ML022680450

Part III of Rev. 10 to Big Rock Point Plant Updated Final Hazards Summary Report (Ufhsr)

ML022680450
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Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	09/17/2002
From:	Consumers Energy
To:	NRC/FSME
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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 1 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS

5.0 INTRODUCTION

A wide range of potential accidents have been reviewed which could be of public or occupational health and safety concern if release of radioactive material were to occur as a result of the accident.

5.1 EVENT IDENTIFICATION PROCESS Review of potential decommissioning accidents for possible safety impact involved an assessment of planned Big Rock Point decommissioning activities to identify accidents with significant radiological release capabilities.

Event identification also included a review of the Big Rock Point Updated Final Hazards Summary Report (UFHSR) [Reference 5.1-1] and the Big Rock Point Integrated Plant Safety Assessment, NUREG-0828 [Reference 5.1-2] to identify whether any, and if so, which previously analyzed events were applicable to decommissioning.

Decommissioning activities and facility design characteristics also were evaluated against accident assumptions and results of the Final Generic Environmental Impact Statement for Decommissioning (FGEIS)

[Reference 5.1-3] and the safety and cost analysis document NUREG/CR-0672 [Reference 5.1-4]. This analysis was performed to identify whether Big Rock Point was bounded by the analyses for the reference BWR nuclear power plant, as described in these documents.

Big Rock Point implemented the guidelines of the EPA Manual of Protective Action Guides (PAGs) and Protective Actions for Nuclear Accidents, EPA-400

[Reference 5.1-5] on January 1, 1994. EPA-400 establishes protective action levels for public protection at one rem total effective dose equivalent (TEDE) for the total body, five rem committed dose equivalent (CDE) for thyroid, and 50 rem skin dose equivalent (SDE) for skin. These doses are small fractions of the limits established in 10CFR100. Revised dose calculations reflecting plant decommissioning and dismantlement described in this section have been performed in accordance with the guidelines of EPA-400.

The following sections discuss accidents which could occur during the decommissioning period, while the reactor is permanently defueled. The following sections contain a summary of these accident scenarios; the Big Rock Point Updated Final Hazards Summary Report contains a more detailed analysis of these accident scenarios.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 2 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS 5.2 EVENTS INVOLVING FUEL 5.2.1 Decommissioning Spent Fuel Pool Storage Events This section reviews anticipated fuel handling operations with the permanently defueled reactor to determine the accident that would produce the maximum off-site radiological consequences.

With the reactor shutdown and permanently defueled, fuel handling accidents bound all other categories of accidents with respect to the potential for offsite doses. The worst-case fuel handling event is a heavy load drop event in the fuel pool, due to the larger number of fuel bundles potentially damaged.

Consequences of minor fuel handling events are limited by worker response to area monitor detection of elevated dose rates with alarms normally set at 15 to 25 mrem/hr above area background dose rates.

For decommissioning, the radiological release estimates for the following fuel accident scenarios have been conservatively evaluated:

a.

All bundles in the pool (conservatively assumed to be 500 bundles) are damaged in a heavy load event. There are 441 assemblies in the fuel pool.

b.

84 bundles (100% of a core) from a reactor off-load, decayed one year, are damaged in a dry shielded configuration (out of the pool) due to an accident while loading a dry transportable canister.

Offsite doses for external, skin, thyroid and TEDE were calculated for various decay times. Damage to the assumed 500 bundles in the pool indicates that at 68 days following plant shutdown, the property boundary doses have dropped to less than the EPA Protective Action Guides of I rem TEDE and 5 rem to thyroid. This analysis assumed a total of 500 assemblies in the spent fuel pool with 84 being discharged from the final core off load. The 500 assemblies was based on operating the plant until the end of license in May 2000 rather than the actual last day of operation on August 29, 1997.

The pool contains only 441 assemblies per the plant license.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 3 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS In addition to evacuation doses, calculations have been made of dose rates to which onsite essential personnel might be exposed if required to enter containment or otherwise be exposed to concentrations approaching containment concentrations. It has been determined that based on use of standard protective gear (respirators and protective garments standard for highly contaminated and high airborne areas), onsite essential personnel will remain below their occupational dose limits for any accident that results in doses less than the PAGs to offsite individuals.

5.2.2 Loss of Spent Fuel Pool Cooling As part of Amendment 2 to the "Consolidated Application" for the Big Rock Point Plant Spent Fuel Pool Rack Addition, Consumers Energy Company performed analyses to demonstrate the structural integrity of the Spent Fuel Pool at elevated temperatures. Based on the analyses results, it was concluded that the pool floor, pool walls, and support walls are adequate to withstand events in which the inside pool wall surface temperature rises to and remains at 150°F.

At the time of permanent plant shutdown, an analysis was performed to determine the spent fuel pool heatup rate based on the operating history of each assembly in the pool. This analysis determined the time required for the pool to reach 150'F from an initial pool temperature of 80°F. Results of this analysis demonstrate that although SFP cooling capability must be maintained, the consequences of a loss of cooling event are not severe. At 93 days after permanent shutdown, the pool can experience a loss of cooling for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without exceeding the 150°F temperature limit. This time interval to respond to a loss of SFP cooling event is sufficient to ensure that the event is terminated, precluding any impact on the public health and safety.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 4 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS 5.2.3 Loss of Spent Fuel Pool Water Level There are no direct connections to the spent fuel pool capable of draining the water. The pool utilizes anti-siphon makeup lines and a weir discharge system to maintain approximately 22 feet of water over the active portion of the fuel and preclude water loss if damage were to occur t6 any pool connected piping systems. Level indication and leak detection capabilities will be retained as long as fuel resides in the pool.

The loss of cooling evaluation bounds any event which could result in a loss of pool water due to boiling. Response to provide makeup for water loss can be accomplished prior to the time at which decreased water level and lowered shielding become a concern.

5.3 EXTERNAL EVENTS External events which could affect the site were reviewed. The events, other than freezing, had been previously analyzed for the operating plant and found to present no significant hazard to the facility. These events include:

a.

Loss of Offsite Power

b.

Aircraft Hazards

c.

External Flooding

d.

Low Water Level

e.

Tornadoes and Extreme Winds

f.

Earthquake

g.

Fire Events 5.3.1 Freezinq Absence of reactor heat load and decreasing decay heat generation while the fuel is stored in the spent fuel pool results in increased reliance upon the plant heating system to maintain reactor building and other important structures above freezing under harsh winter conditions. Initiators of potential freezing conditions would include loss of offsite power, boiler problems or ventilation system failures.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 5 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS The capability to heat and ventilate the reactor building will be retained while fuel remains in the spent fuel pool.

The fuel pool itself, with its large volume and decay heat from the 441 fuel bundles, is not expected to freeze. The anti-siphon makeup line and design of the fuel pool discharge weir preclude loss of fuel pool water by damage to any support piping by freezing. A relatively small volume of fuel pool water from the cooling system external to the pool itself could be lost due to a freeze rupture of the SFP cooling system. With the surge tank and siphon breakers, pool water level would be maintained at near the operating level.

Cooling water leakage would accumulate in containment sumps and be pumped for processing by the radwaste system. Due to location of the fuel pool within the reactor building, there is no direct path for this water to escape to the environment.

5.4 NON-FUEL RELATED DECOMMISSIONING EVENTS An evaluation of potential non-fuel related decommissioning accidents at Big Rock Point has been performed. Decommissioning activities following final plant shutdown were evaluated, including system and equipment deactivation, decontamination, and dismantlement; radioactive material handling and storage; and transportation of radioactive materials. Types of postulated accidents reviewed were: explosions and fires, loss of contamination control, waste transportation accidents, external events, and natural phenomena. In addition to the standard decommissioning activities, postulated accidents associated with potential long term storage of radioactive waste during decommissioning also were evaluated.

Based on this review, it is concluded that all postulated decommissioning accidents for Big Rock Point are bounded by the results described in the FGEIS [Reference 5.1-3]. Thus, as concluded by the FGEIS, decommissioning will have a minimal impact on public safety and health.

This conclusion is further supported by the fact that Big Rock Point, at a rating of 240 Mwt, is a significantly smaller plant than the 3320 Mwt reference BWR.

This fact reduces total quantities of radioactivity present on site, total volumes of waste produced and shipping volumes.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 6 of 6 CHAPTER 5 - ENVIRONMENTAL IMPACTS OF ACCIDENTS The baseline BWR assumed in the FGEIS utilizes high efficiency particulate (HEPA) filters for plant ventilation effluents, whereas the Big Rock Point ventilation system did not include HEPA filters. HEPA filters were only used for specific sources such as fume hoods and offgas. To remain within the bounds of the FGEIS and recognizing that during dismantlement airborne particulate releases could be significantly reduced by plant HEPA filtration, a HEPA filtration system was installed in the ventilation system and is used for dismantlement activities involving major source terms of particulate activity.

5.5

SUMMARY

OF RESULTS The risk of significant radiological release from an accident occurring during decommissioning is significantly less than from an accident occurring during plant operation. Reviews and evaluations have been performed of accidents previously analyzed in the Big Rock Point Updated FHSR, potential incidents described in the FGEIS, and incidents based on industry experience.

5.6 REFERENCES

a.

5.1-1, Consumers Power Company, Big Rock Point Updated Final Hazards Summary Report (FHSR), Revision 7, Chapter 15

b.

5.1-2, NUREG-0828, "Integrated Plant Safety Assessment Systematic Evaluation Program for the Big Rock Point Plant," Final Report, May 1984

c.

5.1-3, NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning Nuclear Facilities," 1988

d.

5.1-4, NUREG/CR-0672, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station,"

Volumes 1 and 2, and Addendum 1

e.

5.1-5, EPA 400-R-92-001, "Manual of Protective Actions Guides and Protective Actions for Nuclear Incidents", May 1992 VOL32-CH5.doc

VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 1 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING

6.0 INTRODUCTION

The radiological status of the environment surrounding the Big Rock Point site is monitored by the radiological environmental monitoring program. For decommissioning planning purposes, two additional programs were completed: the first, a scoping survey program to determine residual contamination levels on the plant site itself; and the second, a program to determine levels of radioactivity within plant buildings, systems and structures. This chapter provides a description of each program, and their major findings.

6.1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Big Rock Point's radiological environmental monitoring program provides representative measurements of radiation and radionuclides which could cause potential radiation exposure to members of the public as a result of plant operation. The radiological environmental monitoring program supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the radioactive effluent measurements and the modeling of the environmental exposure pathways.

The radiological environmental monitoring program and reporting requirements are detailed in the Offsite Dose Calculation Manual (ODCM).

Big Rock Point's radiological environmental monitoring program consists of the following elements:

a.

Monitoring of airborne radionuclides (particulates), direct radiation, radionuclides in well water, lake water (plant's intake and discharge),

shoreline sediment, fish, and other aquatic biota samples.

b.

Participation in an NRC approved inter-laboratory comparison program by the analyst contractor to ensure that independent checks on precision and accuracy of the measurements of radioactive material and sampling matrices are performed in order to demonstrate that the results are valid.

The environmental monitoring program was initiated in 1958 with studies conducted by the University of Michigan. The environmental sampling program began before the plant started commercial operations and currently consists of greater than 1000 samples taken annually.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 2 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING The program has not identified any area that has either potential or known radioactive contaminates that would lead to a risk to the general public.

There were no technical specification reporting levels or action levels exceeded nor were there any special or supplemental analyses required.

Data from the initial pre-operational phase and early operational phase of the REMP is of limited use in evaluating the effects of plant operation due to the presence of weapons testing fallout during the late 50's and early 60's.

Preoperational fallout levels gave rise to much higher biota concentrations than currently observed. Preoperational radioactivity in periphyton was more than an order of magnitude higher than current levels, for example

[Reference 6.1-1].

Maximum individual dose due to gaseous effluents is calculated to be approximately 0.01 millirem per year at the property boundary, and maximum dose from liquid discharge is calculated to be approximately 0.1 millirem per year. Total integrated population doses from each effluent are calculated to be less than 0.1 person-rem per year. Quarterly calculated dose values for 1998 are presented in Table 6.1-1 [Reference 6.1-2].

The radiological environmental monitoring program during the decommissioning of Big Rock Point is modified for the limited radionuclide mix (absence of short-lived fission products) and for lowered gaseous effluent levels.

6.1.1 Facility Operating History During the operation of the Big Rock Point Nuclear Plant there were occurrences that resulted in contamination of structures and components inside buildings located in the Radiation Control Area. in addition, there were some occurrences which resulted in the contamination of the grounds outside of the buildings.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 3 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING The most significant contamination event at Big Rock Point occurred in 1984 when approximately 20,000 gallons of water leaked from an underground line used to route the effluent of the condensate liquid process monitor to the condensate storage tank. As a result of water leakage from the underground line, sixty cubic feet of contaminated soil, containing approximately 99% of the source term activity, were excavated and shipped as low level waste to a licensed burial ground. It was estimated that the remaining, approximate thirty-seven micro-curies, activity was distributed in approximately 5300 cubic feet of soil located under the plants turbine building. On August 16, 1985, Consumers Energy requested NRC approval to retain the remaining low concentration (approximately 1.4E-07 pCi/gm) of contaminated soil in place in accordance with 10CFR20.302. The approval was granted by the NRC on May 8, 1986.

Early in Big Rock Point's life, significant fuel failures occurred due to the collection of copper on fuel assemblies. The copper originated from the feedwater heaters and cleanup heat exchangers that utilized 70% copper, 30% nickel tube material. The tubes in the feedwater heaters were replaced with stainless steel in 1968, and cleanup heat exchanges were similarly modified in the early 1970's. Fuel failures that have occurred since that time are relatively minor in comparison, most consisting of small orifice openings in the cladding that allowed minimal fission product releases.

The integrity of major plant systems has been maintained during plant operations with no major failures occurring. Over the plant's life, routine occurrences such as minor packing and flange leaks, maintenance activities, and normal operational evolutions caused radioactive contamination in areas as anticipated. The contamination levels throughout the plant are maintained at low levels consistent with maintaining personnel radiation doses and releases to the environment ALARA.

6.2 RADIOLOGICAL SITE CHARACTERIZATION 6.2.1 Purpose The purpose of the site characterization survey is to identify, quantify and document residual radioactivity at the Big Rock Point site. The results of the characterization survey will be used to define any potential remediation requirements prior to the final survey and termination of the site NRC license.

The Site Characterization Report will be included in the License Termination Plan as described in 10CFR50.82.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 4 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING 6.2.2 General Program Description The following summarizes the major activities for site characterization survey of soil and groundwater. Regulatory guidance contained in NUREG 1575, MARSSIM, [Reference 6.2-1] is utilized to the extent practical for performing the major activities associated with site characterization. Site Characterization is an ongoing process in conjunction with component removal and building demolition. Specific information regarding sample collection, analysis methodology and results are to be provided in the Site Characterization Plan, applicable procedures and Site Characterization Report, as generated.

The Big Rock Point property consists of only a few acres of buildings and structures located in a forested area on the Lake Michigan shoreline. The site license describes an owner-controlled area of approximately 600 acres; however, less than 20 acres were utilized for actual plant operations.

Big Rock Point completed a radiological scoping survey in 1994 that consisted of measurements and samples of the plant systems, structures, and components along with the analysis of soil and groundwater beneath the plant site and surrounding areas [Reference 6.2-2]. The objective of the scoping survey was to provide a preliminary assessment of radiological conditions around the site prior to decommissioning.

6.2.2.1 Survey Unit Classification A historical site assessment has been performed using Data Quality Objectives as described by NUREG 1575 (MARSSIM) to complete initial classification of all site property into the categories of Non-Impacted or Impacted (Class I, II, Ill). The historical site assessment utilized scoping survey data, Condition Reports, Event Reports, Deviation Reports, questionnaire data, interviews with current and former plant employees, process knowledge of waste transport and review of operating logbooks.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 5 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING A land survey has been completed to section the site property into ten by ten meter survey grids. Based on the historical site assessment and scoping survey data, these grids have been divided into survey unit classifications in accordance with NUREG 1575, MARSSIM, guidance. The classification criteria is provided below.

Classification Description Non-Impacted Area of no potential contamination Impacted Class 1 Areas containing locations where residual activity may exceed the Dose Concentration Guideline Limit3 (DCGL)

Class 2 Areas that have the potential for radioactive contamination but are not expected to exceed the.DCGL Class 3 Impacted areas that are not expected to contain any residual activity or are expected to contain levels at a small fraction of the DCGL Figure 6.2-1 provides a preliminary diagram of impacted and nonimpacted areas for the Big Rock Point site.

6.2.2.2 Regional Background Activity The radioactive background activity levels from man-made sources will be established based on analysis of off-site samples of varying soil types and locations. Fisherman's Island, located approximately 10 miles southwest of the Big Rock site, has been defined by the US Dept. of Agriculture as having the same soil types as Big Rock Point. A MARSSIM survey of this area has been completed to define the regional standard environmental Cs-137 background resulting from fallout. A MARSSIM survey of the Big Rock Point nonimpacted areas will then be statistically compared to the Cs-1 37 background activity determined for Fisherman's Island.

