or designee. Subsequent l

l incorporation, if necessary, as a permanent change, shall be in accord with approved procedure review and approval procedures.

i 6.8 Not Used 6.9 Section 5.2.7 (Maintenance and Modifications) of ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities occurring during the operational phase that are comparable to related activities during design and construction. Five of these standards are addressed elsewhere in this Appendix A.

IES Utilities Inc. does not follow one of those listed, ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities. See UFSAR Section 17.2.9.5 for IES Utilities Inc.'s controls relative to "Special Protective Coatings".

6.10 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.

However, the Standard references ANSI N18.17 for guidance. IES Utilities Inc. is not committed to ANSI N18.17. The DAEC Security Plan complies with 10 CFR Part 73.

6.11 Section 5.2.15 (Review, Approval and Control of Procedures) of ANSI N18.7-1976/ANS-3.2, fourth paragraph requires:

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" Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

This requirement is replaced by the following:

" Plant procedures shall be reviewed, in accordance with the following, to determine if l

changes are necessary or desirable:

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1) Non-routine procedures, such as emergency operating procedures, off-normal l

procedures, those that implement the emergency plan, and others where usage mr be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.

2) The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.

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3) Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process. The need for changes to these procedures are identified through other processes, such as: plant modifications; nonconformance reporting system; test control; performance of operations and maintenance activities; updates to the Updated Final Safety Analysis Report (UFSAR);

l vendor manual control, reviews of industry operating experience; Operating / License Amendments; design specification changes; control of procedure changes; Quality Assurance audits; training; and other routine activities under the Quality Assurance Program. In addition, on a frequency not to exceed 2 years, an independent audit or assessment of a representative sample of routine plant procedures shall be performed j

to evaluate the effectiveness of the procedure review and revision program.

6.12 Section 5.2.16 (Measuring and Test Equipment) of ANSI N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status. Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of the person who performed the calibration. See the discussion provided in Section 5.5 of this document for IES Utilities inc.'s commitment.

6.13 Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI N18.7-1976/ANS-3.2, of IES Utilities Inc.'s DAEC Emergency l

Operating Procedures (EOPs) are in a flowchart format. The format and contents of the DAEC Emergency Operating Procedures are based upon the BWR Owner's Group (BWROG) Emergency Procedure Guidelines (EPGs) Revision 4 and the associated 4

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l generic NRC SER and were updated in accordance with the Emergency Procedure Guidelines / Severe Accident Guidelines (EPGs/ SAGS) Revision 1.

l 7.0 REGULATORY GUIDE 1.37. " Quality Assurance Reauirements for Cleanina of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" l

l COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

7.1 The commitment is to Regulatory Guide 1.37, Revision 0,3/16/73, and to ANSI N45.2.1-1973 which it endorses.

l 7.2 IES Utilities Inc. shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (e.a.. Code requirements, design and construction specification requirements, and inspection requirements).

l 8.0 REGULATORY GUIDE 1.38. " Quality Assurance Reauirements for oackaaina.

Shiopina. Receivina. Storaae. and Handlina of items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

8.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972. However, the IES Utilities Inc. commitment is to the later version of this Standard, ANSI /ASME N45.2.2-1978.

8.2 The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs of the Regulatory Guide relating to these Sections l

(C.1.c, C.1.e, and C.2), is limited to the procurement of major plant equipment l

replacements; they are not applied to procurement of operating plant spares and modifications.

t 8.3 The shipping damage inspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by Storekeepers prior to unloading in lieu of ANSI N45.2.6 certified 17.2 A-11 Revision 20 TBD i

inspectors. A shipping damage inspection is performed by ANSI N45.2.6 certified t

inspectors at a later point in the receiving process for applicable items.

9.0 REGULATORY GUIDE 1.39. "Housekeepina Reauirements for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarification:

9.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.39. Revision 2, September 1977, and to ANSI N45.2.3-1973 which it endorses..

10.0 REGULATORY GUIDE 1.54. " Quality Assurance Reauirements for Protective Coatinos Apolied to Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. is not committed to Regulatory Guide 1.54, June 1973. IES Utilities Inc.'s controls relative to protective coatings are contained in UFSAR Section 17.2.9.5.

11.0 REGULATORY GUIDE 1.58. " Qualification of Nuclear Power Plant inspection.

Examination. and Testina Personnel" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

11.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.58, Revision 1, September 1980, and to ANSI N45.2.6-1978 which it endorses.

11.2 ANSI N45.2.6-1978 Section 1.2, " Applicability", first paragraph, states that this standard applies to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.

The qualification of inspection perseel shall be documented on the basis of either this standard (i.e., ANSI N45.2.6-1978) or on the basis of task qualification in l

accordance with Regulatory Guide 1.8, Revision 1-R, May 1977 and ANSI /ANS 3.1 -

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1978. The basis for deciding which method is used for qualification is described below:

1 Personnel performing inspections as of October 1,1995, are certified to this e

standard (ANSI N45.2.6-1978) for the performance of inspections.

Personnel contracted to perform inspections at the DAEC will continue to be qualified for the performance of inspections in accordance with this standard (ANSI N45.2.6-1978).

Effective with the approval of Revision 16 to the DAEC QADP Quality Assurance Program Description, craft personnel may become qualified to perform inspection by the successful completion of the training for that task. For example, the performance of dimensional measurements by a craftsperson in the performane l

of a repair activity is an equivalent task performed by an inspector qualified pei I

ANSI N45.2.6 - 1978 for performing dimensional measurements. In addition to this task qualification, craft personnel qualified in accordance with this method shall also receive an annual eye examinstlon for vision and color acuity.

Personnel performing testing activities shall have appropriate experience and l

training to assure cornpetence in accordance with Regulatory Guide 1.8 l

(ANSI /ANS 3.1-1978).

11.3 ANSI N45.2.6 Section 1.2, " Applicability", third paragraph, requires that this standard be used in conjunction with ANSI N45.2. IES Utilities Inc. is not committed to ANSI N45.2.

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11.4 ANSI N45.2.6 Section 1.2, " Applicability", fourth paragraph, requires that this standard be applied to organizations other than IES Utilities Inc. The specific applicability of this standard to other organizations is specified on a case-by-case basis in the procurement documents issued to those suppliers of materials and services.

t 11.5 Regulatory Guide 1.58 Revision 1, in Section B, " Discussion", endorses ASNT l

Recommended Practice No. SNT-TC-1 A-1975 for the qualification of nondestructive I

testing personnel. In accordance with the IES Utilities Inc. ASME Section XI program l

the 1989 Edition shall govern. Section IWA-2300 of this Code requires nondestructive personnel to be qualified to SNT-TC-1A-1984.

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l 12.0 REGULATORY GUIDE 1.64. " Quality Assurance Reauirements for the Desian of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

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IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide. The l

IES Utilities Inc. commitment is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-11-1974 which it endorses.

l 13.0 REGULATORY GUIDE 1.74. " Quality Assurance Terms and Definitions" COMMENTS AND CLARIFICATIONS:

l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

13.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.