3DCGLs are isotope specific conversion factors to obtain dose in milliremlyear to a critical member of the population based on quantity of radioactivity found in soil, groundwater, etc.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 6 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING 6.2.2.3 Soil Sampling and Analysis Radiological surveys conducted for site characterization incorporate an integrated evaluation methodology. The MARSSIM approach is used wherever practical for characterization survey sampling and analysis. Survey units are scanned for individual areas of elevated activity using sodium iodide detection methodology. Activity depth profiles are determined by deep core sampling to define the vertical and lateral extent of contamination. Laboratory and in situ gamma spectroscopy is used to identify and quantify levels of soil radioactivity.

Extensive surveys have been performed in and around the protected area, including deep core sampling to profile the depth and extent of potential contamination [Reference 6.2-4]. Preliminary results of this survey indicate that the area of concern (potential Class I impacted areas) encompass approximately 1000 square meters immediately west of the turbine building and about a 300 square meter area beneath the turbine building floor.

Remediation efforts for these areas will be evaluated and/or completed as part of the License Termination Plan.

6.2.2.4 Groundwater Sampling Data on groundwater radioactivity is tracked via the groundwater monitoring wells to assess any radionuclide migration. Groundwater samples are routinely collected from the nine monitoring wells installed in 1994.

Table 6.2-1 provides a description of the wells and Table 6.2-2 summarizes radioactive analysis results to date. Samples are analyzed for gamma emitting nuclides and tritium. The analyses are performed with a minimum detectable activity (MDA) concentration 1.8 E=8 pCi/mI for Cs-1 37. This MDA is substantially below the activity concentration established by the Michigan Drinking Water Standard R325.10604 which sets the limit for water consumed by the public to the concentration that would give a member of the public 4 mrem/year. This calculates to 8 E=8 pCi/ml for Cs-137.

Two of the nine monitoring wells indicated detectable tritium activity; no other radionuclides were detected in any of the wells. The tritium is believed to have originated from the migration of activity from the 20,000 gallons of water that leaked into the ground in 1984 [Reference 6.2-3]. Levels of detected tritium are lower by a factor of approximately 500 than the concentration originally leaked to the ground and is most likely the end of the groundwater plume entering Lake Michigan.

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 7 of 11 CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING 6.2.2.5 Exposure Pathway Modeling Exposure pathway modeling using the RESRAD computer code, or equivalent method acceptable to the NRC, and utilizing applicable site specific geological and characterization data will be completed. These models will be used to determine the appropriate DCGLs prior to submittal of the License Termination Plan to the NRC.

6.3 REFERENCES

a.

6.1-1, Consumers Energy Company, "Big Rock Point Annual Radiological Environmental Monitoring Report January to December 1998," Letter to NRC dated April 29, 1999

b.

6.1-2, Consumers Energy Company, "Big Rock Point Annual Radiological Effluent and Waste Disposal Report", Letter to NRC dated April 26, 1999

c.

6.2-1, NUREG 1575, EPA-402R-97-016, Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM), December 1998

d.

6.2-2, Simonsen, Rodney J., "Development and Utilization of a Method for Performing Insitu Gamma Ray Spectroscopy of Operating Commercial Nuclear Power Plant site Grounds in the Presence of a Varying Background Radiation Field," University of Michigan, 1997

e.

6.2-3, Deviation Report BRP-94-073, Identification of Contaminated Soil Identified from Decommissioning Scoping Survey, Consumers Power Company, Big Rock Point Nuclear Plant

f.

6.2-4, Consumers Energy, Big Rock Plant Core Borings Report, Radian International, August 23, 1999

g.

6.2-5, Action Item Record A-BRP-94-041, Addition of Big Rock Point's Monitoring Wells into the Plant's Radiological Environmental Monitoring Program VOL32-CH6.doc

VOLUME 32 Revision 0 Page 8 of 11 ENVIRONMENTAL REPORT FOR DECOMMISSIONING CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING Figure 6.2-1 VOL32-CH6.doc

VOLUME 32 Revision 0 Page 9 of 11 Note: Groundwater depth as determined August 18, 1994 VOL32-CH6.doc ENVIRONMENTAL REPORT FOR DECOMMISSIONING CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING TABLE 6.2-1 GROUNDWATER MONITORING WELLS AT BIG ROCK POINT Well Top of Well Groundwater Screen Elevation Elevation Bottom Location on Site (ft)

(ft)

Elevation (ft) 1 586.38 583.86 517 W of Annex 2

592.72 Standing 568 NW of Radwaste Bid.

Water 3

594.89 Standing 578 WSW of Radwaste Bid.

Water 4

596.31 Flowing 572 SSW of Radwaste Bid.

Water 5

589.35 583.29 565 NE of Escape Lock 6

591.81 583.09 572 NW of Escape Lock 7

591.36 581.58 562 NW Corner of Protected Area 8

592.57 585.72 567 W of Maintenance Bid.

9 594.18 586.99 578 SW of Stack

VOLUME 32 Revision 0 Page 10 of 11 ENVIRONMENTAL REPORT FOR DECOMMISSIONING CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING TABLE 6.2-2 BIG ROCK POINT GROUNDWATER MONITORING DATA1 Titium Activity (uCi/ml)

Sample Well #1 Well #2 Well #3 Well #4 Well #5 Well #6 Well #7 Well #8 Well #9 Date Aug-94

< 1.OE-06

< 1.OE-06

< 1.OE-06 1.1E-05 4.OE-05

< 1.OE-06

< 1.OE-06

< 1.OE-06 Sept-94

< 5.OE-07

< 5.OE-07

< 5.OE-07 1.1E-05 2.7E-05

< 5.OE-07

< 5.OE-07

< 5.OE-07 Apr-96

< 1.OE-06 2.4-E05 1.7E-05

< 1.OE-06

< 1.0E-06 8.2E-07 Oct-96

< 8.OE-07

< 8.OE-07

< 8.OE-07 2.3E-05 2.2E-05

< 8.OE-07

< 8.OE-07

< 8.OE-07 Apr-97

< 1.5E-07

< 1.5E-07

< 1.5E-07 2.3E-05 3.7E-05

< 1.5E-07

< 1.5E-07

< 1.5E-07 Oct-97

< 7.1E-07

< 7.1E-07 1.4E-05 2.5E-05

< 7.1E-07

< 7.1E-07

< 7.1E-07 Apr-98

< 6.OE-07

< 6.OE-07

< 6.OE-07 1.4E-05 9.1E-06

< 6.OE-07

< 6.OE-07 Oct-98

< 5.2E-07

< 5.2E-07

< 5.2E-07 1.5E-05 2.3E-05

< 5.2E-07 6.3E-07 Mar-99

< 5.2E-07

< 5.2E-07

< 5.2E-07 1.0E-05 1.4E-05

< 5.2E-07

< 5.2E-07 Oct-99

<1.7E-07

< 1.8E-07

< 1.8E-07

< 1.8E-07 1.65E-05 1.90E-06

< 1.8E-07 5.10E-07 VOL32-CH6.doc

VOLUME 32 Revision 0 Page 11 of 11 ENVIRONMENTAL REPORT FOR DECOMMISSIONING CHAPTER 6 - FACILITY RADIOLOGICAL STATUS AND MONITORING TABLE 6.2-2 BIG ROCK POINT GROUNDWATER MONITORING DATA',

1ODCM requires semiannual sampling for six of nine monitoring wells.

2Resampled Well #'s 5 and 6 due to abnormally elevated result for Well #5 in July-00.

VOL32-CH6.doc Titium Activity (uCi/mi)

Apr-00

<1.8E-07

< 1.6E-07

< 1.6E-07

< 1.6E-07 1.7E-05 5.28E-06

< 1.6E-07 July-00 1.91 E-07

< 1.6E-07

< 1.6E-07

< 1.6E-07 2.60E-05 5.06E-06

< 1.6E-07 Mar-012 9.60E-06 5.09E-06 I

VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 1 of 5 CHAPTER 7 - FACILITY RADIOLOGICAL STATUS AND MONITORING

7.0 INTRODUCTION

Decommissioning of Big Rock Point will require the authorization of several federal, state, and local agencies. Some activities require specific authorization. Others may involve permits and approvals already in effect for operation of the facility. Federal, state, and local requirements are identified, and the status for each is reviewed below.

7.1 FEDERAL REQUIREMENTS Decommissioning activities that are subject to federal regulations, permits, licenses, notification, approvals or acknowledgments include:

a.

Handling, packaging and shipment of radioactive waste;

b.

Worker radiation protection;

c.

Worker health and safety;

d.

Liquid effluent releases to Lake Michigan;

e.

Hazardous waste generation/disposition;

f.

Handling and removal of asbestos;

g.

Handling and removal of lead paint;

h.

Closure of mixed low level waste (LLW) storage facility;

i.

Radio communications; and

j.

Soil Erosion Sedimentation and Control Permit.

The majority of radiological activities fall under Title 10 of the Code of Federal Regulation (CFR) and are administered by the Nuclear Regulatory Commission (NRC). Applicable Title 10 regulations include:

a.

Part 50 - decommissioning activities;

b.

Part 20 - radiation protection;

c.

Part 51 - environmental protection; VOL32-CH7.doc

VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 2 of 5 CHAPTER 7 - FACILITY RADIOLOGICAL STATUS AND MONITORING

d.

Part 61 - disposal of radioactive waste; and

e.

Part 71 - packaging and transportation of radioactive waste regulations in (49CFR171 to 174 also apply).

Worker health and safety protection during decommissioning is subject to Occupational Safety and Health Administration (OSHA) regulations. The regulations applicable to construction are 29CFR1910 and 1926. These regulations include requirements for respiratory protection (nonradiological),

hearing protection, illumination, scaffold safety, crane and rigging safety, chemical usage and release response, and clean-up operations.

The Environmental Protection Agency (EPA) regulations outlined in Title 40 of the Code of Federal Regulations apply as follows:

a.

Part 61 - Asbestos Handling and Removal;

b.

Parts 122 to 125 - National Pollutant Discharge Elimination System (NPDES);

c.

Part 141 - Safe Drinking Water Standards;

d.

Part 190 - Radiation Protection Standards for Nuclear Power Operations;

e.

Parts 260 to 272 - Resource Conservation and Recovery Act (RCRA);

f.

Part 280 - Underground Storage Tanks; and

g.

Part 761 - Polychlorinated Biphenyls (PCBs).

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VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 3 of 5 CHAPTER 7 - FACILITY RADIOLOGICAL STATUS AND MONITORING Asbestos and lead paint handling and removal is subject to OSHA regulations 29CFR1910 and 1926, and EPA Regulations 40CFR61, Subpart M.

Hazardous waste generation, storage, transportation, disposal and closure of the mixed LLW waste facility are subject to the regulations outlined 40CFR260 through 272 of the Resource Conservation and Recovery Act (RCRA). Handling and storage of PCB waste are subject to the requirements of 40CFR761 or the Toxic Substances Control Act (TSCA).

Federal Communications Commission (FCC) licenses are required for radio communication equipment used at BRP. FCC regulations apply to any radio communication equipment used in the reactor dismantlement and radwaste processing area.

7.2 STATE AND LOCAL REQUIREMENTS Permits and approvals from or notifications to several state and local agencies are required for safety and environmental protection purposes.

Some of these are for specific decommissioning activities, and others are for existing Big Rock Point site facilities and ongoing activities that will also be required to support decommissioning. Many of the state and local requirements apply to activities that are also subject to federal regulations discussed previously. Decommissioning activities and related site operations that fall under state and local jurisdiction include:

a.

Air emissions,

b.

Hazardous waste generation,

c.

Asbestos removal and disposal,

d.

Lead paint removal and disposal,

e.

Solid waste shipment,

f.

Solid waste disposal,

g.

Liquid effluents,

h.

Liquid waste shipment,

i.

Fuel oil storage, VOL32-CH7.doc

VOLUME 32 ENVIRONMENTAL REPORT Revision 0 FOR DECOMMISSIONING Page 4 of 5 CHAPTER 7 - FACILITY RADIOLOGICAL STATUS AND MONITORING

j.

Building permits,

k.

Plant domestic water wells, I.

Soil erosion and sedimentation,

m.

Wetlands protection, and

n.

Underground storage tanks.

Michigan's environmental acts were consolidated into the Natural Resources and Environmental Protection Act (NREPA), 1994, PA 451 as amended.

Act 451 is organized into "Parts." The following section provides a general description of the Michigan Act 451 parts applicable to decommissioning Big Rock Point.

Air emissions and asbestos removal for the site are regulated under the Michigan Air Pollution Control Rules (Part 55) in addition to the Federal Clean Air Act. Operating permits will be revised or terminated as necessary to accommodate decommissioning activities. Notification of asbestos removal will be prepared and submitted to MDEQ staff.

Liquid discharges from the plant to Lake Michigan are regulated by the NPDES permitting system jointly administered by the EPA and the MDEQ, Surface Water Quality Division. Parts 31 and 88 of Act 451 provide regulations for surface water discharges. Soil erosion and sedimentation control and wetlands protection are governed by Act 451, Parts 91 and 303, respectively.

Michigan waste management regulations are found in Parts 111, 115, 117 and 121 of Act 451. These regulations apply to generation, disposition and disposal of hazardous waste, solid waste management, nonhazardous liquid industrial wastes, and used oil recycling. All nonhazardous, nonradioactive wastes, including demolition debris, will be disposed of as either a Type II or Type III waste. Additionally, lead paint handling and disposal falls under Michigan Occupational Safety and Health Act (MIOSHA) regulations.

Three underground storage tanks exist at the Big Rock Point site for heating fuel oil, diesel generator fuel supply and diesel fire pump fuel supply. In addition to regulation under Part 211 of Act 451, these tanks are also regulated by the State Fire Marshall.

VOL32-CH7.doc

VOLUME 32 Revision 0 Page 5 of 5 ENVIRONMENTAL REPORT FOR DECOMMISSIONING CHAPTER 7 - FACILITY RADIOLOGICAL STATUS AND MONITORING Drinking water supplies are regulated under the Safe Drinking Water Act (PA 399, 1976) by the Drinking Water and Radiological Protection Division of the MDEQ.

At the local level, building permits will be required for temporary field office or other facilities necessary to support decommissioning activities.

VOL32-CH7.doc

ATTACHMENT VI CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DCKET 50-155 AND 72-043 -LICENSE DPR-5 REVISION 10 TO THE UPDATED FINAL HAZARDS

SUMMARY

REPORT (UFHSR)

Submitted September 17, 2002 Informational Copy Revision 20 of the Quality Program Description for Nuclear Power Plants, Part 1 -Big Rock Point (CPC-2A) 89 Pages

Consumersinergy Quality Program Description for Nuclear Power Plants (Part 1) -

Big Rock Point (CPC-2A)

Rev.20

212 West Michigan Avenue Tel 517 788 1352 Jackson, M 49201-2277 Fax. 517 788 2186 President a Chief Execute Officer - Elecc

SUBJECT:

STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS ENERGY QUALITY PROGRAM FOR THE BIG ROCK POINT NUCLEAR PLANT As President and Chief Executive Officer, Electric of Consumers Energy, I have the ultimate management authority for the Consumers Energy Quality Program Description for Nuclear Power Plants (Part 1) - Big Rock Point Nuclear Plant. The Quality Program Description complies with the quality assurance requirements contained in Appendix B of 10 CFR 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," and responds to the additional guidance contained in ANSI N18.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of applicability imposed by N 18.7.. The Quality Program Description outlines the actions that are implemented for important activities affecting decommissioning of the Big Rock Point Nuclear Plant and the construction and operation of the Independent Spent Fuel Storage Installation.

I have delegated responsibility for establishing, maintaining and implementing the Quality Program Description to the Senior Vice President, Nuclear, Fossil and Hydro Operations. I have delegated selected portions of the Quality Program to the Senior Vice President, Electric Transmission and Distribution; and through a Senior Vice President of CMS Energy to the Vice President and Secretary. This Quality Program Description describes the Consumers Energy organizations responsible for implementation.

The Quality Program Description contains mandatory requirements which must be implemented and enforced by all responsible organizations and individuals.

Davih VV.Jos

(

Date President and Ciýecutive Officer, Electric A CMS Energy Company

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT APPROVED BY:

Senior Vice President, Nuclear, Fossil, and Hydro Operations Robert A. Fenech Seni Vice President, Electric Transmission and Distribution John. G. Russell Vice President and Secretary Thomas A. McNish Date' Date Date Page 2 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT CONTENTS Section Title Paqe Statement of Responsibility and Authority I

Approval Page 2

Contents 3

1.0 O RGAN IZATIO N..........................................................................................

5 2.0 QUALITY PROGRA M..................................................................................

12 3.0 DESIG N CO NTRO L....................................................................................

17 4.0 PROCUREMENT DOCUMENT CONTROL.................................................

21 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS..................................

22 6.0 DOCUMENT CONTROL.............................................................................

26 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES...... 28 8.0 IDENTIFICATION AND CONTROL OF ITEMS............................................ 31 9.0 CONTROL OF SPECIAL PROCESSES.....................................................

32 10.0 INSPECTIO N..............................................................................................

33 11.0 TEST CO NTRO L.........................................................................................

37 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT...............................

39 13.0 HANDLING, STORAGE AND SHIPPING.....................................................

41 14.0 INSPECTION, TEST AND OPERATING STATUS......................................

42 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS................. 43 16.0 CORRECTIVE ACTION................................................................................

45 17.0 QUALITY RECORDS.................................................................................

46 18.0 A U D IT S............................................................................................................

48 Page 3 Rev 20 Date: 5115/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT APPENDIX A.................................................................................................................................

50 APPENDIX B.................................................................................................................................

79 APPENDIX C................................................................................................................................

82 APPENDIX D................................................................................................................................

85 APPENDIX E.................................................................................................................................

87 FIGURE 1

Consumers Energy Organization Chart for Big Rock Point Quality Program.....................

11 Page 4 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 1.0 ORGANIZATION 1.1 REQUIREMENTS Consumers Energy is responsible for establishing and implementing the Quality Program, as described herein, for the Big Rock Point Nuclear Plant and its Independent Spent Fuel Storage Installation (ISFSI). Consumers Energy will be delegating the authority for development and maintenance of the Quality Program Description (QPD) and execution of certain quality assurance functions to the Nuclear Management Company (NMC). Until July 1, 2001, these activities will be performed by Consumers Energy personnel. From that time, these activities will be performed by a combination of NMC and Consumers Energy personnel. This is discussed below within the QPD. Although authority for development and execution of some parts of the program is delegated to others, such as contractors and consultants, Consumers Energy retains overall responsibility.

This section of the (QPD) identifies the Consumers Energy and NMC organizations responsible for activities affecting the quality of BRP/ISFSI structures, systems and com ponents and describes the authority and duties assigned to them. It addresses responsibilities for attaining quality objectives; for establishing and maintaining the QPD; and for assessing the performance of activities affecting quality. The maintenance and control of this QPD is the responsibility of the Manager, Nuclear Performance Assessment Department (NPAD).

NPAD functions (e.g., audits, assessments, and supplier evaluations) are performed by personnel within formally designated organizational units that report to the Manager, NPAD or members of other organizations as selected by the Manager, NPAD. The report ing level of the NPAD organization affords sufficient authority and organizational freedom, including sufficient independence from the cost and schedule impacts of NPAD organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 1.2.1 2a 1.2.2 2g 1.2.3 2, 2b, 2c 1.2 IMPLEMENTATION 1.2.1 Source of Authority The President and Chief Executive Officer, Electric (see Figure 1, Company Organization Chart) of Consumers Energy is responsible for safe operation and Page 5 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT decommissioning of Big Rock Point and safe storage of spent fuel at the ISFSI. Authority and responsibility for establishing and implementing the Quality Program for decommissioning is delegated to the Senior Vice President - Nuclear, Fossil, and Hydro Operations (NFHO). This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer, Electric. Other quality-related functions are provided by other organizations as described herein.

1.2.2 Responsibility for Attaining Quality Obiectives at the Nuclear Plants The Senior Vice President, NFHO is responsible to the President and Chief Executive Officer, Electric for decommissioning of BRP and construction and operation of the ISFSI.

Managers who report to the Senior Vice President, NFHO, are responsible for directing the performance of activities that affect safe plant decommissioning and/or safety-related functions of structures, systems and components of the plant and ISFSI in accordance with Quality Program requirements.

The BRP Site General Manager (see Figure 1) is responsible to the Senior Vice President NFHO for operation, maintenance, and decommissioning of BRP and construction and operation of the ISFSI in such a manner as to achieve compliance with licenses, applicable regulations and the Quality Program. The Site General Manager delegates to appropriate managers and staff personnel in his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed Son the authority of the Site General Manager include:

Qualification of appropriate decommissioning/ISFSI personnel, including certification of inspection personnel.

Preparation, review and approval of plant/ISFSl procedures and instructions.

Functioning as the plant/ISFSI design and configuration control authority for compliance of plant/ISFSI modifications and design changes to existing plant/ISFSI design criteria.

Modifying components, including procurement, installation, inspection and testing activities when assigned by the Site General Manager.

Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits.

Maintaining Echelon III calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE).

Calibration/maintenance of installed plant/ISFSI instrumentation.

ob Page 6 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Maintaining a calibration recall system.

Maintaining a Master List for plant-owned PL-M&TE.

Performing necessary surveillance testing.

Maintaining equipment status control.

Maintaining required controls over chemical standards and reagents.

Conducting a water chemistry program in accordance with technical specifications.

Stopping unsatisfactory work to control further processing, delivery or installation of nonconforming materials or items.

Plant site/ISFSI inspection program, including inspection of maintenance, testing and fuel handling.

Preparation, review, and approval of means that identify plant/ISFSI structures, systems and components, and activities to which this QPD apply, as described in Section 2.0, depending on plant conditions during dismantlement.

Assuring that nonconforming items are identified, segregated and dispositioned.

Nuclear engineering such as accident-transient and physics analysis of spent fuel storage configurations.

Establishing, implementing and documenting the appropriate training of decommissioning/ISFSI personnel, including Quality Program indoctrination and training.

Procurement, including preparation, reviews and approval of purchase requests for spares, replacement items, consumables, and materials, items and services and submittal of purchase requests to the purchasing organization. Planning and execution of vendor source surveillance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.

Providing for storage and protection of purchased materials and items awaiting disposition implementation after removal from service, assuring preservation of identification.

Accomplishing plant/ISFSI licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or tracking licensing commitments and coordinating internal action on NRC bulletins, generic letters, etc.

Page 7 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability.

Operating experience reviews including NRC Information Notices.

Performing the engineering, construction, inspection and testing associated with plant/ISFSI modification projects as assigned.

Developing, maintaining and implementing security, fire protection and emergency plans.

Performing reviews to advise the Site General Manager on matters related to nuclear safety, as specified in Appendix B, Safety Review Committee.

1.2.3 Responsibilities of the Nuclear Performance Assessment Department The Manager, NPAD, (see Figure 1) is directly responsible to the Senior Vice President, NFHO, for:

Assessment of the effectiveness of the Nuclear Quality Program.

Supplier surveys and evaluation including review/approval of supplier QA programs, and maintenance of the Approved Suppliers List.

Preparation, review, approval and implementation of departmental procedures governing nuclear assessment activities.

Assuring that assessments are done by personnel not directly responsible for the work being performed.

Recommending to the Senior Vice President, NFHO that decommissioning activities including spent fuel transfer activities be stopped if such action appears necessary.

Assessment programs (site and Corporate Office), including follow-up on corrective action for audit findings.

Review of performance trends associated with BRP/ISFSI activities including corrective actions.

Analysis of new and/or changed regulatory direction, codes and standards to determine their effect on the Quality Program.

Maintenance of the Quality Program Description for Nuclear Power Plants Part 1 - Big Rock Point Nuclear Plant.

Page 8 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

Reporting audit findings relative to follow-up on corrective actions and the effectiveness of the Quality Program to Consumers Energy Management.

In fulfilling the above responsibilities, the Manager, NPAD may use a combination of Consumers and NMC employees. The Manager, NPAD, is provided with "Stop Work" authority whereby he can suspend any quality related activity or process which may, in his opinion, adversely affect public safety, the safe decommissioning of BRP, or safe fuel storage operations. A Stop Work Order that would result in the suspension of in-process spent fuel transfer operations is given as a recommendation - the certified fuel handlers are responsible for determining and carrying out the safest course of action.

The Manager, NPAD has no other primary duties or responsibilities unrelated to NPAD that would prevent his attention to nuclear performance assessment matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality considerations in his decisions and recommendations, and has direct access to high enough levels of Management to obtain resolution of quality problems.

1.2.4 Responsibilities of the Equipment Services Department The Manager, Equipment Services provides electrical, rotating and stationary equipment expertise, including developing and qualifying procedures for welding and heat-treating and qualifying welders.

1.2.5 Responsibilities of the Plant Operations Department The Director, Plant Operations is responsible for maintaining the Records Management System including required retention, protection and retrievability. This includes collecting, storing, and maintaining, distributing and controlling plantISFSI engineering design documents. This excludes Big Rock Safeguards Information documents, which are maintained at Big Rock. The accuracy, quality, and correctness of Big Rock documents in the Records management System are the responsibility of the BRP Site General Manager.

1.2.6 Responsibilities of the Environmental and Laboratory Services Department The Manager, Environmental and Laboratory (E&LS) is responsible for:

Maintaining the Company's Echelon II calibration facility for calibrating reference and secondary standards and general usage portable and laboratory measuring and test equipment.

Controlling the calibration recall system for Portable and Laboratory M&TE owned by E&LS, and other departments, as requested.

Maintaining a Master PL-M&TE List for E&LS PL-M&TE and for other departments, as requested.

Page 9 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Providing a PL-M&TE Inventory List for BRP/ISFSI.

Providing chemistry support to BRP/ISFSI, as requested.

Preparing, reviewing, approving and obtaining additional reviews and approvals if required, of purchase requests for services, equipment and consumables, and submitting such requests to purchasing for procurement action.

Conducting performance tests on materials, equipment and systems when requested.

Performing nondestructive examination, and controlling/maintaining NDE equipment.

Providing qualified NDE procedures and equipment and NDE personnel.

Providing chemical and metallurgical analytical services.

Providing necessary corrective action processing and status reporting for assigned corrective action documents.

1.2.7 Responsibility for Attaining Quality Obiectives Outside Nuclear, Fossil, and Hydro Operations Certain functions that constitute part of the Nuclear Quality Program are performed by Consumers Energy organizational units outside the Nuclear, Fossil and Hydro Operations Department. Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization responsible for that activity (i.e., the design authority).

a.

The Manager, Electric System Operations (see Figure 1) is responsible through the Senior Vice President, Electric Transmission and Distribution to the President and Chief Executive Officer, Electric for determining settings for electrical protective systems and relay control schemes, for design, review and recommending changes to electrical protective schemes and associated settings. He is also responsible for testing and maintaining electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associated settings.

b.

The Corporate Records Administrator (see Figure 1) is responsible through the Vice President and Secretary for microfilming of specified quality records and plant/lSFSI engineering/design documents.

c.

The Manager, Production Support (see Figure 1) is responsible, through the Senior Vice President, Electric Transmission and Distribution to the President and Chief Executive Officer - Electric for operating the Skill Centers including the training, and testing of personnel and equipment for welding operations.

Page 10 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Chairman and CEO - CMS Energy and Chairman Consumers Energy I

Senior Vice President & General Counsel CMS Energy Vice President and Secretary Corporate Records Administrator President and Chief Executive Officer, Electric I

Senior Vice President, Electric Transmission and Distribution Manager Electric System Operations Manager Production Support Restoration Safety Review Committee Senior Vice President Nuclear, Fossil and Hydro Operations Manager Environmental and Laboratory Services

• As of May 15, 2001, the Manager of NPAD is a Consumers Energy employee as is the staff supporting him. Effective July 1, 2001, the Manager, NPAD will become a Nuclear Management Company employee and his supporting staff will be a combination of Consumers Energy and Nuclear Management Company employees.

Figure 1 - Consumers Energy Organization for Big Rock Point Quality Program Page 11 Rev 20 Date: 5/15/01 I

I

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 2.0 QUALITY PROGRAM 2.1 REQUIREMENTS Policies that define and establish the Consumers Energy Quality Program for Nuclear Power Plants (Part 1) - Big Rock Point Nuclear Plant are stated in the individual sections of this document. The program is implemented through procedures and instructions responsive to provisions of the QPD and will be carried out for the life of BRP and its associated ISFSI. Plant/ISFSI life is defined as the period covered by a valid license under 10 CFR 50 or 10CFR 72, respectively.

Quality controls apply to activities affecting the quality of structures, systems and components, to an extent based on the importance of those structures, systems, or components to safety. Such activities are performed under suitably controlled conditions, including the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that all applicable prerequisites have been met.

Quality Program status, scope, adequacy and compliance with 10 CFR 50, Appendix B and 10CFR 72 are regularly reviewed by Consumers Energy Management through reports, meetings and review of audit results. A preplanned and documented assessment of the nuclear safety performance is conducted as described in Appendix C.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 2.2.3 21a, 21.b 2.2.5 19a 2.2.6 1, 19a, 21a, 21b 2.2.9 2j, 4a, 5a, 5b, 6a, 7b, 10a, 11a, 12a, 12b, 12c, 12d, 13a, 17e 2.2.10 2e, 2f 2.2 IMPLEMENTATION 2.2.1 The President and Chief Executive Officer, Electric, has stated in a formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy to comply with the provisions of applicable legislation and regulations pertaining to quality assurance for BRP/ISFSI as defined by 10 CFR 50, Appendix B and 10 CFR 72, Subpart G. The statement makes this QPD and the associated implementing procedures and instructions mandatory and requires compliance by all responsible organizations and individuals. It identifies the Management positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness.

Page 12 Rev 20 Date: 5/15/01

• 62.2.2 QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT The Quality Program at Consumers Energy consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION).

2.2.3 The effectivity and applicability of this QPD are as follows:

a.

For Big Rock Point, the QPD became effective on April 1, 1982, with full implementation on January 1, 1983.

b.

For the ISFSI, in accordance with 10 CFR 72.4, the NRC Spent Fuel Project Office was notified by letter dated February 17, 2000 of Consumers Energy's intent to apply this Quality program to the ISFSI and spent fuel storage cask activities as required by 10 CFR Part 72.140.

c.

The Quality Program described in this Quality Program Description is intended to apply for the life of BRP and its associated ISFSI.

d.

The Quality Program applies to activities affecting the quality of structures, systems, components and related consumables at BRP/ISFSI. Structures, systems, components and related consumables to which this program applies are identified in accordance with the criteria of Regulatory Guide 1.29, as clarified by Items No. 21a and No. 21 b in Part 2 of Appendix A to this QPD, and as described below.

2.2.4 This QPD, organized to present the Consumers Energy Quality Program for Nuclear Power Plants (Part 1) in the order of the 18 criteria of 10 CFR 50, Appendix B, states Consumers Energy requirements for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this QPD that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually as specified by 10 CFR 50.71.e. Any changes made to this QPD that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation in accordance with the requirements of 10 CFR 50.54.

Appendix A to this QPD lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits. Appendix A also describes necessary exceptions and clarifications to the requirements of those documents.

The program described in this QPD will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B.

2.2.5 Documents used for implementing the provisions of the QPD include the following:

a.

Administrative procedures specify the standard methods of accomplishing plant activities. Because the Quality Program is an integral part of these activities, the methods for implementing Quality Program controls are integrated into these documents.

Page 13 Rev 20 Date: 5/15/01 I I I

I I I

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

b.

When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50, Appendix B and the contract, and are approved by Consumers Energy prior to the start of work.

c.

Applicable elements of the Quality Program are applied to emergency plans, security plans, radiation and fire protection plans for BRP/ISFSI. These plans describe quality controls applicable to associated equipment and activities.

2.2.6 Provisions of the Quality Program for Nuclear Power Plants (Part 1) apply to activities affecting the quality of structures, systems, components and related consumables.

Consumers Energy uses the following criteria in the selection of structures, systems, components, and activities to which the Quality Program is applied. Application of the Quality Program assures that such structures, systems, components, and activities are monitored and controlled in a manner sufficient to provide reasonable assurance that they are capable of fulfilling their intended functions.

a.

The Quality Program shall be applied to structures, systems, components, and activities selected based on engineering evaluation that uses the guidance of Regulatory Guides 1.26 and 1.29 to determine those items and activities whose function is important to safe plant operation and shutdown. These items and activities are commonly referred to as "safety related" (see Appendix A).

b.

The Quality Program shall be applied to structures, systems, components, and activities important to the safe storage, control and maintenance of spent nuclear fuel (ISSSF);

c.

The Quality Program shall be applied to structures, systems, components, and activities important to the monitoring and control of radiological hazards (IMCRH).

Application of these criteria in engineering evaluation of an item's function results in its classification and identification as either subject to this Program, or not. Identification may be via a "DQ-List," electronic databases, or other controlled means. Identification is maintained current with plant conditions during dismantlement. This information is available for inquiry by individuals involved in site activities. The extent to which controls specified in the Quality Program are applied is determined for each item considering its relative importance to the above criteria. Such determinations are based on data in such documents as the post-shutdown Technical Specifications, the Updated Final Hazards Summary Report (UFHSR), and the Cask Storage System SAR.