13.2 IES Utilities Inc. has adopted the definition of " Audit" which appears in ANSI /ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.

14.0 REGULATORY GUIDE 1.88. " Collection. Storace. and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies w?h the Regulatory Position of this Regulatory Guide with the following clarifications:

14.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9-1974 which it endorses.

14.2 Section 3.2.2 of ANSI N45.2.9-1974 specifies establishment of an "index". As we understand this term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the informatior, attributed to an "index"in the Standard. Record retention requirements for records are specified. The specific retention times for records are indicated when the records are i

transmitted for permanent storage. IES Utilities Inc. utilizes computer-aided retrieval systems to index and locate records.

14.3 Section 5 of ANSI N45.2.9-1974, " Storage, Preservation and Safekeeping", provides no distinction between temporary and permanent facilities. To address temporary storage, the following position is established: Active records (those completed but not yet duplicated or placed on microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are duplicated or microfilmed. Open-ended documents-those revised or updated on a more-or-less continuing basis over an 17.2 A-14 Revision 20 TBD

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extended period of time (el personnel qualification and training documents) and i

those which are cumulative in nature (el nonconforming item logs and control room log books)-are not considered as QA records since they are not " complete" These types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on-going document shall be transferred to permanent storage as a " record".

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14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.

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14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemenMd only for the permanent record files and not for temporary record files.

15.0 REGULATORY GUIDE 1.94. " Quality Assurance Reauirements for Installation.

Inspection. and Testina of Structural Concrete and Structural Steel Durina the Construction Phase of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with I

the following clarifications:

15.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.94, Revision 1, April 1976, and to ANSI N45.2.5-1974 which it endorses.

15.2 For modification activities IES Utilities Inc. shall comply with the Regulatory Position l

established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply. Technical requirements associated with j

modification activities shall be equal to or better than the original requirements (_eJL e

Code requirements, design and construction specification requirements, and inspection requirements).

16.0 REGULATORY GUIDE 1.116. " Quality Assurance Reauirements for Installation.

Inspection. and Testina of Mechanical Eauipment and Systems" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

16.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.116, Revision O-R, June l

1976, with first page revision May 1977, and to ANSI N45.2.8-1975 which it endorses.

17.2 A-15 Revision 20 TBD

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16.2 IES Utilities Inc.'s commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (e.a..

Code requirements, design and construction specification requirements, and inspection requirements).

17.0 REGULATORY GUIDE 1.123. " Quality Assurance Reauirements for Control of Procurement of items and Services for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Ir.c. complies with the Regulatory Position of this Regulatory Guide with the following clcrifications:

17.1 The IES Utilities Inc. ccmmitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13 976 which it endorses.

18.0 REGULATORY GUIDE 1.144. "Auditina of Quality Assurance Proorams for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

18.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.144, Revision 1, September 1980, and to ANSI N45.2.12-1977 which it endorses.

18.2 Section 1.1, " Scope", and Section 1.2, " Applicability", of ANSI N45.2.12-1977 reference ANSI N45.2. lES Utilities Inc. is committed to ANSI N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.

18.3 Regulatory Pc3ition C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2, " Acceptance by Receiving inspection", of ANSI l

N45.2.13-1976. The suppliers of products that meet this requirement are included on the IES Utilities Inc. external audit schedule and are audited on a triennial basis.

i 18.4 ANSI N45.2.12, Section 4.3.1 " Pre-Audit Conference" 17.2 A-16 Revision 20 TBD 1

For internal audits, a " pre-audit planning meeting" may be substituted for the " pre-audit conference." The pre-audit planning meeting should accomplish the following:

1) The Lead Auditor to present the proposed audit plan and an opportunity for the audited organizations to provide input to the proposed audit plan.

2) Introduce the Lead Auditor and identify proposed audit team members. Those audit team members available will be introduced. Note: Non-utility team members are usually not available at these meetings.

3) Counterparts are invited to these audit planning meetings as part of the planning process.

4) The audit schedule is presented, including a tentative exit date. The final exit date is announced separately during the audit period.

5) The channels c,f communication are opened at the audit planning meeting through participation in the audit planning process.

6) Following the audit planning meeting, the Lead Auditor will finalize the audit plan.

18.5 in lieu of an annual supplier evaluation specified by Regulatory Position C.3.b(2), a documented ongoing evaluation of the supplier should be performed. Where applicable, this evaluation should take into account (1) review of supplier-furnished documents such as certificates of conformance, non-conformance notices, and corrective actions, (2) results of previous source verifications, audits, and receiving inspections, (3) operating experience of identical or similar products furnished by the same supplier, and (4) results of audits from other sources, e.g., customer, ASME, or NRC audits. The results of the evaluations should be reviewed and appropriate corrective action should be taken. Adverse findings resulting from these evaluations should be periodically reviewed in order to determine if, as a whole, they result in a significant condition adverse to quality and to provide input to support supplier audit activities conducted by IES Utilities or a third party auditing entity.

19.0 REGULATORY GUIDE 1.146. " Qualification of Quality Assurance Proaram Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

19.1 The IES Utilities Inc commitment is to Regulatory Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.

19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2. For IES Utilities Inc., the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976. This is consistent with IES Utilities Inc.'s commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI N45.2.

17.2Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>17.2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. A-17 Revision 20 TBD

l 19.3 in lieu of ANSI N45.2.23 Section 2.3.4, prospective lead auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. This demonstration process shall be described in written procedures or I

instructions. The demonstration shall be evaluated and the results documented.

Regardless of the methods used for the demonstration, the prospective lead auditor shall have participated in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Upon successful i

demonstration of the ability to effectively implement the audit process and effectively i

lead audits, and having met the other provisions of Section 2.3 of ANSI N45.2.23 -

l 1978, the individual may be certified as being qualified to lead audits.

j 20.0 REGULATORY GUIDE 1.155. " Station Blackout" l

l COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with Appendix A, " Quality Assurance Guideline for Non-l Safety Systems and Equipment," to Regulatory Guide 1.155, Revision 1, August 1988.

21.0 REGULATORY GUIDE 4.15. " Quality Assurance for Radioloaical Monitorino Proarams (Normal Ooerations)- Effluent Streams and the Environment" l

COMMENTS AND CLARIFICATIONS lES Utilities Inc. complies with the Regulatory Position in Regulatory Guide 4.15, Revision 1, February 1979.

22.0 ASME B&PV Code.Section XI.1989 Edition with no Addenda COMMENTS AND CLARIFICATIONS:

The IES Utilities Inc. commitments relative to the Ten-Year inspection Program and the Pump and Valve Test Program are established separately in formal correspondence with the Nuclear Regulatory Commission and incorporated into appropriate IES Utilities Inc. documents.

17.2 A-18 Revision 20 TBD

1 lES Utilita %.

Appendix A to UFSAR/DAEC-1 Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD) l INTRODUCTION l

This Appendix describes the manner by which the IES Utilities Inc. Operational Quality j

Assurance Program for the Duane Amold Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the June 6,1990, letter from Region ill (Miller) to lowa Electric (Liu) and certain l

4 other commitments previously contained in Table 2-1 of the Quality Assurance Manual.