2.2.7 Activities affecting quality of items within the scope of this Program are accomplished under controlled conditions. Preparations for such activities include confirmation that prerequisites have been met, such as:

a.

Assigned personnel are qualified.

Page 14 Rev 20 Date-5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

b.

Work has been planned to the proper revisions of applicable engineering and/or technical specifications.

c.

Specified equipment and/or tools, if any, are on hand to be used.

d.

Materials and items are in an acceptable status.

e.

Systems or structures on which work is to be performed are in the proper condition for the task.

f.

Authorized current instructions/procedures for the work are available for use.

g.

Items and facilities that could be damaged by the work have been protected, as required.

h.

Provisions have been made for special controls, processes, tests and verification methods.

2.2.8 Development, control and use of computer programs affecting nuclear power plant design and operation at BRP/ISFSI are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).

2.2.9 Responsibility and authority for planning and implementing indoctrination and training are specifically designated in the Consumers Energy organization (see Section 1.0, ORGANIZATION).

a.

The training and indoctrination program provides for ongoing training and periodic refamiliarization with this QPD.

b.

Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.58, SNT TC-IA, or the ASME Code, or Section 10.2.3 of this QPD, as applicable.

c.

Personnel who lead audits are qualified in accordance with Regulatory Guide 1.146.

Others are either qualified to ANSI N45.2.23 or have detailed expertise in the area being audited.

d.

Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with applicable codes, standards and regulatory guides.

e.

The training/qualification program for personnel leading audits includes provisions for retraining, reevaluation and recertification to ensure that proficiency is maintained.

f.

Training and qualification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the Page5 1

Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT personnel involved are performing activities to which the traininglqualification is relevant.

g.

Personnel responsible for performing activities that affect quality are instructed as to the requirements identified in applicable quality related manuals, instructions and procedures.

2.2.10 Status and adequacy of the Quality Program are regularly assessed by Consumers Energy Management. The following activities constitute formal elements of that assess ment:

a.

Audit reports, including follow-up on corrective action accomplishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).

b.

The Restoration Safety Review Committee assesses nuclear safety performance as described in Appendix C. Conclusions and recommendations are reported to the Senior Vice President, NFHO.

Corrective actions in response to recommendations are tracked in the regular corrective action tracking system (see Section 16.0, CORRECTIVE ACTION).

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 3.0 DESIGN CONTROL 3.1 REQUIREMENTS Modifications to structures, systems and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are accomplished in accordance with approved designs. Activities to develop such designs are controlled. Depending on the type of modification, these activities include design and field engineering; the performance of physics, seismic, stress, thermal, hydraulic, radiation and UFHSR and ISFSI SAR accident analyses; the development and control of associated computer programs; studies of material compatibility; accessibility for in-service inspection and maintenance; and determination of quality standards. The controls apply to preparation and review of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 3.1 9a, 13b 3.2.9 15a 3.2.10 13d 3.2 IMPLEMENTATION 3.2.1 Authority and responsibility for modification activities is under the cognizance of BRP as described in Section 1.0, ORGANIZATION. This authority and responsibility includes the preparation, review, approval and verification of the following design documents: a)

System descriptions; b) Design input and criteria; c) Drawings and specifications; and d)

Engineering analyses and associated computer programs.

3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect structures, systems and components are documented. Action is taken to assure that the errors and deficiencies are corrected.

3.2.3 Materials, parts and processes that are essential to safety-related functions are selected and specified, based on the requirements of applicable codes and standards or on known, successful use under similar conditions. This includes standard commercial materials, parts and processes. Alternatively, materials, parts and processes may be qualified for use through qualification testing (see Item 3.2.8). The adequacy of the selected materials, parts and processes is assured through the required design verifications or approvals.

3.2.4 Exceptions and waivers to or deviations from the engineering (quality) standards (i.e., the required dimensions, material properties, features and other characteristics specified for modifications) are required by procedure and by contract, when applicable, to be docu Page 17 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT mented and controlled. (See, also, Section 15 concerning the approval of "repair" or "use as is" dispositions of nonconformances.)

3.2.5 When modifications involve design interfaces between internal or external design organizations or across technical disciplines, these interfaces are controlled. Procedures are used for the review, approval, release, distribution and revision of documents involving design interfaces to ensure that structures, systems and components are compatible geometrically, functionally and with processes and environment. Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses. Decisions and problem resolutions involving design interfaces are made by the Consumers Energy organization having responsibility for engineering direction of the design effort.

3.2.6 Checks are performed and documented to verify the dimensional accuracy and completeness of design drawings and specifications (i.e., the products of a design process).

3.2.7 Modification design document packages are reviewed by Plant Engineering personnel to assure that the documents that they contain have been prepared, verified, reviewed and approved in accordance with Company procedures and that they contain the necessary quality requirements. These requirements include the inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results.

I 3.2.8 The extent of and methods for design verification are documented. The extent of design verification performed is a function of the importance of the item to safety, design complexity, degree of standardization, the state-of-the-art and similarity with previously proven designs. Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews. These methods may be used singly or in combination, depending on the needs for the design under consideration.

When design verification is done by evaluating standardized or previously proven designs, the applicability of such designs is confirmed. Any differences from the proven design are documented and evaluated for the intended application.

Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated.

This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function. Qualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented.

Results are evaluated to assure that test requirements have been satisfied. Modifications shown to be necessary through testing are made, and any necessary retesting or other verification is performed. Scaling laws are established and verified, when applicable. Test configurations are clearly documented.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

Design reviews are performed by multi-organizational or interdisciplinary groups or by single individuals. Criteria are established to determine when a formal group review is required and when review by an individual is sufficient.

Unless otherwise stated, the verification of design addresses all information conveyed by the design document. When the verification is limited to certain areas or features, the scope or extent and any limitations on the verification are documented.

3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience but are not directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that:

1.

He is the only technically qualified individual available, and

2.

He has not specified a singular design approach, ruled out certain design considerations or established the design inputs for the particular design aspect being verified, and

3.

His review is either:

a.

Approved in advance by the supervisor's management, with documentation of the approval included in the design package, or

b.

Controlled by a procedure which provides specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification.

Independent audits by NPAD cover the frequency, effectiveness, and technical adequacy of the use of supervisors as design verifiers to guard against abuse.

3.2.10 When designs must be released for use before they have been fully completed or before they have been verified, the incomplete or unverified parts of the design and the hold point to which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function.

Justification for such early release is documented.

3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their use is specified.

3.2.12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original design. Such changes are evaluated for impact. Those that affect fit, form, or function are reviewed and approved by the same, or Page 19 Rev 20 Date: 5/15101

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART I - BIG ROCK POINT NUCLEAR PLANT equivalent, organizations that approved the original design. Information on approved changes is transmitted to all affected organizations.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 REQUIREMENTS Procurement documents for structures, systems, components and services to which this Program applies according to Section 2.0, QUALITY PROGRAM, define the characteristics of item(s) to be procured, identify applicable regulatory and industry codes/standards requirements and specify supplier quality assurance program require ments to the extent necessary to assure adequate quality.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 4.2.1 17c, 17d 4.2.3 21, 17a, 17b 4.2.5 17d 4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement planning and for preparation, review and approval of procurement documents are delineated in Section 1.0, ORGANIZATION.

5 Procurement request packages are reviewed and approved prior to submittal to the Purchasing and Materials Department. Review includes verification that the necessary quality requirements are specified.

The responsible project engineer performs bid evaluations.

4.2.2 Supplier selection is described in Section 7.0, CONTROL OF PURCHASED MATERIALS, EQUIPMENT AND SERVICES.

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

a.

Scope of work to be performed.

b.

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

c.

Regulatory, administrative and reporting requirements.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

d.

Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections.

e.

A requirement for a documented Quality Program, subject to Consumers Energy review and written concurrence prior to the start of work.

f.

A requirement for the supplier to invoke applicable quality requirements on subtier suppliers.

g.

Provisions for access to supplier and subtier suppliers' facilities and records for inspections, surveillances and audits.

h.

Identification of documentation to be provided by the supplier, identification of documents to be compatible with the records system, the schedule of submittals and identification of documents requiring Consumers Energy approval.

4.2.4 Trained, qualified personnel perform and document reviews of procurement request packages to assure that:

a.

Quality requirements (see 4.2.3 of this Section) are correctly stated, inspectable, and controllable.

b.

Adequate acceptance and rejection criteria are included.

c.

The procurement documents have been prepared, reviewed, and approved per the Quality Program requirements.

4.2.5 Changes to the technical or quality requirements in procurement documents are controlled in a manner commensurate with that used for the original requirements. Those that could affect fit, form, function or the necessary assurance of quality are reviewed and approved by the same, or equivalent, organizations that approved the original procurement request packages.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 REQUIREMENTS Activities affecting the quality of structures, systems and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are accomplished using instructions, procedures and drawings appropriate to the circumstances that include acceptance criteria for determining if an activity has been satisfactorily completed.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 5.1 9a, 13b 5.2, item 5 2r, 2s, 8a 5.2, item 10 6b 5.2 IMPLEMENTATION The authority and responsibility for performing activities affecting the quality of structures, systems and components are assigned as described in Section 1.0, ORGANIZATION.

Management personnel assigned these responsibilities assure that the instructions, procedures and drawings necessary to accomplish the activity are prepared and implemented.

Instructions, procedures and drawings incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and/or qualitative (such as workmanship standards) acceptance criteria sufficient to determine that the activity has been satisfactorily accomplished.

Temporary procedures may be issued to provide management instructions which have short-term applicability. Temporary procedures include a designation of the time period during which they may be used.

The procedures used by Consumers Energy to control its activities include the following:

1.

Administrative Procedures.

2.

System procedures that describe the operation of the plant.

3.

Process monitoring procedures that provide for monitoring plant system performance and which, as appropriate, identify limits for significant process parameters.

4.

Fuel-handling procedures that provide for activities such as:

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

a.

Fuel accountability

b.

Receipt and shipment of fuel

c.

Nuclear safety measures

d.

Fuel movement

5.

Maintenance procedures that provide for:

a.

Preparation for maintenance

b.

Performance of maintenance

c.

Post-maintenance and operability checks and tests

d.

Use of supporting maintenance documents

6.

Radiation control procedures that provide for:

a.

Implementation of the radiation control program including the acquisition of radiation data

b.

Identification of equipment for performing radiation surveys

c.

Measurement, evaluation and assessment of radiation hazards

7.

Calibration and test procedures that provide for:

a.

Periodic calibration and testing of instrumentation and control systems

b.

Calibration of portable measuring and test equipment used in activities affecting safety

8.

Chemical-radiochemical control procedures that provide for activities including:

a.

Sampling and analyses

b.

Maintenance of coolant quality

c.

Control of deleterious agents

d.

Control, treatment and management of radioactive wastes

e.

The control of radioactive calibration sources Page 24 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

9.

Emergency Plan Implementing Procedures

10. Inspection, test and examination procedures that identify:

a.

Objectives

b.

Acceptance criteria

c.

Prerequisite and special conditions

d.

Limiting conditions

e.

Test or inspection instructions

f.

Any required special equipment or calibration

g.

Hold and Witness points, as appropriate

11. Modification procedures that provide for:

a.

Administrative control and technical support during plant/ISFSI modifications

b.

The basis for a consistent method of performing recurring engineering, construction and quality activities

c.

Control of the interfaces between Consumers Energy and its suppliers

d.

Control of onsite quality-related modification activities that assure the Quality Program is implemented and its effectiveness is assessed and reported

12. Decommissioning procedures that provide for controlled dismantlement of BRP and restoration of the plant site.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S 6.0 DOCUMENT CONTROL 6.1 REQUIREMENTS Documents controlling activities within the scope defined in Section 2.0, QUALITY PROGRAM, are issued and changed according to established procedures. Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for release prior to implementation by authorized personnel and are distributed and used at the location where a prescribed activity is performed.

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

Personnel authorized to approve procedures specified by Permanently Defueled Technical Specifications are limited to an appropriate senior department manager, based on the activities addressed in the specific procedure, predesignated in writing by the Site General Manager.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 6.1 2h, 2n 6.2.3 2h, 2n, 2s, 12b 6.2 IMPLEMENTATION 6.2.1 The authority and responsibility for the control of documents are described in Section 1.0, ORGANIZATION.

6.2.2 Controls are established for approval, issue and change of documents in the following categories:

a.

Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codesý

b.

As-built drawings (record drawings) and related documents

c.

Procurement documents

d.

Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test, plant/ISFSI maintenance and operation, and decommissioning which implement the Quality Program.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

e.

UFHSR

f.

Reports of nonconformances

g.

Permanently Defueled Technical Specifications 6.2.3 The review, approval, issue and change of the above documents are controlled by:

a.

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

b.

Identification of the organizations responsible for review, approval, issue and revision.

c.

Review of changes to documents by the organizations designated in accordance with the procedure governing the review and approval of specific types of documents, including quality aspects.

6.2.4 Controlled documents are issued and distributed so that:

a.

The documents are available at the work location prior to commencing work.

b.

Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner.

6.2.5 Master lists or equivalent controls are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents. When master lists are used they are updated and distributed to designated personnel who are responsible for maintaining current copies of the lists.

6.2.6 Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 REQUIREMENTS Activities that implement approved procurement requests for material, equipment and services used in systems, structures, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to BRP/ISFSI prior to reliance on equipment, material or services.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 7.1 2i 7.2.2 16d 7.2.3 7b, 17e 7.2.5 2m, 7e, 17f 7.2.6 2m, 9b, 13c, 13d, 17f 7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in Section 1.0, ORGANIZATION.

7.2.2 Consumers Energy qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. To remain qualified, suppliers involved in active procurements are evaluated continuously and are audited triennially. If an audit is acquired from an external source, the audit is evaluated prior to its use.

Supplier evaluation and triennial audits are not necessary when the items or services supplied are all of the following:

a.

Relatively simple and standard in design, manufacture and test, and

b.

Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery, and Page 28 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

c.

Such that receiving inspection does not require operations that could adversely affect the integrity, function or cleanness of the item.

In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service.

7.2.3 Supplier activities that affect quality are verified in accordance with written procedures.

These procedures provide the method of verifying (such as audit, surveillance or inspection) and documenting that the characteristics or processes meet the requirements of the procurement document. For commercial "off-the-shelf" items where the requirements for a specific quality assurance program appropriate for nuclear applications cannot be imposed in a practical manner, source verification is used to provide adequate assurance of acceptability unless the quality of the item can be adequately verified upon receipt.

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

a.

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

b.

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

c.

Where quality requirements for the original items cannot be determined, requirements and controls are established by engineering evaluation performed by qualified individuals. The evaluation assures there is no adverse effect on interfaces, interchangeability, safety, fit, form, function, or compliance with applicable regulatory or code requirements. Evaluation results are documented.

d.

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

7.2.5 Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with procurement requirements not previously verified by source surveillance or inspection and that required supplier furnished documentation is available. Items inspected are identified as to their acceptance status prior to their storage or release for installation.

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• 7.2.6 Suppliers are required to furnish the following records:

a.

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

b.

Documentation identifying any procurement requirements that have not been met.

c.

A description of those nonconformances from the procurement requirements dispositioned "accept as is" or "repair."

d.

Quality records as specified in the procurement requirements.

The acceptability of these documents is evaluated during source and/or receipt inspection.

7.2.7 Supplier's certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure that they are valid. The results of these evaluations are documented.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT IDENTIFICATION AND CONTROL OF ITEMS REQUIREMENTS Materials, parts and components (items) used in structures, systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph 8.2.2 8.2.3 Exceptions/Interpretations 7d, 7g 7a IMPLEMENTATION 8.2.1 Controls are established that provide for the identification and control of materials (including consumables), parts and components, (including partially fabricated assemblies). Responsibility for the identification and control of items is described in Section 1.0, ORGANIZATION.

8.2.2 Items are identified by physically marking the item, its storage area or its container or by maintaining records traceable to the item. The method of identification is such that the quality of the item is not degraded.

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

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

• 9.0 CONTROL OF SPECIAL PROCESSES 9.1 REQUIREMENTS Special processes affecting structures, systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 9.2.1 6c, 13e 9.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at BRP/ISFSI are those for which full verification or characterization by direct inspection is impossible or impractical. Such processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement, and nondestructive examination.

W 9.2.2 Organizational responsibility for implementation of special processes and for qualification of procedures, personnel, and equipment used to perform special processes is indicated in Section 1.0, ORGANIZATION.

9.2.3 Special process procedures are prepared by personnel with expertise in the discipline involved. The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.

9.2.4 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations. Certification is based on examination results.

Personnel qualification is kept current by performance of the special process (es) and/or reexamination at time intervals specified by applicable codes, specifications, and standards. Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals requires recertification.

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

9.2.6 Qualification records are maintained in accordance with QPD Section 17.

9.2.7 The NPAD audits/assesses special process activities, including qualification activities to assure they are satisfactorily performed.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S 10.0 INSPECTION 10.1 REQUIREMENTS Activities affecting the quality of structures, systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are inspected to verify their conformance with requirements. Inspections are accomplished by independent verification or process monitoring as necessary. Verification points are used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 10.2.2 2p, 2q 10.2.3 2j, 6a 10.2.7 2j, 6a 10.2.10 2j 10.2 IMPLEMENTATION

• 10.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.

10.2.2 Inspections are applied to procurement, maintenance, modification,-testing, fuel handling, Inservice inspection and decommissioning to verify that items and activities conform to specified requirements. Work authorizing documents (e.g.; procedures, instructions, maintenance work orders) are reviewed in accordance with established criteria to do the following as necessary:

a.

Determine the need for inspection(s).

b.

Identify the inspection organization or personnel.

c.

Identify independent verification points.

d.

Determine how and when the inspections are to be performed.

e.

Specify measuring and test equipment of the necessary accuracy for performing inspection.

f.

Provide for documentation of inspection results to provide adequate objective evidence of acceptability.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Independent verification is performed at each operation where it is necessary to verify conformance with requirements.

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

10.2.3 Training and qualification programs for personnel who perform inspections, including nondestructive examination, are established, implemented, and documented in accordance with Section 2.0, QUALITY PROGRAM, and plant or offsite procedures.

These programs meet the requirements of applicable codes and standards. The Site General Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility.

Training and qualification programs for Environmental and Laboratory Services (E&LS) personnel who perform inspections, including nondestructive examination, are documented in E&LS procedures.

Training and qualification programs for Electric Services personnel who perform inspections are documented in Electric Services procedures.

Qualifications and certifications of inspection and NDE personnel are maintained.

10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists and are either provided or concurred with by the organization that performs the inspection planning. They (procedures, etc) provide for the following as appropriate:

a.

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

b.

Identification of characteristics and activities to be inspected.

c.

Inspection methods (independent verification or process monitoring).

d.

Specification of measuring and test equipment having the necessary accuracy.

e.

Identification of personnel responsible for performing the inspection.

f.

Acceptance and rejection criteria.

g.

Recording of the inspection results and the identification of the inspector.

10.2.5 Independent verification points are designated when confirmation is needed that critical characteristics are acceptable before the work can be allowed to proceed further.

Independent verifications are performed, and work is released for further processing or Page 34 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT use, by assigned verification personnel. Independent verification points may be waived only by the organization that performs the inspection planning.

10.2.6 Independent verifications are performed and documented in accordance with the written instructions provided. The results are evaluated by designated personnel in order to ensure that the results substantiate the acceptability of the item or work. Evaluation and review results are documented.

Independent verification should be designated when the activity/task being verified is necessary to ensure critical characteristics are in conformance with requirements and/or the verification is the result of codes, standards, regulations, or commitments.

10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:

a.

Qualifications of the independent verifier are equal to or better than the minimum qualifications for persons who can be authorized to perform the task; and

b.

The work is within the skills of Consumers Energy personnel and/or is addressed by Consumers Energy procedures.

c.

If work involves breaching a pressure retaining item, the quality of the work can be demonstrated through a functional test.

When a, b, and c are not met, inspections will be carried out by individuals certified in accordance with ANSI N45.2.6.

The verification is performed by individuals other than the person(s) performing or directly supervising the work.

10.2.8 For independent verification, when acceptance criteria are not met, corrected areas are to be reverified. Results of independent verification are documented and retained for the purposes of performance trending and analysis.

10.2.9 The independent verifier has the authority to stop work if inspection criteria are not met.

Resolution of disagreements between the verifier and worker is resolved by plant management.

10.2.10 Contractors may be used as independent verifiers in accordance with Section 10.2.7 provided:

a.

The work is performed using the Consumers Energy Quality Program and procedures.

b.

Individuals are trained andqualified in accordance with Section 10.2.3.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART I - BIG ROCK POINT NUCLEAR PLANT

• 111.0 TEST CONTROL 11.1 REQUIREMENTS Testing is performed in accordance with established programs to demonstrate that structures, systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification (as applicable), acceptance, surveillance, and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions are specified and met. Test results are documented and evaluated.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paracgraph Exceptions/Interpretations 11.2.2 2k, 17g 11.2 IMPLEMENTATION 11.2.1 Organizational responsibilities for testing are described in Section 1.0, ORGANIZATION.

11.2.2 Tests are performed in accordance with programs, procedures, and criteria that designate when tests are required and how they are to be performed. Such testing includes the following:

a.

Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0, DESIGN CONTROL.

b.

Acceptance tests of equipment and components to assure their proper operation prior to delivery or to pre-operational tests.

c.

Surveillance tests to assure continuing proper and safe operation of systems and equipment.

d.

"Maintenance tests after preventive or corrective maintenance.

11.2.3 Test procedures and instructions include provisions for the following, as applicable:

a.

The requirements and acceptance limits contained in applicable design and procurement documents.

b.

Test prerequisites such as calibrated instrumentation, adequate test equipment, and instrumentation including accuracy requirements, completeness of the item to be Page 37 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT tested, suitable and controlled environmental conditions, and provisions for data collection and storage.

c.

Instructions for performing the test.

d.

Mandatory inspection hold points for witness by the appropriate authority.

e.

Acceptance and rejection criteria.

f.

Methods of documenting or recording test data and results.

g.

Assuring that test prerequisites have been met.

h.

Verification of completion of modification activities.

Test procedures and instructions are reviewed for technical content and quality aspects, by the plant engineering organization, or the offsite technical organization, as applicable When acceptance criteria are not met, corrected areas are to be retested.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART I - BIG ROCK POINT NUCLEAR PLANT 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 REQUIREMENTS Measuring and testing equipment used in activities affecting the quality of structures systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are properly identified, controlled, calibrated, and adjusted at specified intervals to maintain accuracy within necessary limits.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Parapraph Exceptions/Interpretations 12.2.3 2o, 9c 12.2.4 2o, 9c 12.2.5 10c 12.2.8 10b 12.2 IMPLEMENTATION 12.2.1 The authority and responsibility of personnel establishing, implementing and assuring effectiveness of calibration programs is described in Section 1.0, ORGANIZATION.

12.2.2 Procedures are established for measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components. These procedures describe calibration technique and frequency and maintenance and control of the equipment.

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

12.2.4 Consumers Energy uses a system of labels to be attached to measuring and test equipment to display the next calibration due date. Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.

12.2.5 Measuring and test equipment (M&TE) and installed plant instrumentation is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

Calibration of M&TE is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and the basis of acceptance is documented and authorized by responsible management.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.

12.2.6 Calibrating standards have greater accuracy than standards being calibrated. Calibrating standards with the same accuracy may be used if it can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible management.

12.2.7 Reference and transfer standards are traceable to nationally recognized standards; where national standards do not exist, provisions are established to document the basis for calibration.

12.2.8 When measuring and testing equipment used for inspection and test is found to be outside of required accuracy limits at the time of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration. The results of evaluations are documented. Retests or reinspections are performed on suspect items.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

@ 13.0 HANDLING, STORAGE AND SHIPPING 13.1 REQUIREMENTS Activities with the potential for causing contamination or deterioration that could adversely affect the ability of an item (to which this Program applies according to Section 2.0, QUALITY PROGRAM) to perform its intended safety functions, and activities necessary to prevent undetected or uncorrectable damage are identified and controlled. These activities include cleaning, packaging, preserving, handling, shipping, and storing.

Controls are effected through the use of appropriate procedures and instructions implemented by suitably trained personnel.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 13.2.2 7a, 7c, 7d., 7f, 7g, 7h 13.2 IMPLEMENTATION 13.2.1 The authority and responsibility of personnel implementing and assuring the effectiveness of material cleaning, handling, storing, packaging, preserving, and shipping activities is described in Section 1.0, ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storing, packaging, preserving, and shipping of materials, components and systems in accordance with design and procurement requirements. These procedures include, but are not limited to, the following functions:

a.

Cleaning, to assure that required cleanliness levels are achieved and maintained.

b.

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

c.

Handling, to preclude damage or safety hazards.

d.

Storing, to minimize the possibility of loss, damage to or deterioration of items in storage, including consumables such as chemicals, reagents, and lubricants.

Storage procedures also provide methods to assure that specified shelf lives are not exceeded.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 REQUIREMENTS Operating status of structures, systems, and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, is indicated by tagging of valves and switches, or by other specified means, in such a manner as to prevent inadvertent operation. The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/interpretations 14.1 2r 14.2.5 2i 14.2 IMPLEMENTATION 14.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.

14.2.2 For modification activities, including item fabrication, installation and test, procurement documents, service contracts, and procedures specify the degree of control required for the indication of inspection and test status of structures, systems, and components.

14.2.3 Application and removal of inspection and welding stamps and of such status indicators as tags, markings, labels, etc, are controlled by procedures.

14.2.4 The sequence of inspections, tests and other operations important to safety are controlled by procedures. Changes in the approved sequence are subject to the same review and approval as the original, or as specified in administrative procedures if the original organization no longer exists.

14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems, and components is clearly identified and documented to prevent inadvertent use.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 15.1 REQUIREMENTS Materials, parts, or components for structures, systems and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, that do not conform to requirements are controlled in order to prevent their inadvertent use. Nonconforming items are identified, documented, segregated when practical, and dispositioned. Affected organizations are notified of nonconformances The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/interpretations 15.1 2i 15.2 IMPLEMENTATION 15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which render the quality unacceptable or indeterminate, are identified as nonconforming and any further use is controlled. Nonconformances are documented and dispositioned, and notification is made to affected organizations. Personnel authorized to disposition, conditionally release, and close out nonconformances are designated. The authority and responsibility for the implementation of activities related to the processing and control of nonconforming materials, parts, or components are described in Section 1.0, ORGANIZATION.

a.

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

b.

The original inspection planning authority reviews the disposition of nonconformances, and documents concurrence with the acceptance, conditional release or repair of a nonconforming item.

c.

Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the original inspection planning authority.

d.

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

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15.2.2 QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Dispositions of conditionally released items are closed out before the items are relied upon to perform safety-related functions.

15.2.3 Prior to the initiation of preoperational testing on an item, all nonconformances are corrected or dispositioned and evaluated for impact upon the item or the testing program.

15.2.4 Nonconformance reports are analyzed to identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management for review and assessment.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 16.0 CORRECTIVE ACTION 16.1 REQUIREMENTS Conditions adverse to quality of structures, systems, components, or activities to which this Program applies according to Section 2.0, QUALITY PROGRAM, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconform ances, are identified promptly and corrected as soon as practical.

For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude repetition. In these cases, the condition, cause and corrective action taken is documented and reported to appropriate levels of management for review and assessment.

16.2 IMPLEMENTATION 16.2.1 The responsibility and authority for the control of corrective action are described in Section 1.0, ORGANIZATION.

16.2.2 Controls are established to assure that conditions adverse to quality are identified and documented and that appropriate remedial action is taken.

16.2.3 For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded. Corrective action includes determining the cause and extent of the condition, and taking appropriate action to preclude similar problems in the future. The controls also assure that corrective action is implemented in a timely manner.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 17.0 QUALITY RECORDS 17.1 REQUIREMENTS Records that furnish evidence of activities affecting the quality of structures, systems and components to which this Program applies according to Section 2.0, QUALITY PROGRAM, are maintained. They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations 17.1 14b 17.2.5 14c 17.2.8 14a, 14c 17.2 IMPLEMENTATION 17.2.1 Responsibilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION.

17.2.2 Documents that furnish evidence of activities affecting quality are generated and controlled in accordance with the procedures that govern those activities. Upon completion, these documents are considered records. These records include:

a.

Results of reviews, inspections, surveillances, tests, audits, and material analyses

b.

Qualification of personnel, procedures, and equipment

c.

Operating/Decommissioning logs

d.

Maintenance and modification procedures and related inspection results

e.

Reportable occurrences

f.

Records required by Appendix E

g.

Nonconformance reports

h.

Corrective action reports

i.

Other documentation such as drawings, specifications, procurement documents, calibration procedures, and reports Page 46 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Page 47 Rev 20 Date: 5/15/01 0

17.2.3 Inspection and test records contain the following where applicable:

a.

A description of the type of observation

b.

The date and results of the inspection or test

c.

Information related to conditions adverse to quality

d.

Inspector or data recorder identification

e.

Evidence as to the acceptability of the results

f.

Action taken to resolve any discrepancies noted 17.2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times.

Permanent records are maintained for the life of the item. Appendix E identifies retention periods for certain specific records.

17.2.5 Temporary storage of completed documents during processing to become records is in special fire-resistant file cabinets.

17.2.6 Only authorized personnel may issue corrections or supplements to records.

17.2.7 Traceability between the record and the item or activity to which it applies is provided.

17.2.8 Records are stored in remote, dual facilities to prevent damage, deterioration, or loss due to natural or unnatural causes. Records that can only be stored as originals, such as radiographs and some strip charts are retained in a four-hour fire-rated facility.

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 18.0 AUDITS 18.1 REQUIREMENTS A comprehensive system of audits is carried out to provide independent assessment of performance and effectiveness of the Quality Program to achieve nuclear safety, including those elements of the program implemented by suppliers and contractors. Audits are per formed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are documented and are reviewed by management. Follow-up action is taken where indicated.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paraglraph Exceptions/Interpretations 18.2.2 3a, 3b, 16a, 16b 18.2.3 16c 18.2.9 2e 18.2 IMPLEMENTATION 18.2.1 Responsibility and authority for the audit program is described in Section 1.0, ORGANIZATION.

18.2.2 Internal audits are performed in accordance with established schedules that reflect the status and importance to safety of the activities being performed. Audits are conducted in accordance with frequencies stated in Appendix D, Audit Frequencies.

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

18.2.4 Principal contractors are required to audit their suppliers based on performance and on a schedule based on the status and safety importance of the activities being performed.

Such audits shall be initiated early enough to assure an effective Quality Program on the part of their suppliers.

18.2.5 Regularly scheduled audits are supplemented by special audits when significant changes are made in the Quality Program, when it is suspected that quality is in jeopardy or when an independent assessment of program effectiveness is considered necessary.

18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities and items, and review of documents and records to confirm that the Quality Program is effective and properly implemented.

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18.2.7 QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Audit procedures and the scope, plans, checklists, and results of individual audits are documented.

18.2.8 Personnel selected for auditing assignments have experience or are given training commensurate with the needs of the audit and have no direct responsibilities in the areas audited.

18.2.9 Audit data are analyzed by the NPAD. The resulting audit reports identify any quality deficiencies and assess the effectiveness of the Quality Program in the area audited. The reports are distributed to the responsible management of both the audited and auditing organizations.

18.2.10 Management of the audited organization identifies and takes appropriate corrective action to correct observed deficiencies and to prevent recurrence of any significant conditions adverse to quality. Follow-up for internal audits is performed by the NPAD to ensure that appropriate corrective action is taken and is effective. Such follow-up includes re-audits when necessary. For Vendor Audits, such follow-up shall be performed by the organization performing the audit.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

APPENDIX A, PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Energy Quality Program complies with the regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2.

I. Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

2.

10 CFR, Part 50.55a - Codes and Standards.

3.

Regulatory Guide 1.8 - (9/80 Draft) - Personnel Qualification and Training - Endorses ANSI/ANS 3.1 - (12/79 Draft) (application limited as described in exceptions 4a and 5a of Appendix A, Part 2).

4.

Regulatory Guide 1.26 - (2/76, Rev 3) - Quality Group Classification, and Standards for Water

, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants.

5.

Regulatory Guide 1.29 - (9/78, Rev. 3) - Seismic Design Classification.

6.

Regulatory Guide 1.30 (Safety Guide 30) - (8/11/72) - Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment - Endorses ANSI N45.2.4

7.

Regulatory Guide 1.33 - (2178, Rev 2) - Quality Assurance Program Requirements (Operation)

- Endorses ANSI N18.7 - 1976.

8.

Regulatory Guide 1.37 - (3/16/73) - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.1 - 1973.

9.

Regulatory Guide 1.38 - (5177, Rev 2) - Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for water-Cooled Nuclear Power Plants Endorses ANSI N45.2.2 - 1972.

10.

Regulatory Guide 1.39 - (9/77, Rev 2) - Housekeeping Requirements for water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.

11.

Regulatory Guide -1.58 - (9/80, Rev I) - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel - Endorses N45.2.6 1978.

12.

Regulatory Guide 1.64 - (6/76, Rev 2) - Quality Assurance Requirements for the Design Of Nuclear Power Plants - Endorses N45.2.11 - 1974.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

13.

Regulatory Guide 1.74 - (2/74) - Quality Assurance Requirements Terms and Definitions Endorses ANSI N45.2.10 - 1973.