Comments and clarifications to these specific commitments are identified in this Appendix.

i l

IES Utilities Inc. position on each ANSI standard which is endorsed by a Regulatory Guide to j

which IES Utilities Inc. is committed is stated in either the UFSAR or the QAPD. Other ANSI standards are not requirements for IES Utilities Inc. even if they are listed as references in a j

standard endorsed by a Regulatory Guide to which IES Utilities Inc. is committed. (Such standards may, of course, be used as guidance.) However, a section of a standard which is j

specifically referred to in a standard endorsed by a Regulatory Guide to which IES Utilities Inc.

is committed is a requirement for IES Utilities Inc. unless an exception is stated.

i IES Utilities Inc. is not committed to ANSI N45.2 for the operational phase. Regulatory Guide 1.33, Revision 2, Section B, " Discussion" states ANSI N18.7-1972, along with ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants", was endorsed by Regulatory Guide 1.33. The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 i

CFR Part 50; however, this dual endorsement caused some confusion among users. To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program " requirements" for the operation phase. This revised standard was approved by the American National Standards Committee N18, Nuclear Design Criteria. It was subsequently approved and designated N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants", by the American National Standards Institute on February 19,1976. Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the use of ANSI N45.2 in conjunction with that Standard, IES Utilities Inc. inserts the ANSI Standard N18.7-1976.

17.2 A-1 Revision 20 TBD l

I l

j 1.0 REGULATORY GUIDE 1.8. " Personnel Selection and Trainina" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

1.1 IES Utilities Inc's. commitment is to Regulatory Guide 1.8, Revision 1-R, September 1975 (reissued May 1977), which endorses ANSI N18.1-1971. However, the IES Utilities Inc. commitment is to ANSI /ANS 3.1-1978, which is a revision of N18.1-1971.

1.2 With respect to selection and training of security personnel, IES Utilities Inc. does not commit to the standard [ ANSI N18.17-1973 (ANS 3.3)] referred to in ANSI /ANS 3.1-1978, Sections 1 (Scope) and 6 (References). The IES Utilities Inc. training and j

qualification plan for security personnel complies with 10 CFR Part 73, Appendix B.

2.0 REGULATORY GUIDE 1.26. " Quality Group Classifications and Standards for Water.

Steam. and Radioactive-Waste-Containina Components of Nuclear Power Plan.ts" COMMENTS AND CLARIFICATIONS:

The IES Utilities Inc. commitment to Safety Guide 26 (3/23/72), Quality Group Classifications and Standards, is stated in UFSAR Chapter 1.8, Conformance to NRC Regulatory Guides.

3.0 REGULATORY GUIDE 1.28. " Quality Assurance Proaram Reauirements (Desian and Construction)"

COMMENTS AND CLARIFICATIONS:

This Regulatory Guide (Safety Guide 28, dated June 7,1972) endorses ANSI N45.2 and is not applicable to the operating phase. DAEC's operational QA program is based on Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section 1.8.

4.0 REGULATORY GUIDE 1.29. " Seismic Desian Classification" COMMENTS AND CLARIFICATIONS:

The IES Utilities Inc. commitment to Safety Guide 29 (6/7/72), Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.

17.2 A-2 Revision 20 TBD

5.0 REGULATORY GUIDE 1.30. " Quality Assurance Reauirements for the Installation.

inspection. and Testina of instrumentation and Electric Eauipment" i

COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

5.1 The IES Utilities Inc. commitment is to Safety Guide 30, dated August 11,1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses.

5.2 For maintenance and modification activities, IES Utilities Inc. shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance l

program requirements included therein (subject to the clarifications below) shall apply.

Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (e L Code requirements, design j

and construction specification requirements, and inspection requirements).

i f

l-5.3 Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction i

with ANSI N45.2-1971. In lieu of this, IES Utilities Inc. uses ANSI N45.2.4-1972 in conjunction with ANSI N18.7-1976.

l 5.4 Section 2.2(5)(d) of ANSI N45.2.4-1972 requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, I

before the requirements of ANSI N45.2.4-1972 are implemented. in lieu of this, IES Utilities Inc. may pmceed with installation, inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been

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identified and controlled in accordance with IES Utilities Inc.'s nonconformance reporting system.

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5.5 With respect to Section 2.5.2 of ANSI N45.2.4-1972, calibration and control covers two classes of instrumentation used by IES Utilities Inc.: (1) portable equipment and (2) permanently-installed equipment. With respect to permanently-installed 1'

instrumentation, in lieu of marking the equipment to indicate the date of the next l

required calibration, a computer-based preventative maintenance program is used.

Once a permanently-installed instrument is identified as needing control, a calibration frequency is assigned, and the information is entered into the data base. The calibration task is then automatically tracked and tasked by the data base. A "DO NOT USE Until Tested and Calibrated" or equivalent sticker is applied to instruments not calibrated before their due date and to instruments unacceptable for use. The l

provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment.

i i

17.2 A-3 Revision 20 i

TBD

5.6 Section 3 of ANSI N45.2.4-1972 regarding " Preconstruction Verification" states it is necessary to verify that the quality of an item has not suffered during the interim period and it is not intended to duplicate inspections but rather verify that items are in a satisfactory condition for installation. Verifications and checks are then required. In lieu of these verifications and checks, IES Utilities Inc. considers the provisions of QAPD Sections 17.2.8 (identification and Control of Materials, Parts, and Components) and 17.2.13 (Handling, Storage and Shipping) to be equivalent.

5.7 The last paragraph of Section 6.2.1 of ANSI N45.2.4-1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of person who performed the calibration. In lieu of this, for permanently-installed instrumentation, the calibration status is reflected in a computerized preventive maintenance program as described in Section 5.5 above.

6.0 REGULATORY GUIDE 1.33. " Quality Assurance Proaram Reauirements (Operation)"

COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

6.1 The commitment is to Regulatory Guide 1.33, Rev. 2, February 1978, and to ANSI i

N18.7-1976/ANS-3.2 which it endorses.

6.2 Regulatory Guide 1.33 Regulatory Position, Section C.2, also lists fifteen Regulatory i

Guides and ANSI standards that are referenced in ANSI N18.7-1976/ANS-3.2. The l

IES Utilities Inc. position with respect to each of these standards is stated elsewhere in i

this Appendix A.

6.3 Regulatory Guide 1.33 Regulatory Position, Section C.4, refers to Section 4.5, " Audit Program", of ANSI N18.7-1976/ANS-3.2 and lists specified audit frequencies for three (3) audits. The frequencies for audits are now specified in UFSAR Section 17.2.18.2.2.

6.4 Section 4.3.2, " Standing Committees Functioning as Independent Review Bodies" of ANSI N18.7-1976/ANS-3.2 describes the composition, quorum requirements, and j

meeting records of the committees functioning as independent review bodies. The Safety Committee and the Operations Committee implement such requirements as follows:

i 6.4.1 The Operations Committee shall function to advise the Plant Manager on all matters l

related to nuclear safety. The committee shall be composed of Managers, Supervisors and personnel selected from the following departments: Operations, Outage Management, Maintenance, Reactor Engineering, Radiation Protection, l

4 i

17.2 A-4 Revision 20 TBD

Quality Assurance, Systems Engineering and Licensing. The Manager, Outage and l

Support shall act as the Chairman. One or more of the members shall be designated as Vice Chairman. All alternate members shall be appointed in writing by the Plant Manager to serve on a permanent basis; however, no more than three alternates shall participate as voting members in Operations Committee activities at any one time.

The committee shall meet at least once per calendar month and as convened by the Operations Committee Chairman or Vice Chairman. A quorum of the Operations Committee shall consist of the Chairman or Vice Chairman and five members including alternates.

The Operations Committee shall be responsible for:

a) review of (1) written procedures, and changes thereto, involving nuclear safety, including applicable check off lists and instructions, covering areas listed below.

These procedures shall be approved by the Plant Manager or designee prior to implementation, except as provided in Section 6.7.

1. Normal startup, operation, and shutdown of systems and components of the facility.

2. Refueling operation.

3. Actions to be taken to correct specific and foreseen potential malfunctions of systems or components, including resoonses to alarms, suspected primary system leaks, and abnormal reactivity changes.

4. The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33.

5. Preventive and corrective maintenance operations which could have an effect on nuclear safety of the facility.

6. Surveillance and testing requirements of equipment that could have an effect on the nuclear safety of the facility.

7. Operation of radioactive waste systems

8. Fire Protection Program implementation

9. A preventive maintenance and periodic visual examination program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient to as low as practicallevels. This program shall also include provisions for performance of periodic systems leak tests of each system once per Operating Cycle.

17.2 A-5 Revision 20 TBD

10. Program to ensure the capability to accurately determine the airbome iodine concentration in vital areas under accident conditions, including training of personnel, procedures for monitoring and provisions for maintenance of sampling and analysis equipment,

11. Administrative procedures for shift overtime for Operations personnel to be consistent with Commission's June 15,1982 policy statement.

12. Offsite Dose Assessment Manual.

13. Process Control Program.

14. Quality assurance for effluent and environmental monitoring l

(2) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety.

b) Review of all proposed tests and experiments that affect nuclear safety.

c) Review of all proposed changes to the Technical Specifications.

d) Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

e) Investigation of all violations of the Technical Specifications including the preparation l and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President, Nuclear and the Chairman of the Safety Committee.

f) Review of all Reportable Events.

g) Review of facility operational to detect potential safety hazards.

h) Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman of the Safety Committee.

i) Review of Plant Security Plan.

j) Review of Emergency Plan.

k) Review of every unplanned release of radioactivity to the environs for which report to the NRC is required.

17.2 A-6 Revision 20 TBD l

. -.- -.- ~...

I e

l} Review of changes to the Offsite Dose Assessment Manual and changes to the i

Process Control Program.

j i

m) Review of the Fire Protection Program and implementing procedures.

The Operations Committee has the authority to:

recommend to the Plant Manager written approval or disapproval items (a) through l

e (d) above, i

render determinations in writing with regard to whether or not each item (a) through j

e j

(e) above constitutes an unreviewed safety question, I

l provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President, Nuclear and the e

Safety Committee of dicagreement between the Operations Committee and the Plant Manager; however, the Plant Manager shall have responsibility for resolution l

for such disagreements.

The Operations Committee shall maintain written minutes of each meeting and copies I

shall be provided to the Vice President, Nuclear and the Chairman of the Safety Committee.

6.4.2 The Safety Committee shall function to provide independent review and audit of l

designated activities in the areas of :

f a) Nuclear power plant operations b) Nuclear engineering l

l c) Chemistry and radiochemistry I

d) Metallurgy e) Instrumentation and control f) Radiological safety j

g) Mechanical and electrical engineering h) Quality Assurance practices i) Non-destructive testing j) Administration i

i l

17.2 A-7 Revision 20 TBD

The Safety Committee shall be composed of persons who have been appointed in writing by the President, IES Utilities Inc. to serve on a permanent basis and who l

collectively have or have access to applicable technical and experimental expertise in the a. through j. areas above. All alternate members shall be appointed in writing by the President, IES Utilities Inc. to serve on a permanent basis. Consultants shall be l

utilized as determined by the Safety Committee Chairman to provide expert advice to the Safety Committee. The Safety Committee shall meet at least once per calendar quarter during the initial year of facility operation following fuel load and at least once per six months thereafter. A quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maximum of two alternates as voting members. No more than a minority of the voting members shall have line responsibility for operation of the facility.

The Safety Committee shall be responsible for the review of :

a) The safety evaluation for (1) changes to procedures, and (2) tests or experiments completed under the provisions of Section 50.59,10CFR, to verify that such actions did not constitute an unreviewed safety question.

b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10CFR.

c) Proposed tests or experiments which involved an unreviewed safety question as defined in Section 50.59,10CFR

~%

d) Proposed changes in Technical Specifications or licenses.

e) Violations of applicable statutes, codes, regulations, orders, technical specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f) Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

g) Ali reportable events.

h) All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components.

i) Reports and meeting minutes of the Operations Committee.

The Safety Committee shall report to and advise the President on those areas of responsibility specified for items (a) through (i) above. Records of Safety Committee activities shall be prepared, approved, and distributed as noted below:

17.2 A-8 Revision 20 TBD

a) Minutes of each Safety Committee meeting shall be prepared, approved, and forwarded to the President within 14 days following each meeting.

b) Reports of reviews for items (a) through (i) above shall be prepared, approved and I

forwarded to the President within 14 days following completion of the review.

6.5 With respect to Section 4.3.4 (1), Subjects Requiring Independent Review, of ANSI N18.7-1976/ANS-3.2, the DAEC Safety Committee is not required to review safety evaluations of changes in the facility which are completed under 10 CFR Part 50.59.

6.6 Section 5.1 (Program Description) of ANSI N18.7-1976/ANS-3.2 requires a " summary document" for the Quality Assurance Program. The QAPD and Appendix A thereto fulfill this requirement for IES Utilities Inc.

)

6.7 Section 5.2.2 (Procedure Adherence) of ANSI N18.7-1976/ANS-3.2 states that temporary procedure changes which do not change the intent of the procedure are required to be approved by two members of the plant staff, of which one shall hold a senior operators license. In lieu of one of these members being the on-shift senior operator, a non-shift senior licensed operator may approve of these temporary changes.

These temporary minor changes shall be documented and promptly reviewed by the Operations Committee and by the Plant Manager or designee. Subsequent l

incorporation, if necessary, as a permanent change, shall be in accord with approved procedure review and approval procedures.

6.8 Not Used 6.9 Section 5.2.7 (Maintenance and Modifications) of ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities occurring during the operational phase that are comparable to related activities during design and construction. Five of these standards are addressed elsewhere in this Appendix A.

IES Utilities Inc. does not follow one of those listed, ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities. See UFSAR Section 17.2.9.5 for IES Utilities Inc.'s controls relative to "Special Protective Coatings" 6.10 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.