14.

Regulatory Guide 1.88 - (10/76, Rev 2) - Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - Endorses N45.2.9 - 1974.

15.

Regulatory Guide 1.94 - (4/76, Rev 1) - Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -Endorses ANSI N45.2.5 - 1974.

16.

Regulatory Guide 1.116 - (5/77) - Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems - Endorses ANSI N45.2.8 - 1975.

17.

Regulatory Guide 1.123 - (7/77, Rev 1) - Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants - Endorses N45.2.13 - 1976.

18.

Regulatory Guide 1.144 - (9/80, Rev I) - Auditing of Quality Assurance Programs for Nuclear Power Plants - Endorses N45.2.12 - 1977.

19.

Regulatory Guide 1.146 - (8/80) - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants - Endorses N45.2.23 -1978.

20.

Branch Technical Position ASB9.5.1 (Rev 1) Guidelines for Fire Protection for Nuclear Power Plants.

21.

ANSI/ANS 3.1-1987, Selection, Qualification, and Training of Personnel for Nuclear Power Plants (application limited as described in Appendix C of this document).

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT APPENDIX A, PART 2 CONSUMERS ENERGY EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES

1.

General Requirement Certain Regulatory Guides invoke or imply Regulatory Guides and standards in addition to the standard each primarily endorses.

Certain ANSI Standards invoke or imply additional standards.

Exception/Interpretation The Consumers Energy commitment refers to the Regulatory Guides and ANSI Standards specifically identified in Appendix A, Part 1. Additional Regulatory Guides, ANSI Standards, and similar documents implied or referenced in those specifically identified are not part of this commitment.

Imposition of these Regulatory Guides on Consumers Energy suppliers and'subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured.

W

2.

N18.7 General Exception/Interpretation Consumers Energy has established an organization, the Restoration Safety Review Committee, (RSRC) for independent review activities.

The standard numeric and qualification requirements may not be met by the RSRC.

Procedures will be established to specify how the RSRC will acquire necessary expertise to carry out its review responsibilities in accordance with Appendix C, Restoration Safety Review Committee.

2a.

N18.7, Sec 3.4.2 Requirement "The Plant Manager shall have overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation Since Consumers Energy has more than one organization providing services to BRP/ISFSI, overall responsibility cannot be centralized in a single on-site position. Instead, responsibilities are as designated within the QPD.

2b.

N18.7, Sec 4.3.1 Requirement "Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines and shall collectively have the experience and competence required to review problems in the following areas:..."

Exception/Interpretation The RSRC will not have members specified by number or by technical disciplines and its members may not have the experience and competence required to review problems in all areas listed in this section; however, the RSRC will function as described in Appendix C, Restoration Safety Review Committee, and will acquire the services of personnel having such experience and competence as necessary.

2c.

N18.7, Sec 4.3.4 Requirement "The following subjects shall be reviewed by the independent review body:"

Exception/Interpretation Subjects requiring review will be as specified in Appendix C, Restoration Safety Review Committee.

2d.

N18.7, Sec 4.3.4(3)

Requirement Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/interpretation The RSRC will not review Technical Specification Changes after NRC approval prior to implementation. The basis for this position is that all Technical Specification changes are reviewed prior to submittal to the NRC.

2e.

N18.7, Sec 4.5 Requirement Written reports of audits specified in ANSI N18.7 shall be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited.

Exception/Interpretation The RSRC shall review or arrange for reviews of those audits over which it has cognizance, in accordance with Appendix C, Restoration Safety Review Committee.

Some of the audits required during the operational and decommissioning phase are in areas other than those requiring independent review in accordance with ANSI N 18.7, Section 4.3.4.

S2f.

N18.7, Sec 4.5 Requirement Periodic review of the audit program shall be performed by the independent review body or by a management representative at least semiannually to assure that audits are being accomplished in accordance with requirements of technical specifications and of this standard.

Exception/Interpretation Audits of nuclear facility activities are performed under the cognizance of the RSRC as described in Appendix C, Restoration Safety Review Committee.

2g.

N18.7, Sec 5.2.1 Requirement "The responsibilities and authorities of the plant operating personnel shall be delineated."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation On-site personnel not directly associated with operating activities, as defined in ANSI N18.7, Section 2.2, are not considered to be operating personnel.

2h.

N 18.7, Sec 5.2.2 Requirement "Temporary changes, which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators license on the unit affected."

Exception/Interpretation Consumers Energy considers that this requirement applies only to procedures identified in Plant Technical Specifications and to Security and Emergency Plans implementing procedures. Temporary changes to these procedures may be made provided:

a.

The intent of the original procedure is not altered;

b.

The change is approved by two members (or designated alternates) of the SRC, at least one of whom is a Certified Fuel Handler; and

c.

The change is documented, subsequently reviewed by the SRC within 30 days of issuance, and approved by an appropriate* senior department manager predesignated by the Site General Manager.

Determination of the appropriate senior department manager is based on the activities addressed in the specific procedure, and will be predesignated in writing by the Site General Manager.

2i.

N18.7, Sec 5.2.6 Requirement "In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation Consumers Energy initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which is required to verify equipment acceptability. This action includes a technical evaluation of the equipment's operability status.

2j.

N18.7, Sec 5.2.7 Requirement The following standards contain useful guidance concerning design and construction-related activities associated with modifications and shall be applied to those activities that are comparable in nature and extent to related activities occurring during initial plant design and construction: American National Standard Installation, Inspection and Testing of Instrumen tation and Electric Equipment During the Construction of Nuclear Power Generation Station, N45.2.4-1972 (IEEE 336-1972) [6]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, N45.2.5-1974 [7];

American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973 [5]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for Construction Phase of Nuclear Power Plants, N45.2.8-1975 [8]; American National Standard Quality Assurance Requirements for the Design of Nuclear Power Plants, N45.2.11 1974 [9]; and American National Standard Quality Assurance for Protective Coating Applied to Nuclear Facilities N101.4-1972 [10].

Considerable care is required in assessing which operational phase activities are comparable in nature and extent to activities normally associated with design and construction.

Exception/Clarification Work that is within the skills of Consumers Energy personnel and is covered by Consumers Energy procedures may be inspected by independent verifiers qualified in accordance with Section 10.2.3 and 10.2.7 and 10.2.10, rather than ANSI N45.2.6.

2k.

N18.7, Sec 5.2.8 Requirement "A surveillance testing and inspection program...shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART I - BIG ROCK POINT NUCLEAR PLANT Exception/I nterpretation Separate master schedules may exist for different programs such as ISI, Pump and Valve Testing, and Technical Specification Surveillance Testing.

21.

N18.7, Sec 5.2.13.1 Requirement "To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 - 1971."

Exception/Interpretation To the extent necessary, procurement documents require that the supplier have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.

2m.

N18.7, Sec 5.2.13.2 Requirement ANSI N 18.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

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

2n.

N18.7, Sec 5.2.15 Requirement 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.

Exception/Interpretation Consumers Energy has in place programmatic procedure preparation, review and usage controls that ensure procedures are technically and administratively correct and make a biennial review program unnecessarily duplicative. These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications Page 57 Rev 20 Date: 5/15101

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT are revised), when unusual incidents occur, when plant modifications are made, and when significant deficiencies are identified. In addition, procedures may be reviewed because industry experience reviews or self-assessments identify deficiencies or opportunity for improvement. Revisions are made as necessary.

Because of their critical nature, non-routine procedures, such as Emergency Operating Procedures, Off-Normal Procedures, Special Operating Procedures, Special Test Procedures, Fuel Handling Procedures, Emergency Plan Implementing Procedures, and others where use would be dictated by a particular event are reviewed at least every two years and revised as appropriate.

In addition, procedures that have not been used or reviewed for two years are reviewed prior to use to determine if changes are necessary or desirable.

An assessment performed at least every two years includes examination of selected plant procedures to determine procedure acceptability and verify that the procedure review and revision controls are effectively implemented. Identified deficiencies are corrected in accordance with Section 16.0 of this QPD.

2o.

N18.7, Sec 5.2.16 Requirement Records shall be made and equipment suitably marked to indicate calibration status.

Exception/Interpretation See Item 9c.

2p.

N18.7, Sec 5.2.17 Requirement For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities (see also Section 5.2.7)

Exception/Interpretation Maintenance and modification activities which are within the skills of Consumers Energy maintenance personnel and are carried out using Consumers Energy procedures may be inspected by independent verifiers qualified in accordance with Sections 10.2.3, 10.2.7, and 10.2.10 of this program description.

2q.

N18.7, Sec 5.2.17 Page 58 S

Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Requirement If mandatory inspection hold points are required, the specific hold points shall be indicated in appropriate documents. Information concerning inspection shall be obtained from the related design drawings, specifications, and/or other controlled documents.

Exception/Interpretation Consumers Energy uses the terminology "independent verification points" as equivalent to hold points.

2r.

N18.7, Sec 5.3.5(3)

Requirement Instructions shall be included, or referenced (in maintenance procedures), for returning the equipment to its normal operating status.

Exception/Interpretation At Consumers Energy, equipment is returned to its normal operating status, i.e., declared operable, by qualified Operations Department personnel, not Maintenance personnel.

Operations personnel verify and document equipment operability through second level line-up verification or appropriate functional testing.

2s.

N18.7, Sec 5.3.5(4)

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

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

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 3a.

RG 1.33, Sec C4a Requirement The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six months.

Exception/Interpretation Performance trends are reviewed by the RSRC. In addition, the corrective action system is audited in accordance with Appendix D, Audit Frequencies.

3b.

RG 1.33, Sec C4b Requirement The conformance of facility operations to provisions contained within the Technical Specifications and applicable license conditions-at least once per 12 months.

Exception/Interpretation Consistent with guidance presented in NRC letters dated March 29, 1983 (RLSpessard to JMTaylor) and January 30, 1984 (JGPartlow to RLSpessard), Consumers Energy interprets the commitment to audit Technical Specification/license conditions contained in 18.2.2 of this QPD, and in Appendix D, Audit Frequencies, as follows:

Consumers Energy maintains a matrix that identifies all applicable Technical Specification line items to be audited. The matrix is updated annually to conform to approved Technical Specification changes. During each 12 month period, a selected sample of line items, with the exception of the onsite and offsite review committee which are audited every 24 months, is audited:

1.

Limiting Conditions for Operation

2.

Limiting Safety System Settings

3.

Reactivity Control Systems

4.

Power Distribution Limits

5.

Instrumentation

6.

Reactor Coolant System

7.

Emergency Core Cooling System

8.

Containment Systems

9.

Plant Systems

10.

Electrical Power Systems

11.

Refueling Operations

12.

Special Tests

13.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

14.

Offsite Committee

15.

Administrative Controls Audits are scheduled so that all line items are covered within a maximum period of 5 years.

The audit period for any of the above elements may be reduced depending on Technical Specification compliance history.

4a.

ANS 3.1, General Exception/Interpretation The commitment to ANS 3.1 (12/79, draft) is limited to the requirements that apply to the training and qualification of persons performing independent quality assurance functions, except for Lead Auditors. Lead auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ANSI 45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.

5a.

RG 1.8, C.3.1, General Exception/Interpretation The commitment to Regulatory Guide 1.8 (9/80, draft) is limited to the requirements that apply to the training and qualification of persons performing independent quality assurance functions, except for Lead Auditors. Lead Auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.

5b.

RG 1.8, C1.2.2 Requirement "When an individual is hired to temporarily function as a plant employee, such as for contracted services, evidence of previous education, experience, and training should be provided and reviewed by the appropriate professional-technical group leaders. The appropriate group leaders should then determine the content for that individual's training, including plant-specific training. As a minimum, each individual should receive General Employee Training."

Exception/Interpretation Consumers Energy understands that this requirement applies both to Consumers Energy employees from another site and to contract personnel who are temporarily assigned to BRP either as replacements for regular employees or to augment the staff. Consumers Energy employees so assigned possess the required qualifications as a prerequisite to the assignment and the review is waived. The qualifications of contract personnel are reviewed and arrangements made for any necessary training. Temporarily assigned personnel Page 61 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT requiring unescorted access receive the site general orientation as embodied in General Employee Training.

6a.

N45.2.1, Sec 2.4 Requirement Those personnel who perform inspection, examination, or testing activities required by this standard shall be qualified in accordance with ANSI N45.2.6 Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants.

Exception/Interpretation Consumers Energy certifies its inspectors in accordance with Paragraph 10.2.7 of CPC-2A unless the work is comparable in nature and extent to original construction (See Item 2j).

6b.

N45.2.1, Sec 3.1 Requirement N45.2.1 establishes criteria for classifying items into "cleanness levels," and requires that items be so classified.

Exception/Interpretation Instead of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activities is addressed on a case-by-case basis.

Cleanness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material. As a minimum, cleanness inspections are performed prior to system closure. Such inspections are documented.

6c.

N45.2.1, Sec 5 Requirement "Fitted and tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other non-halogenated plastic film until the welds can be completed."

Exception/Interpretation Consumers Energy sometimes uses other non-halogenated material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 7a.

N45.2.2, General Requirement N45.2.2 establishes requirements and criteria for classifying items subject to this program into protection levels.

Exception/Interpretation Instead of classifying items subject to this program into protection levels, controls over the packaging, shipping, handling, and storage of such items are established on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

7b.

N45.2.2, Sec 2.4 Requirement

"...Offsite inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N45.2.6."

Exception/Interpretation Offsite inspection, examination, or testing activities are audited or inspected by persons qualified and certified in accordance with ANSI N45.2.23-1978, as endorsed by Regulatory Guide 1.146, or by personnel meeting the requirements of 10.2.7, respectively. Monitoring activities not involving audit or inspection may be conducted by persons trained and qualified to effectively carry out such tasks, but not necessarily certified to either ANSI N45.2.23, N45.2.6 or Paragraph 10.2.7.

7c.

N45.2.2, Sec 3.4.1 and Appendix A, 3.4.1(4) and (5)

Requirement

"(4)...However, preservatives for inaccessible inside surfaces containing reactor coolant water shall be indicated to facilitate touch up.

(5) The name of the preservative used shall be the water flushable type."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation Based on comparison of these statements to ANSI/ASME NQA-2 1983, Consumers Energy believes the intent was to establish the following as requirements:

A(4)... However, preservatives for inaccessible inside surfaces of pumps, valves, and pipe for systems containing reactor coolant water shall be the water flushable type.

(5) The name of the preservative used shall be provided to facilitate touch-up.

7d.

N45.2.2, Sec 3.9 and Appendix A 3.9 Requirement "The item and the outside of containers shall be marked."

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

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

7e.

N45.2.2, Sec 5.2.2 Requirement "The inspections shall be performed in an area equivalent to the level of storage."

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

7f.

N45.2.2, Sec 6.2.4 Requirement "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall not be permitted."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation Packaged food for emergency or extended overtime use may be stored in material stock rooms. The packaging assures that materials are not contaminated. Food will not be "used" in these areas.

7g.

N45.2.2, Sec 6.3.4 Requirement "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."

Exception/Interpretation See N45.2.2, Section 3.9 (Exception 7d).

7h.

N45.2.2, Sec 6.4.1 Requirement "Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its container...is being maintained."

Exception/Interpretation The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule. Instead, the inspections and examinations are performed and documented in accordance with material storage procedures which identify the characteristics to be inspected and include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.

8a.

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

Exception/Interpretation Instead of the five-level zone designation system referenced in ANSI N45.2.3, Consumers Energy bases its controls over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modifications work, are Page 65 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible. However, in preparing these procedures, consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3.

9a.

N45.2.4, Sec 2.2 Requirement Section 2.2 establishes prerequisites which must be met before the installation, inspection, and testing of instrumentation and electrical equipment may proceed. These prerequisites include personnel qualification, control of design, conforming and protected materials, and availability of specified documents.

Exception/Interpretation During the decommissioning phase, this requirement is considered to be applicable to modifications and initial start-up of electrical equipment. For routine or periodic inspection and testing, the prerequisite conditions will be achieved as necessary.

9b.

N45.2.4, Sec 2.2(5)

Requirement Section 2.2(5) of ANSI N45.2.4 lists documents which are to be available at the construction site.

Exception/Clarification All of the documents listed are not necessarily required at the plant site for installation and testing. Consumers Energy assures that they are available to the site as necessary.

9c.

N45.2.4, Sec 6.2.1 Requirement "Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed the calibration."

Exception/Interpretation Frequently, physical size, and/or location of Installed Plant Instrumentation (IPI) mandates that calibration labels or tags not be affixed to IPI. Instead, each instrument is uniquely identified and is traceable to its calibration record.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT A scheduled calibration program assures that each instrument's calibration is current.

1Oa. N45.2.5, Sec 2.4 Requirement "Persons charged with engineering managerial responsibility of the inspection and testing organization at the site in either a resident or non-resident capacity shall be certified for Level III capability."

Exception/Interpretation This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activity in the areas of concrete and structural steel which do not generally occur at an operating plant. At Consumers Energy, persons having engineering managerial responsibility for inspections and tests* may be certified to Level Ill, or may meet other qualification criteria established for the position, including, but not limited to, nuclear power and management experience. For major modifications involving significant concrete or structural steel work, the services of a properly qualified Level III individual will be obtained in at least an advisory capacity.

within the scope of N45.2.5 lOb. N45.2.5, Sec 2.5.2 Requirement "When discrepancies, malfunctions, or inaccuracies in inspection and testing equipment are found during calibration, all items inspected with that equipment since the last previous calibration shall be considered unacceptable until an evaluation'has been made by the responsible authority and appropriate action taken."

Exception/Interpretation Consumers Energy uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The N18.7 requirements are more applicable to a plant undergoing decommissioning.

1Oc. N45.2.5, Sec 5.4 Requirement "Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more often if deemed necessary. Impact torque wrenches used for inspection must be calibrated at least twice daily."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

Exception/Interpretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 11a. N45.2.6. Sec 1.2 Requirement "The requirements of this standard apply 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 start-up testing, and during operational phases of nuclear power plants."

Exception/I nterpretation See Exception/Interpretation 2j for those inspectors who must be certified to this standard.

Others are qualified to Paragraph 10.2.7 of CPC-2A.

Qualification of plant personnel who are involved with testing associated with plant operation is provided in specific plant specifications. In addition, personnel participating in inspection or testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 but need only be trained to the extent necessary to perform the assigned function.

12a. RG 1.58. Sec C.1 Requirement "However, for qualification of personnel (1) who approve preoperational, start-up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start-up and operational tests, the guidelines contained in Regulatory Guide 1.8, Personnel Selection and Training, should be followed in lieu of the Guidelines of ANSI N45.2.6 - 1978."

Exception/Interpretation Consumers Energy endorses this position, as also stated in 11 a, above, except that offsite support organizations involved in testing may apply ANSI N45.2.6. Some of these departments have already developed their qualification programs based on ANSI N45.2.6, and provide services throughout the decommissioning of BRP.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 12b. RG 1.58, Sec C.5 Requirement "In addition, the individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives."

Exception/Interpretation While a Level III individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives, this is not construed by Consumers Energy as requiring personnel who review, approve or evaluate such procedures to be certified as Level III personnel.

12.c. RG 1.58, Sec C.6 Requirement "Since only one set of recommendations is provided for the education and experience of personnel, a commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be followed."

Exception/Interpretation The education and experience recommendations given in ANSI N45.2.6, Section 3.5 will be treated as such, since our qualification and certification program is based upon these recommendations, and more significantly, upon satisfactory completion of capability testing prior to certification. It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.

12.d RG 1.58, Sec C.10 Requirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experience should result in documented evidence (i.e., procedure and record of written test) demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/Interpretation We will maintain documented objective evidence that demonstrates that an individual does have "comparable" or "equivalent" competence to that which would be gained from having the required education and experience. However, this may take the form of documentation other than "procedures and records of written test" such as documentation of oral tests and on-the job performance demonstrations.

13a. N45.2.8, Sec 2.7 Requirement Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6.

Exception/Interpretation See Exception/Interpretation 2j, 11 a, and 12a. Test personnel who are part of the plant staff need not be certified to N45.2.6, provided they meet applicable qualification criteria of plant Technical Specifications.

13b. N45.2.8, Sec 2.9 Requirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel and procedure qualification, control of design, material selection and fabrication, and availability of specified documents.

Exception/I nterpretation During the decommissioning phase, this requirement is considered to be applicable to modifications of mechanical equipment. For routine or periodic inspection and testing, the prerequisites will be achieved as necessary.

13c. N45.2.8, Sec 2.9e Requirement Section 2.9e of N45.2.8 lists documents relating to the specific stage of installation activity which are to be available at the construction site.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exceptionlinterpretation All of the documents listed are not necessarily required at the plant site for installation and testing. Consumers Energy assures that they are available to the site as necessary.

13d. N45.2.8, Sec 2.9e Requirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.

Exception/Interpretation Equipment may be installed before final approval of engineering or design changes. However, the system is not declared operable until such changes are documented and approved.

13e. N45.2.8, Sec 4.5.1 Requirement "Installed systems and components shall be cleaned, flushed, and conditioned according to requirements:....." (Requirements are given for chemical conditioning, flushing and process controls.)

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

14a. N45.2.9, Sec 5.4, Item 2 Requirement Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel cabinets are preferred.

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

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S 14b. N45.2.9, Sec 6.2 Requirement "A list shall be maintained designating those personnel who shall have access to the files."

Exception/Interpretation Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms exist for general use and backup.

14c. RG 1.88, C2 Requirement "Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974. NFPA No 232-1975...also contains provisions for records protection equipment and records handling techniques that provide protection from the hazards of fire. This standard, within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the fire protection provisions listed in Subdivision 5.6...When NFPA 232-1975 is used, quality assurance records should be classified as NFPA Class 1 records...."

Exception/Interpretation Consumers Energy adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Class 1 records (usually NFPA Class C, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Class 350).

15a. RG 1.64, C2 Requirement "Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design......

Exception/Interpretation Consumers Energy follows the requirements of ANSI N45.2.11-1974, Section 6.1, and the guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9, herein). This approach is necessary to 5

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT allow small organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks.

16a. RG 1.144, Sec C3a(1)

Requirement This section requires that for operational phase activities, RG 1.33 "Quality Assurance Program Requirements (Operations)" are to be followed. One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six months.

Exception/Interpretation See Item 3a for the exception to this requirement.

16b. RG 1.144, Sec C3a(2)

Requirement Applicable elements of an organization's quality assurance program (for "design and construction phase activities") should be audited at least annually or at least once within the life of the activity, whichever is shorter.

Exception/Interpretation Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.

16c. RG 1.144, Sec C3b(1)

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

Exception/Interpretation In addition to the exemptions of RG 1.144, Consumers Energy considers that Authorized Inspection Agencies, National Institute of Standards and Technology or other State and Federal Agencies which may provide services to Consumers Energy are not required to be audited.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 16d. RG 1.144, Sec C.3.b(2), second paragraph Requirement A documented evaluation of the supplier should be performed annually. 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).

Exception/Interpretation Consumers Energy will review the information described in the second paragraph of section C.3.b(2) of Regulatory Guide 1.144, Revision 1, 1980, as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.

17a. N45.2.13, Sec 3.2.2 Requirement N45.2.13 requires that technical requirements be specified in procurement documents by reference to technical requirement documents. Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.1 1.

Exception/Interpretation For replacement parts and materials, Consumers Energy follows ANSI N18.7, Section 5.2.13, Subitem 1, which states: 'Where the original item or part is found to be commercially 'off the shelf or without specifically identified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance."

17b. N45.2.13, Sec 3.2.3 Requirement "Procurement documents shall require that the supplier have a documented quality assurance program that implements portions of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards."

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT Exception/I nterpretation Refer to Item 21.

17c. N45.2.13, Sec 3.3(a)

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

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

17d. N45.2.13, Sec 3.3(b)

Requirement "Changes made in the procurement documents as a result of the bid evaluations or precontract negotiations shall be incorporated into the procurement documents. The review of such changes and their effects shall be completed prior to contract award."

Exception/Interpretation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems 1 through 5.) The timing of reviews will be the same as for review of the original procurement document.

17e. N45.2.13, Sec 7.5 Requirement "Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as applicable."

Exception/interpretation Consumers Energy qualifies audit personnel according to N45.2.23. Thus, personnel performing source verification audits may not be certified according to N45.2.6. Personnel performing inspection as part of source verification will be certified to N45.2.6 or qualified in accordance with Paragraph 10.2.7. However, personnel performing source surveillances may not be certified to any of those requirements.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT 17f.

N45.2.13, Sec 10.1 Requirement "Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods."

Exception/Interpretation Refer to Item 2m.

17g. N45.2.13, Sec 10.3.4 (as modified by RG 1.123, C6e)

Requirement "Post-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."

Exception/Interpretation In exercising its ultimate responsibility for its Quality Program, Consumers Energy establishes post-installation test requirements, giving due consideration to supplier recommendations.

18a. ANSI N45.2.23-1978, Section 2.3.4 Requirement The prospective lead auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality assurance audit within the year prior to his qualification.

Exception/Interpretation The prospective lead auditor shall demonstrate his ability to properly implement the audit process defined by this Standard and Consumers Energy program/procedure, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear quality assurance audit within the year preceding date of certification.

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QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S19a.

RG 1.26, General Requirement RG 1.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements.

(However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are not.)

Exception/Interpretation RG 1.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety-related determinations. Regulatory Guide 1.29, subject to Exception/Interpretation 21a, is used to determine what systems and equipment are included in the Quality Program. Other criteria, as specified in Section 2.0 are also used to establish the SSCs and activities to which this Program shall be applied.

20a. Branch Technical Position ASB9.5.1 and 10 CFR 50 Appendix RSections III G., III J., and III O.,General Exception/Interpretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 Appendix R except for the specific exemptions approved by the NRC.

21a. RG 1.29, Sec C, Regulatory Position Requirement The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category 1 and should be designed to withstand the SSE.

Exception/Interpretation BRP was designed, constructed and licensed based on criteria available prior to Revision 3 of this Regulatory Guide being issued. The specific design criteria and seismic designations are reflected in the UFHSR and in other docketed analysis. Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.

The criteria of this Regulatory Guide are used at Consumers Energy primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 21b, below).

Page 77 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

• 21b.

RG 1.29, General Requirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B.

Exception/Interpretation The pertinent quality requirements for these systems, structures and components will be determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.

22.

ANSI/ANS 3.1 - 1987 Exception/Interpretation The commitment to ANSI/ANS 3.1-1987 is limited to requirements that apply to persons performing the independent safety review function as specified in Appendix C to this QPD.

Page 78 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT APPENDIX B SAFETY REVIEW COMMITTEE (SRC) (BIG ROCK POINT)

B1.

FUNCTION The Safety Review Committee (SRC) shall function to advise the Site General Manager on all matters related to nuclear safety.

B2.

COMPOSITION The BRP SRC is composed of a Chairman and a minimum of four members from the BRP staff. The SRC members shall meet or exceed the minimum qualifications described in Sections 4.2 and 4.4 of ANSI N18.1-1971 for comparable positions. The SRC shall include representatives from Operations, Engineering and Licensing, and Radiation Protection and Environmental Services. The members shall be designated in, writing, by the Site General Manager. The Site General Manager shall also designate an Alternate Chairman in writing.

B3.

ALTERNATES Alternate members of the SRC shall be appointed in writing by the SRC Chairman to serve on a temporary basis. No more than one alternate shall participate as a voting member at any one time in BRP SRC activities.

SB4.

MEETING FREQUENCY The BRP SRC shall meet at least monthly while fuel is stored in the spent fuel pool during the pre-dismantlement and dismantlement phases. During the safe storage phase (no fuel in the spent fuel pool), SRC shall meet at least quarterly.

B5.

QUORUM A quorum of the BRP SRC shall consist of the Chairman or alternate Chairman and two members, which may not include more than one alternate member.

B6.

RESPONSIBILITIES The SRC shall be responsible for nuclear safety review of:

a.

All procedures and programs specified by the Technical Specifications and changes thereto, and any other procedures or changes thereto as determined by the Site General Manager to affect nuclear safety; all proposed tests or experiments that affect nuclear safety; all proposed changes or modifications to plant systems or equipment or the ISFSI that affect nuclear safety.

b.

All proposed changes to Operating License, the ISFSI License, Technical Specifications, and the Spent Fuel Storage System Certificate of Compliance.

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Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT S

c.

Results of investigations of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and recommendations to prevent recurrence and be forwarded to the Vice President, NFHO, the Manager, NPAD, and the RSRC).

d.

Plant/ISFSI operations to detect potential safety hazards.

e.

Reports of special reviews and investigations as requested by the Site General Manager, the Manager, NPAD, or RSRC.

f.

Site Emergency Plan and implementing procedures.

g.

All reportable events as defined in 10 CFR 50.72, 50.73, 72.74, and 72.75

h.

Nuclear industry operating experience.

i.

Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Site General Manager, the Manager, NPAD, and RSRC.

SRC review of the above items may be performed by routing, subject to the requirements of B7., below.

B7.

AUTHORITY The SRC shall:

a.

Recommend in writing to the Site General Manager approval or disapproval of items considered under B6.a. through i. above.

b.

Render determinations in writing with regard to whether or not each item considered under B6.a, b, and c, above needs prior NRC approval.

c.

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 Senior Vice President, NFHO, the Manager, NPAD, and RSRC of any disagreements between the SRC and the Site General Manager; however, the Site General Manager shall have responsibility for the resolution of such disagreements.

Page 80 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT The SRC Chairman may recommend to the Site General Manager approval of those items identified in B6, above based on a routing review provided the following conditions are met:

(1) at least three SRC members, including the Chairman and not more than one alternate, shall review the item, concur with determination as to whether or not the item requires prior NRC approval, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the SRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers.

The item shall be reviewed at a SRC meeting in the event that: (1) Comments are not resolved; or (2) the Site General Manager overrides the recommendations of the SRC; or (3) a proposed change to the Technical Specifications involves a safety limit, a limiting safety system setting or a limiting condition for operation; or (4) the item was reportable to the NRC.

B8.

RECORDS The SRC shall maintain written minutes of each SRC meeting and shall provide copies for RSRC review.

Page 81 Rev 20 Date: 5/15/01 I

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT APPENDIX C RESTORATION SAFETY REVIEW COMMITTEE The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:

Paragraph Exceptions/Interpretations Cl.

2, 2c, C2 2,22 C3 2, 2b, 22 C4.1 2c C4.1(b) 2d C4.1(i) 2e, 2f C1.

FUNCTION The Restoration Safety Review Committee (RSRC) shall function to provide independent review of activities in the areas of:

a.

Nuclear power plant operation/decommissioning

b.

Nuclear engineering

c.

Chemistry and radiochemistry

d.

Metallurgy

e.

Nondestructive testing

f.

Instrumentation and control

g.

Radiological safety

h.

Mechanical and electrical engineering

i.

Administrative controls and quality assurance practices

j.

Emergency Planning

k.

Training C2.

COMPOSITION The RSRC shall report to the Senior Vice President, NFHO and shall consist of a Chairman and members appointed by the Senior Vice President - NFHO. RSRC members shall meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1-1987. The RSRC members shall have no direct responsibility for activities subject to their review.

C3.

SUPPORT PERSONNEL If sufficient expertise is not available within the RSRC to review particular issues, the RSRC shall have the authority to utilize consultants or other qualified organizations for expert advice.

Support personnel shall meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1-1987. Support personnel shall have no direct responsibility for activities they Page 82 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT review.

C4.

RESPONSIBILITIES C4.1 REVIEW The RSRC shall review:

a.

50.59 and 72.48 evaluations for proposed changes in the facility, procedures or conduct of tests or experiments completed under the provisions of 10 CFR 50.59 and 72.48 to verify that an acceptable safety analysis is provided and prior NRC approval was requested as required by 10 CFR 50.59 and 72.48.

b.

Proposed changes to Technical Specifications, the ISFSI License, or the Spent Fuel Cask Storage System Certificate of Compliance to verify that the changes are consistent with applicable requirements and that an acceptable safety analysis is provided.

c.

Proposed changes to the Operating License.

d.

Violations of codes, regulations, orders, Technical Specifications, license requirements, Cask Storage System Certificate of Compliance, or of internal procedures or instructions having nuclear safety significance.

e.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment or the ISFSI that affects nuclear safety.

f.

All reportable events having nuclear safety significance.

g.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.

h.

Reports and meeting minutes of the SRC.

i.

Reports of audits performed as specified in Appendix D.

RSRC review of the subjects in C4 above shall be performed by members or support personnel selected on the basis of technical expertise relative to the subject being reviewed.

If the assigned reviewer determines the need for interdisciplinary review, a committee consisting of the RSRC Chairman, or his designate, and at least four RSRC members or qualified support personnel, shall be assigned. Such committee shall meet as conditions requiring interdisciplinary review arise, but no less than twice yearly.

Page 83 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT C5 AUTHORITY The RSRC shall report to and advise the Senior Vice-President, NFHO, of significant findings associated with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.

C6 RECORDS Records of RSRC activities shall be maintained. Reports shall be prepared and distributed as indicated below:

a.

The results of reviews performed pursuant to C4 above shall be reported to the Senior Vice-President, NFHO, at least monthly.

b.

A report assessing Big Rock's overall nuclear safety performance shall be provided to senior Consumers Energy management annually.

Page 84 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT APPENDIX D AUDIT FREQUENCIES DI.

AUDITS Audits of operational and decommissioning activities subject to this Program are performed by the NPAD staff under the cognizance of the RSRC. These audits encompass:

a.