However, the Standard references ANSI N18.17 for guidance. IES Utilities Inc. is not committed to ANSI N18.17. The DAEC Security Plan complies with 10 CFR Part 73.

6.11 Section 5.2.15 (Review, Approval and Control of Procedures) of ANSI N18.7-1976/ANS-3.2, fourth paragraph requires:

17.2 A-9 Revision 20 TBD

" Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

This requirement is replaced by the following:

" Plant procedures shall be reviewed, in accordance with the following, to determine if changes are necessary or desirable:

1) Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.

I

2) The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.

3) Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process. The need ior changes to these procedures are identified through other processes, such as: plant modifications; nonconformance reporting system; test control; performance of operations and maintenance activities; updates to the Updated Final Safety Analysis Report (UFSAR);

vendor manual control; reviews of industry operating experience; Operating / License Amendments; design specification changes; control of procedure changes; Quality Assurance audits; training; and other routine activities under the Quality Assurance Program. In addition, on a frequency not to exceed 2 years, an independent audit or l

assessment of a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.

6.12 Section 5.2.16 (Measuring and Test Equipment) of ANSI N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status. Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of the person who performed the calibration. See the discussion provided in Section 5.5 of this document for IES Utilities Inc.'s commitment.

6.13 Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI N18.7-1976/ANS-3.2, of IES Utilities Inc.'s DAEC Emergency Operating Procedures (EOPs) are in a flowchart format. The format and contents of the DAEC Emergency Operating Procedures are based upon the BWR Owner's Group (BWROG) Emergency Procedure Guidelines (EPGs) Revision 4 and the associated 17.2 A-10 Revision 20 TBD 3

l l

l

generic NRC SER and were updated in accordance with the Emergency Procedure Guidelines / Severe Accident Guidelines (EPGs/ SAGS) Revision 1.

l 7.0 REGULATORY GUIDE 1.37. " Quality Assurance Reauirements for Cleanina of Fluid i

Systems and Associated Components of Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

i 7.1 The commitment is to Regulatory Guide 1.37, Revision 0,3/16/73, and to ANSI N45.2.1-1973 which it endorses.

7.2 lES Utilities Inc. shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than i

the origina. requirements (e1 Code requirements, design and construction specification requirements, and inspection requirements).

8.0 REGULATORY GUIDE 1.38. " Quality Assurance Reauirements for oackaaina.

Shionina. Receivina. Storaae. and Handlina of items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS-IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

8.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972. However, the IES Utilities Inc. commitment is to the later version of this Ste.1dard, ANSl/ASME N45.2.2-1978.

8.2 The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs of the Regulatory Guide relating to these Sections (C.1.c, C.1.e, and C.2), is limited to the procurement of major plant equipment replacements; they are not applied to procurement of operating plant spares and modifications.

8.3 The shipping damage mspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by Storekeepers prior to unloading in lieu of ANSI N45.2.6 certified 17.2 A-11 Revision 20 TBD l

l l

e 1

' nspectors. A shipping damage inspection is performed by ANSI N45.2.6 certified i

inspectors at a later point in the receiving process for applicable items.

9.0 REGULATORY GUIDE 1.39. "Housekeepino Reauirements for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with I

the following clarification:

' 9.1 The IES Utilities Inc. commitment is to Regulatnry Guide 1.39, Revision 2, September 1977, and to ANSI N45.2.3-1973 which it endorses.

[.

10.0 REGULATORY GUIDE 1.54. " Quality Assurance Recuirements for Protective Coatinas Applied to Water-Cooled Nuclear Power Plants" l

COMMENTS AND CLARIFICATIONS:

l IES Utilities Inc. is not committed to Regulatory Guide 1.54, June 1973. IES Utilities l

Inc.'s controls relative to protective coatings are contained in UFSAR Section 17.2.9.5.

1 f

I 11.0 REGULATORY GUIDE 1.58. " Qualification of Nuclear Power Plant inspection.

Examination. and Testina Personnel" i

COMMENTS AND CLARIFICATIONS:

j IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

11.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.58, Revision 1 September 1980, and to ANSI N45.2.6-1978 which it endorses.

j 11.2 ANSI N45.2.6-1978 Section 1.2, " Applicability", first paragraph, states that this standard applies to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.

The qualification of inspection personnel shall be documented on the basis of either this standard (i.e., ANSI N45.2.6-1978) or on the basis of task qualification in i

accordance with Regulatory Guide 1.8, Revision 1-R, May 1977 and ANSI /ANS 3.1 -

17.2 A-12 Revision 20 TBD l

l l

1978. The basis for deciding which method is used for qualification is described below:

l Personnel performing inspections as of October 1,1995, are certified to this l

I standard (ANSI N45.2.6-1978) for the performance of inspections.

Personnel contracted to perform inspections at the DAEC will continue to be j

qualified for the performance of inspections in accordance with this standard l

(ANSI N45.2.6-1978).

f Effective with the approval of Revision 16 to the DAEC QADP Quality Assurance Program Description, craft personnel may become qualified to perform inspection by the successful completion of the training for that task. For example, the l

performance of dimensional measurements by a craftsperson in the performance f

of a repair activity is an equivalent task performed by an inspector qualified per ANSI N45.2.6 - 1978 for performing dimensional measurements in addition to l

this tas.k qualification, craft personnel qualified in accordance with this method shall also receive an annual eye examination for vision and color acuity.

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i l

Personnel performing testing activities shall have appropriate experience and training to assure competence in accordance with Regulatory Guide 1.8 (ANSl/ANS 3.1-1978).

11.3 ANSI N45.2.6 Section 1.2, " Applicability", third paragraph, requires that this standard j

be used in conjunction with ANSI N45.2. IES Utilities Inc. is not committed to ANSI j

N45.2.

i 11.4 ANSI N45.2.6 Section 1.2, " Applicability", fourth paragraph, requires that this standard l

be applied to organizations other than IES Utilities Inc. The specific applicability of this j

standard to other organizations is specified on a case-by-case basis in the l

procurement documents issued to those suppliers of materials and services.

i 11.5 Regulatory Guide 1.58 Revision 1, in Section B, " Discussion", endorses ASNT l

Recomrnended Practice No. SNT-TC-1 A-1975 for the qualification of nondestructive testing persont;el. In accordance with the IES Utilities Inc. ASME Section XI program the 1989 Edition shall govern. Section IWA-2300 of this Code requires nondestructive personnel to be qualified to SNT-TC-1 A-1984, i

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17.2 A-13 Revision 20 TBD l

l

l i

12.0 REGULATORY GUIDE 1.64. " Quality Assurance Reauirements for the Desion of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

lES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide. The IES Utilities Inc. commitment is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-11-1974 which it endorses.

13.0 REGULATORY GUIDE 1.74. " Quality Assurance Terms and Definitions" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

13.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.

13.2 IES Utilities Inc. has adopted the definition of " Audit" which appears in ANSI /ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.

14.0 REGULATORY GUIDE 1.88. " Collection. Storaae. and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

14.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9-1974 which it endorses.

14.2 Section 3.2.2 of ANSI N45.2.9-1974 specifies establishment of an "index" As we understand this term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the information attributed to an "index" in the Standard. Record retention requirements for records are specified. The specific retention times for records are indicated when the records are transmitted for permanent storage. IES Utilities Inc. utilizes computer-aided retrieval systems to index and locate records.

14.3 Section 5 of ANSI N45.2.9-1974," Storage, Preservation and Safekeeping", provides no distinction between temporary and permanent facilities. To address temporary 17.2 A-14 Revision 20 TBD

storage, the following position is established: Active records (those completed but not yet duplicated or placed on microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are duplicated or microfilmed. Open-ended l

documents--those revised or updated on a more-or-less continuing basis over an

)

extended period of time (e.a. personnel qualification and training documents) and l

those which are cumulative in nature (eg nonconforming item logs and control room

)

log books)--are not considered as QA records since they are not " complete" These l

types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on-gning document shall be transferred to permanent storage as a " record" 14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.

1 14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.

1 1

1 15.0 REGULATORY GUIDE 1.94. " Quality Assurance Renuirements for Installation.

Inspection. and Testina of Structural Concrete and Structural Steel Durina the l

l Construction Phase of Nuclear Power Plants" i

COMMENTS AND CLARIFICATIONS:

l l

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

15.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.94, Revision 1, April 1976, and to ANSI N45.2.5-1974 which it endorses.

{

l 15.2 For modification activities IES Utilities Inc. shall comply with the Regulatory Position i

established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply. Technical requirements associated with modification activities shall be equal to or better than the original requirements (e.a..

Code requirements, design and construction specification requirements, and inspection requirements).

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17.2 A-15 i

Revision 20 TBD i

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16.0 REGULATORY GUIDE 1.116. " Quality Assurance Reauirements for Installation.

Inspection. and Testina of Mechanical Eauipment and Systems" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

16.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.116, Revision 0-R, June 1976, with first page revision May 1977, and to ANSI N45.2.8-1975 which it endorses.

16.2 IES Utilities Inc.'s commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (m Code requirements, design and construction specification requirements, and inspection requirements).

17.0 REGULATORY GUIDE 1.123. " Quality Assurance Reauirements for Control of Procurement of items and Services for Nuclear Power Plants" i

COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

17.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13-1976 which it endorses.

l 18.0 REGULATORY GUIDE 1.144. "Auditina of Quality Assurance Proarams for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

18.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.144, Revision 1, September l

1980, and to ANSI N45.2.12-1977 which it endorses.

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17.2 A-16 Revision 20 TBD l

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18.2 Section 1.1, " Scope", and Section 1.2, " Applicability", of ANSI N45.2.12-1977 reference ANSI N45.2. IES Utilities Inc. is committed to ANSI N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.

j 18.3 Regulatory Position C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2, " Acceptance by Receiving Inspection", of ANSI l

N45.2.13-1976. The suppliers of products that meet this requirement are included on i

the IES Utilities Inc. external audit schedule and are audited on a triennial basis.

j 18.4 ANSI N45.2.12, Section 4.3.1 " Pre-Audit Conference" For internal audits, a " pre-audit planning meeting" may be substituted for the " pre-audit conference." The pre-audit planning meeting should accomplish the following:

1) The Lead Auditor to present the proposed audit plan and an oppodunity for the audited organizations to provide input to the proposed audit plan.

2) Introduce the Lead Auditor and identify proposed audit team members. Those audit team members available will be introduced. Note: Non-utility team members are j

usually not available at these meetings.

3) Counterparts are invited to these audit planning meetings as part of the planning process.

4) The audit schedule is presented, including a tentative exit date. The final exit date is announced separately during the audit period.

5) The channels of communication are opened at the audit planning meeting through participation in the audit planning process.

6) Following the audit planning meeting, the Lead Auditor will finalize the audit plan.

i 18.5 in lieu of an annual supplier evaluation specified by Regulatory Position C.3.b(2), a documented ongoing evaluation of the supplier should be performed. Where applicable, this evaluation should take into account (1) review of supplier-furnished documents such as certificates of conformance, non-conformance notices, and corrective actions, (2) results of previous source verifications, audits, and receiving inspections, (3) operating experience of identical or similar products furnished by the same supplier, and (4) results of audits from other sources, e.g., customer, ASME, or NRC audits. The results of the evaluations should be reviewed and appropriate corrective action should be taken. Adverse findings resulting from these evaluations should be periodically reviewed in order to determine if, as a whole, they result in a significant condition adverse to quality and to provide input to support supplier audit activities conducted by lES Utilities or a third pady auditing entity.

17.2 A-17 Revision 20 TBD

19.0 REGULATORY GUIDE 1.146. " Qualification of Quality Assurance Proaram Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

lES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

19.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.

19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2. For IES Utilities Inc., the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976. This is consistent with IES Utilities Inc.'s commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI N45.2.

19.3Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>19.3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. in lieu of ANSI N45.2.23 Section 2.3.4, prospective lead auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. This demonstration process shall be described in written procedures or instructione. The demonstration shall be evaluated and the results documented.

Regardless of the methods used for the demonstration, the prospective lead auditor shall have participated in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of Section 2.3 of ANSI N45.2.23 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.23 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., the individual may be certified as being qualified to lead audits.

20.0 REGULATORY GUIDE 1.155. " Station Blackout" COMMENTS AND CLARIFICATIONS:

IES Utilities Inc. complies with Appendix A," Quality Assurance Guideline for Non-Safety Systems and Equipment," to Regulatory Guide 1.155, Revision 1, August 1988.

21.0 REGULATORY GUIDE 4.15. " Quality Assurance for Radioloaical Monitorina Proarams (Normal Operations) - Effluent Streams and the Environment" COMMENTS AND CLARIFICATIONS lES Utilities Inc. complies with the Regulatory Position in Regulatory Guide 4.15, Revision 1, February 1979.

17.2 A-18 i

Revision 20

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TBD i

1 22.0 ASME B&PV Code.Section XI.1989 Edition with no Addenda COMMENTS AND CLARIFICATIONS:

The IES Utilities Inc. commitments relative to the Ten-Year Inspection Program and the Pump and Valve Test Program are established separately in formal correspondence with the Nuclear Regulatory Commission and incorporated into appropriate IES Utilities Inc. documents.

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17.2 A-19 Revision 20 TBD

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Discussion of changes to the UFSAR 17.2, Quality Assurance Program Description

l NG 98-1850 i

Discussion of Changes in the Quality Assurance Program Description

1. UFSAR Sections 17.2.1.2,17.2.1.3,17.2.1.3.1,17.2.2.5,17.2.2.6,17.2.2.7,17.2.7.1, 17.2.9.1,17.2.9.4,17.2.15.1,17.2.16.2,17.2.18.1,17.2.18.2.1,17.2.18.2.2,17.2.18.5 Identification of the Chanae:

Revised the title of the " Corporate Quality Assurance Manager" to " Manager, Quality Assurance." Also, changed references to " Corporate Quality Assurance Department" to " Quality Assurance Department."

Reason for the Chanae:

As a result of the merger of IES Utilities Inc., Interstate Power Co. and WPL l

Holdings, Inc. the word " corporate" has been removed from titles of positions, and their reporting organizations, that do not have organizational responsibilities above IES Utilities Inc.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This change is editorialin nature and does not change the responsibilities of the affected positions or their reporting organizations. This change is not a reduction in commitment.

2. UFSAR Section 17.2.1.3 Identification of the Chanae:

l Removed "and the Purchasing Department" from the second paragraph. The revised sentence reads " Fulfilling the responsibilities of the Quality Assurance Department requires significant communication with the DAEC, the Nuclear Licensing Department, the Emergency Planning Department, the Nuclear Business Unit, the Engineering Department, and the Training Department."

Reason for the Chanae:

The responsibilities for purchasing at the DAEC are consolidated into the Engineering Department making the reference in UFSAR Section 17.2.1.3 to the Purchasing Department unnecessary. Purchasing issues are the responsibility of the Engineering Department as administered through Materials Management.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments l

I The functions previously administered by the Purchasing Department are now performed in the Engineering Department. The removal of the reference to the Purchasing Department is made to correctly identify those DAEC organizations l

Page 1 l

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NG 98-1850 Discussion of Changes in the Quality Assurance Program Description with which Quality Assurance communicates. Quality Assurance does not communicate with the Purchasing Department to implement the DAEC commitment to 10 CFR 50, Appendix B.

There is no impact on DAEC commitments to either ANSI N45.2.13, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear power Plants" or Regulatory Guide 1.123, " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants", Revision 1. This change is not a reduction in commitment.

3. UFSAR Section 17.2.7.1 Identification of the Chanae:

Removed "..and the Purchasing Department" from the second sentence. The revised sentence states "The responsibility for the control of purchased material, i

equipment, and services is that of the Quality Assurance Department in close cooperation with the Engineering Department, and the DAEC."

Reason for the Chanae:

The responsibility for the functions previously assigned to the Purchasing Department for the control of purchased material, equipment and services is shifted to the Engineering Department. The reference to the Purchasing Department is not necessary following the shift of responsibilities.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments The functions previously administered by the Purchasing Department have been relocated to the Engineering Department. This consolidation of procurement activities is discussed in item 2 above. The removal of the reference to the Purchasing Department is made to correctly identify those DAEC organizations that control the purchase of material, equipment and services.

There is no impact on DAEC commitments to either ANSI N45.2.13, " Quality Assurance Requirernents for Control of Procurement of items and Services for Nuclear Power Plants" or Regulatory Guide 1.123, " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants", Revision 1. This change is not a reduction in commitment.

4. UFSAR Sections 17.2.2.3,17.2.2.6 & 17.2.3.2 Identification of the Chanae:

Revised the title " Manager of Engineering" to " Manager, Engineering."

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NG 98-1850 Discussion of Changes in the Quality Assurance Program Description Reason for the Chanae:

This change is being made to provide consistency with current job titles and other references in the UFSAR.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This is an editorial change only and is intended to provide consistency with the l

current titles as presented in UFSAR Table 13.1-1 and Figure 13.1-1. This change is not a reduction in commitment.

5. UFSAR Section 17.2.2.7 Identification of the Chanae:

Replaced the sentence "The Safety Committee audit is in accordance with the Technical Specifications requirement for a biennial audit of the quality assurance program." with "The Safety Committee audit is in accordance with the requirement for a biennial audit of the quality assurance program as delineated in Appendix A, Section 6.4 of this UFSAR Chapter."

Reason for the Chanae:

This reference to Technical Specifications was overlooked in the IES Utilities Inc.

September 25,1997 submittal of changes to revision 18 of the Quality Assurance Program Description. That submittal relocated Technical Specification requirements for the Safety Committee to UFSAR Section 17.2, Appendix A Section 6.4.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments The commitments of the Safety Committee are not affected by the relocation of this requirement from the Technical Specifications to the Quality Assurance Program Description. This change is not a reduction in commitment.

6. UFSAR Section 17.2.6.3 Identification of the Chanae:

l On page 17.2-12, the paragraph numbered 17.6.2.3 was changed to 17.2.6.3.

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i NG 98-1850 Discussion of Changes in the Quality Assurance Program Description

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Reason for the Chanae:

The paragraph number is incorrect and is a typographical transposition of numbers. UFSAR 17.2.6.3 was incorrectly-typed as 17.6.2.3.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This change is editorial in nature and does not affect the meaning of the paragraph. This change is not a reduction in commitment.

7. UFSAR Section 17.2.9.1 l

identification of the Chanae:

The reference to the ANST recommended Practice was changed from "SNT-TC-IA" to "SNT-TC-1 A."

Reason for the Chanae:

The correct reference includes the number one ("1") and not the alphabetic letter

("l").

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments i

This change is editorialin nature and does not affect the meaning of the paragraph. This change is not a reduction in commitment.

8. UFSAR Section 17.2.10.4.1 i

identification of the Chanae:

Revised the title of the " Corporate NDE Level lli Examiner to "NDE Level til Examiner."

Reason for the Chanae:

As a result of the merger of IES Utilities Inc., Interstate Power Co. and WPL Holdings, Inc. the word " corporate" has been removed from titles of positions, and organizations, that do not have organizational responsibilities above IES Utilities Inc.

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NG 98-1850 Discussion of Changes in the Quality Assurance Program Description Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This change is editorial in nature and does not change the responsibilities of the affected positions or their reporting organizations. Thio change is not a reduction 1

in commitment.

9. UFSAR Section 17.2.2.6 and Appendix A,6.4.1,6.4.1(a)(1),6.4.1 (a)(2),6.7 & 6.14 i

identification of the Channe:

Revised the title " Plant Manager, Nuclear" to " Plant Manager."

Reason for the Channe:

This change is being made to provide consistency with current job title = and other references in the UFSAR.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments j

This is an editorial change only and is intended to provide consistency with the current titles as presented in UFSAR Table 13.1-1 and Figure 13.1-1. This change is not a reduction in commitment.

10. UFSAR Section 17.2 Appendix A,6.4.1 Identification of the Chanae:

The following changes were made to the composition of the Operations i

Committee: " Quality Control" changed to " Quality Assurance,"" Reactor Performance" changed to " Reactor Engineering," " Technical Support" changed to

" Licensing," and added " Outage Managemerit" and " Systems Engineering."

Reason for the Chanae:

These changes are being made to reflect the current organizational arrangement and to provide additional diversity. Since the transfer of the inspection program from the Quality Assurance Department to the Maintenance Department, quality engineering expertise resides in to the Quality Assurance Department. The Reactor Performance group, now known as Reactor Engineering, has been reassigned to the Operations Oupport Supervisor. The Technical Support Department has been disbanded, with licensing expertise now located in the l

Licensing Department. Outage Management and System Engineering have been added to the Operations Committee to provide diversity.

I Page 5

NG 98-1850 Discussion of Changes in the Quality Assurance Program Description Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments These changes are the result of organizational changes or improvement in the diversity of the expertise present in the Operations Committee. The present composition is best suited to advise the Plant Manager on safe plant operation.

There is no negative impact on DAEC's commitment to N18.1-1976 ANSI /ANS-3.2 " Quality Assurance Program Requirements (Operations)." This change is not a reduction in commitment.

11. UFSAR Section 17.2 Appendix A,6.4.1.a identification of the Chanae:

Added the sentence "These procedures shall be spproved by the Plant Manager or designee prior to implementation, except as provided in Section 6.7."

Reason for the Chanae:

This sentence was reworded and moved from Section 6.14. Section 6.14 is being deleted (see change number 15 of this attachment).

Basis for Concludina that the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This is an editorial change only. No requirements have been changed. There is no impact on DAEC's commitment to N18.1-1976 ANSI /ANS-3.2 " Quality Assurance Program Requirements (Operations)." This change is not a reduction in commitment.

12. UFSAR Section 17.2 Appendix A,6.4.1.a.4 Identification of the Chanae:

Added the phrase "The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33."

Reason for the Chanae:

This phrase was moved from Section 6.14. Section 6.14 is being deleted (see change number 15 of this attachment).

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NG 98-1850 l

Discussion of Changes

]

in the Quality Assurance Program Description Basis for Concludina that the Chance Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This is an editorial change only. No requirements have been changed. There is j

no negative impact on DAEC's commitment to N18.1-1976 ANSI /ANS-3.2

" Quality Assurance Program Requirements (Operations)." This change is not a reduction in commitment.

13. UFSAR Section 17.2 Appendix A,6.4.1.a.(1)14 Identification of the Chanae:

I The phrase " Quality Control Program for effluent" has been changed to " Quality assurance for effluent and environmental monitoring."

Reason for the Chanae:

This change was made to provide consistence with improved Technical Specifications. The ITS project changed the phrase to " Quality assurance for effluent and environmental monitoring" as noted in Technical Specification 5.4.1.c.

Basis for Concludina that the Chanae Continues to Sctisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This is an editorial change only. No requirements have been changed. There is no negative impact on DAEC's commitment to N18.1-1976 ANSI /ANS-3.2

" Quality Assurance Program Requirements (Operations)." This change is not a reduction in commitment.

14. UFSAR Section 17.2 Appendix A,6.4.1.(2)

Identification of the Chance:

Revised the title " President" to " President, IES Utilities Inc."

Reason for the Chanae:

This change is being made to provide consistency with other references in the UFSAR.

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NG 98-1850 Discussion of Changes in the Quality Assurance Program Description Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This is an editorial change only and is intended to provide consistency with the current titles as presented in UFSAR Table 13.1-1 and Figure 13.1-1.

i This change is not a reduction in commitment.

15. UFSAR Section 17.2 Appendix A,6.14 Identification of the Chanae:

I Section 6.14 was removed in it's entirety.

Reason for the Chance:

Section 6.14 was relocated from Technical Specifications as part of revision 19

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of the QAPD. Section 6.14 contained requirements for the Operations Commi%ee that were also stated in Section 6.4.1. In revision 20 Section 6.14 was merged with Section 6.4.1. Redundant requirements were not restated.

Unique requirements were merged and are identified as changes 11 and 12 of this attachment.

Basis for Concludina that the Chance Continues to Satisfy 10 CFR 50 Appendix _B and Previous QA Proaram Commitments This is an editorial change only. No requirements have been changed. There is no impact on DAEC's commitment to N18.1-1976 ANSI /ANS-3.2 " Quality Assurance Program Requirements (Operations)." This change is not a reduction in commitment.

16 UFSAR Section 17.2 Appendix A,6.13 Identification of the Chanae:

The phrase " Engineering Operating Procedures" was corrected to " Emergency Operating Procedures." Also the content guidance for Emergency Operating Procedures was changed from "are in accordance with the guidelines of the BWR Owner's Group (BWROG) Emergency Procedure Guidelines, as reviewed and approved in the NRC Safety Evaluation Report, BWROG EPG, Revision 4, September 1988." are based upon the BWR Owner's Group (BWROG)

Emergency Procedure Guidelines (EPGs) Revision 4 and the associated generic NRC SER and were updated in accordance with the Emergency Procedure Guidelines / Severe Accident Guidelines (EPGs/ SAGS) Revision 1."

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o NG 98-1850 i

Discussion of Changes in the Quality Assurance Program Description Reason for the Chanae:

DAEC, as part of an industry initiative described in NEl 91-04 Revision 1, committed to implement Severe Accident Management (SAM) guidelines. The next revision of the EOP generic guidance (what would have been EPG Rev 5) was combined into a generic guidance document referred to as EPGs/ SAGS.

This change is to accurately reflect the basis for EOPs at DAEC with the mplementation of the new generic guidance.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This change reflects DAEC's commitment to incorporate the latest industry

)

guidance into the EOPs. The format of the EOPs will continue to be in a flowchart method and in accordance with generic guidance in lieu of Section 5.3.9.1 of ANSI N18.7-1976/ANS3.2. There is no additional impact on DAEC's i

commitment to N18.1-1976 ANSl/ANS-3.2 " Quality Assurance Program Requirements (Operations)" as a result of this change. Therefore, this change is not a reduction in commitment.

17. UFSAR Section 17.2 Appendix A,11.5 identification of the Chanae:

j Revised to update the basis for the in-service inspection program from the ASME Boiler and Pressure Vessel Code,Section XI from 1980 Edition with Addenda through Winter 1981 to the 1989 edition with no Addenda.

Also deleted the second paragraph which read: "In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and IES Utilities Inc. ASME Section XI Relief Request NDE-006, the recertification period for NDE Level lil personnel shall be every five years as opposed to the three years as stated in SNT-TC-1A-1980, paragraph 9.7.1."

Reason for the Chanae:

This change was overlooked in the UFSAR submittal of May 16,1997. That submittal revised the basis for the inservice inspection program to ASME Boiler and Pressure Vessel Code,Section XI,1989 Edition with no Addenda. The l

1989 Edition defines the recertification period for NDE Level lli personnel as every five years, making the second paragraph unnecessary. The previous relief request has been incorporated into Code and that later Code was adopted per the reqirements of 10CFR 50.55a.

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NG 98-1850 Discussion of Changes in the Quality Assurance Program Description Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments The DAEC has committed to implement an effective in-service inspection program. At ten year intervals the basis of the in-service inspection program is updated. This change is made to update the basis for the ASME Boiler and Pressure Vessel Code,Section XI to the 1989 Edition with no Addenda.

Commitments to 10 CFR 50 Appendix B and to implement an ASME program per 10 CFR 50.55a requirements remain unchanged. This change is not a reduction in commitment.

18. UFSAR Section 17.2, Appendix A 18.3 Identification of the Chanae:

Changed the phrase " Acceptance by Reviewing inspection" to " Acceptance by Receiving inspection."

Reason for the Chanae:

The phrase is incorrect and is a typographical error.

Basis for Concludina that the Chanae Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Proaram Commitments This change is editorialin nature and does not affect the meaning of the paragraph. This change is not a reduction in commitment.

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