The conformance of plant operation to provisions contained within the Technical Specifications, applicable license conditions, and the Spent Fuel Storage Cask System Certificate of Compliance at least once per 12 months.

b.

The performance, training and qualifications of the entire facility staff at least once per 12 months.

c.

The performance of activities required by the QPD for Nuclear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50, Appendix B at least once per 24 months.

d.

The Site Emergency Plan and implementing procedures at least once per 12 months.

e.

The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 12 months.

f.

Any other area of plant/ISFSI operation considered appropriate by NPAD or the Senior Vice President, NFHO.

g.

The plant Fire Protection Program and implementing procedures at least once per 24 months.

h.

An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

i.

An inspection and audit of the fire protection and loss prevention program to be performed by an outside qualified fire consultant at intervals no greater than 3 years.

j.

Radiological environmental monitoring program and the results thereof at least once per 12 months.

k.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

Page 85 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

1.

The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

Audit reports encompassed by D1. above shall be forwarded to the Manager, NPAD, and Management positions responsible for the areas audited within thirty (30) days after completion of the audit.

Page 86 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT APPENDIX E RECORD RETENTION El.

In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

Where 1 OCFR 72 or the Part 72 license conditions do not specify a retention period for a record, the records shall be retained until the NRC terminates the license.

E2.

The following records shall be retained for at least five years:

a.

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

b.

Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c.

All reportable events as defined in 10 CFR 50.72, 50.73, 72.74, and 72.75.

d.

Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications.

e.

Records of changes made to the procedures required by Plant Technical Specifications.

f.

Records of radioactive shipments.

g.

Records of sealed source leak tests and results.

h.

Records of annual physical inventory of all source material of record.

E3.

The following records shall be retained for the duration of the Facility 10 CFR 50 or Part 72 License:

a.

Record and drawing changes reflecting facility design modifications made to systems and equipment described in the BRP UFHSR.

b.

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

c.

Records of quarterly radiation exposure for all individuals entering radiation control areas.

d.

Records of gaseous and liquid radioactive material released to the environs.

e.

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

f.

Records of in-service inspections performed pursuant to Plant Technical Specifications.

Page 87 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT

g.

Records of Quality Assurance activities required by the QPD.

h.

Records of reviews performed for changes made to procedures or equipment, or reviews of tests and experiments pursuant to 10 CFR 50.59,10 CFR 50.82 and 72.48.

i.

Records of meetings of the SRC, and reviews performed by the RSRC, according to Appendices B and C.

j.

Records of monthly facility radiation and contamination surveys.

k.

Records for environmental qualifications which are covered under the provisions of 10 CFR 50.49.

I.

Records of training and qualifications for members of the plant staff.

m.

Records of reactor tests and experiments.

n.

Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

E4.

The following records shall be retained as long as the associated material is stored and for a period of five years after the material is transferred out of the ISFSI:

a.

Records of receipt, inventory (including location), disposal, acquisition, and transfer of all spent fuel and high level waste in storage.

E5.

The following records shall be retained until the NRC terminates the 10 CFR Part 72 General License for the ISFSI:

a.

Records of the current inventory of all spent fuel and high-level waste.

b.

Current material control and accounting procedures.

c.

ISFSI and Cask Storage System records pertaining to the design, fabrication, erection, testing, maintenance, and use of structures systems and components important to safety.

E6.

The following records shall be retained and forwarded to the appropriate NRC Regional Office prior to the ISFSI General License termination:

a.

Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment or site. These records may be limited to instances when contamination remains after any clean-up procedures or when there is a reasonable likelihood that contaminants may have spread to inaccessible areas as in the case of possible seepage into porous materials such as concrete. The records must Page 88 Rev 20 Date: 5/15/01

QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS PART 1 - BIG ROCK POINT NUCLEAR PLANT include any known information on identification of involved nuclides, quantities, forms, and concentrations.

b.

As-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored, and of locations of possible inaccessible contamination such as buried pipes which may be subject to contamination. If required drawings are referenced, each relevant document need not be indexed individually. If drawings are not available, the licensee shall substitute appropriate records of available information concerning these areas and locations.

c.

A list contained in a single document and updated no less than every 2 years of the following:

(1) All areas designated and formerly designated as restricted areas as defined under 10 CFR 20.1003; and (2) All areas outside of restricted areas that require documentation under 10 CFR 72.30(d)(1).

d. Records of the cost estimate performed for the decommissioning funding plan or of the amount certified for decommissioning, and records of the funding method used for assuring funds if either a funding plan or certification is used.

e. Records of the results of measurements and calculations used to evaluate the release of radioactive effluents to the environment. This includes those records of the results of measurements and calculations used to evaluate the release of radioactive effluents to the environment under the standards for protection against radiation in effect prior to January 1, 1994.

Page 89 Rev 20 Date: 5/15/01

ATTACHMENT VII CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DCKET 50-155 AND 72-043 -LICENSE DPR-5 REVISION 10 TO THE UPDATED FINAL HAZARDS

SUMMARY

REPORT (UFHSR)

Submitted September 17, 2002 Comparison Matrix Quality Program Description for Nuclear Power Plants (Part 1)

Big Rock Point (CPC-2A)

(Revision 19 to Revision 20) 56 pages

CPC-2A COMPARISON MATRIX (PART 1) BIG ROCK POINT (Rev 20)

Item Revision 19 Revision 20 1

Reason for Change Basis for Conclusion 1

CPC-2A cover letter CPC-2A cover letter Consumers Energy Company SUBJECT SUBJECT cohtracted responsibility for This is not a reduction in opbration of the Palisades plant to commitment as previous CONSUMERS ENERGY PROGRAM FOR CONSUMERS ENERGY QUALITY PROGRAM Nuclear Management Company commitments for Big Rock Point NUCLEAR POWER PLANTS FOR THE BIG ROCK POINT NUCLEAR (NMC) 5/15/01. This necessitated were maintained in its site PLANT the revision of CPC-2A that applied specific program to Ioth Big Rock Point and Palisades plaints into separate, site-specific programs for each plant.

2 1

CPC-2A cover letter CPC-2A cover letter Thý Quality Program for Palisades This is not a reduction In Paragraph 1, 1st sentence Paragraph 1, 16 sentence and Big Rock Point was separated commitment as previous int6 site-specific programs for each commitments for Big Rock Point Consumers Energy Quality Program Added' (Part 1) - Big Rock Point Nuclear plant. The wording for the Big Rock were maintained in Its site Description for Nuclear Power Plants.

Plant*

PoRnt program was revised to reflect specific program the' current decommissioning Paragraph 1, 3d sentence Paragraph 1, 3d sentence activities and the construction and operation of the ISFSI.

The Quality Program Description for The Quality Program Description outlines the Nuclear Power Plants outlines the actions actions that are implemented for important that are implemented for important activities affecting decommissioning of the Big activities including fueling, testing, Rock Point Nuclear Plant and the construction operation, refueling procurement, and operation of the Independent Spent Fuel maintenance, repair, modification design Storage Installation.

and construction, and decommissioning of the nuclear power plants.

3 CPC-2A cover letter CPC-2A cover letter Reflects the organization of the This is not a reduction in Paragraph 2, 2 nd sentence Paragraph 2, 2nd sentence Corisumers Energy Company.

commitment per 10 CFR 50.54(a)(3)(iii).

I have delegated selected portions of the I have delegated selected portions of the Quality Quality Program to the Vice President, Program to the Senior Vice President, Electric Electric Transmission and Distribution; Vice Transmission and Distribution; and through a President, Information Technology and Senior Vice President of CMS Energy to the Operations services Division; and through Vice President and Secretary.

a Vice Chairman of Consumers Energy to the Vice President and Secretary.

Page 1 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion CPC-2A cover letter Signature David W. Joos President and Chief Executive Officer I

t CPC-2A Page 2ii QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS APPROVED BY Senior Vice President, Nuclear, Fossil, and Hydro Operations Robert A. French Vice President, Electric Transmission and Distribution Carl L. English Vice President, Information Technology and Operations Services Kenneth C. Emery Vice President and Secretary Thomas A. McNish Table of Contents Page iii & iv Page Numbers as is for sections 1.0 - 18.0 plus Appendices and Figures CPC-2A cover letter Signature David W. Joos President and Chief Executive Officer 5/15101 Date CPC-2A Page 2 QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS (PARTI) - BIG ROCK POINT APPROVED BY Robert A. Fenech Senior Vice President, Nuclear, Fossil, and Hydro Operations John G. Russell Senior Vice President, Electric Transmission and Distribution Thomas A. McNish Vice President and Secretary Table of Contents Page 3 & 4 Change in Page Numbers for sections 1.0 18.0 plus Appendices and Figures r4 Editorial page numbering Added date.

The Quality Program for Palisades and Big Rock Point were separated intolsite-specific programs.

Reflects the organization of the Consumers Energy Company.

Editorial.

I

.1 __________________________________________

Page 2 of 56 Previous commitments were maintained for each site in their own site-specific program.

This is not a reduction in commitment per 10 CFR 50.54(a)(3)(iii).

5 6

-t IJ I

I Editorial.

Page 3 of 56 Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 7

1.1 (Page 1) 1.1 (Page 5)

Reflects the application of part I of Previous commitments for Big Paragraph 1, 1st sentence REQUIREMENTS CPC-2A to Big Rock Point and Rock Point were maintained.

Paragraph 1, Is1 sentence specifically include the Big Rock Consumers Energy is responsible for... for Independent Spent Fuel Storage its nuclear power Plants.

Consumers Energy is responsible for... for the Installation (ISFSI).

Big Rock Point Nuclear Plant and its Independent Spent Fuel Storage Installation (ISFSI).

1.1 (Page 1) 1.1 (Page 5)

Effective 7/1/01 various Consumers The affected quality functions REQUIREMENTS REQUIREMENTS Energy employees with responsibility continue to be performed Paragraph 1, 2nd sentence Paragraph 1, 2nd sentence for executing quality functions were qualified personnel, and transferred to NMC. Consumers Consumers Energy continues to Consumers Energy will be delegating the Energy contracted NMC to provide retain responsibility for these

... such as contractors and consultants, authority for development and maintenance of service to perform quality functions quality functions. This is not a Consumers Energy....

the Quality Program Description (QPD) and to support Big Rock Point.

reduction in commitment.

execution of certain quality assurance functions to the Nuclear Management Company (NMC).

Until July 1, 2001, these activities will be performed by Consumers Energy personnel.

From that time, these activities will be performed by a combination of NMC and Consumers Energy personnel. This is discussed below within the QPD. Although authority for development and execution of some parts of the program is delegated to others, such as contractors and consultants, Consumers Energy retains overall responsibility.

Page 4 of 56 Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 9

1.1 (Page 1) 1.1 (Page 5)

Reflects the application of part I of Previous commitments for Big REQUIREMENTS REQUIREMENTS CPC-2A to Big Rock Point and Rock Point were maintained.

Paragraph 2 Paragraph 2 specifically includes activities related The affected quality functions to the Big Rock Independent Spent continue to be performed by This section of the Quality Program This section of the (QPD) identifies the Fuel Storage Installation (ISFSI).

qualified personnel, and Description (QPD) identifies the Consumers Consumers Energy and NMC organizations Effective 7/1/01 various Consumers Consumers Energy continues to Energy organizations responsible for responsible for activities affecting the quality of Energy employees with responsibility retain responsibility for these activities affecting the quality of nuclear BRP/ISFSI structures, systems and components for executing quality functions were quality functions.

power plant structures, systems and and describes the authority and duties assigned transferred to NMC.

components describes the authority and to them. It addresses responsibilities for duties assigned to them. It addresses attaining quality objectives; for establishing and Includes editorial changes:

Editorial.

responsibilities for attaining quality objec-maintaining the QPD; and for assessing the

- Abbreviated "Quality Program" tives; for establishing and maintaining the performance of activities affecting quality. The with acronym "QPD".

Quality Program; and for assessing the maintenance and control of this QPD is the

- Added "maintenance" and performance of activities affecting quality, responsibility of the Manager, Nuclear abbreviated "Quality Program The control of this Quality Program Performance Assessment Department (NPAD).

Description" with acronym "QPD*,

Description is the responsibility of the assigned responsibility within Nuclear Performance Assessment NPAD to the Manager-NPAD.

Department.

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 10 1.1 (Page 1) 1.1 (Page 5)

Reflects the reassignment of The affected quality functions REQUIREMENTS REQUIREMENTS responsibility for independent safety continue to be performed Paragraph 3 Paragraph 3 reviews from NPAD to a different qualified personnel, and organization (RSRC) (see Item #59)

Consumers Energy continues to Nuclear Performance Assessment NPAD functions (e.g., audits, assessments, and retain responsibility for these Department (NPAD) functions (audits, supplier evaluations) are performed by quality functions. This is not a surveillances, and independent safety personnel within formally designated or-reduction in commitment reviews) are performed by personnel within ganizational units that report to the Manager, formally designated organizational units NPAD or members of other organizations as Includes editorial changes:

Editorial that report to the Manager, Nuclear selected by the Manager, NPAD. The reporting

- Replaced "surveillances" with Performance Assessment or members of level of the NPAD organization affords sufficient "assessments" and added other organizations as selected by the authority and organizational freedom, including "supplier evaluations".

Manager, Nuclear Performance sufficient independence from the cost and

- Replaced "Nuclear Assessment. The reporting level of the schedule impacts of NPAD organization actions, Performance Assessment Nuclear Performance Assessment organi-to enable people in that organization to identify Department" with acronym zation affords sufficient authority and quality problems; to initiate, recommend, or "NPAD.

organizational freedom, including sufficient provide solutions; and to verify implementation independence from the cost and schedule of solutions.

impacts of Nuclear Performance Assessment organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementa tion of solutions 11 1.2.1 (Page 1) 1.2.1 (Page 5 & 6)

Source of Authority Source of Authority Reflects the application of part 1 of The assignment of new The President and Chief Executive Officer-The President and Chief Executive Officer, CPC-2A to Big Rock Point and responsibility for ISFSI Electric (see Figure 1, Company Electric (see Figure 1, Company Organization specifically includes activities related construction and operation is not Organization Chart) of Consumers Energy Chart) of Consumers Energy is responsible for to the Big Rock Independent Spent a reduction in commitment.

is responsible for safe operation and safe operation and decommissioning of the Big Fuel Storage Installation (ISFSI).

decommissioning of Consumers Energy Rock Point Plant and, safe storage of spent fuel nuclear power plants. Authority and at the ISFSI. Authority and responsibility for responsibility for establishing and establishing and implemernting the Quality implementing the Quality Program for plant Program for decommissioning is delegated to operations, maintenance, modifications and the Senior Vice President - Nuclear, Fossil, and decommissioning is delegated to the Senior Hydro Operations (NFHO)

Vice President-Nuclear, Fossil, and Hydro Operations.

Page 5 of 56

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 12 1.2.2 (Page 2) 1.2.2 (Page 6)

Responsibility for Attaining Quality Responsibility for Attaining Quality Oblectives at The Quality Program for Palisades Deletion of Palisades Objectives at the Nuclear Plants the Nuclear Plants and Big Rock Point was separated information has no impact on 1ST Paragraph into site-specific programs for each Big Rock Point's commitments.

plant. The wording for the Big Rock The Senior Vice President - Nuclear, The Senior Vice President, NFHO is responsible Point program was revised to reflect Fossil, and Hydro Operations (NFHO) is to the President and Chief Executive Office, the current decommissioning responsible to the President and Chief Electric for decommissioning of BRP and activities and the construction and Executive Officer-Electric for operation, construction and operation of the ISFSI.

operation of the ISFSI.

maintenance, and decommissioning of Managers who report to the Senior Vice The addition of new information Consumers Energy nuclear power plants.

President, NFHO, are responsible for directing and commitments is not a Managers who report to the Vice President, the performance of activities that affect safe reduction in commitment.

NFHO are responsible for directing the plant decommissioning and/or safety-related performance of activities that affect safe functions of structures, systems and plant operation or decommissioning and/or components of the plant and ISFSI in safety-related functions of structures, accordance with Quality Program requirements.

systems and components of the nuclear power plants in accordance with Quality Program requirements 13 Page 6 1.2.2a (Page 2, 3, & 4)

Responsibility for Attaining Quality Obiectives at This section was limited to a Deletion of Palisades' Responsibility for Attaining Quality the Nuclear Plants-description of the Palisades Site Vice information has no impact on Obiectives at the Nuclear Plants President's responsibilities and did Big Rock Point's commitments.

Section 1.2 2a -deleted in its entirety.

not affect Big Rock Point.

1.2.2a The Palisades Plant Site Vice President (see Figure 1) is responsible for 14 1.2.2b (Page 4) 1.2.2 (Page 6)

Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 1, 1st sentence Paragraph 2, 1"t sentence The Big Rock Point Site General Manager The BRP Site General Manager (see Figure 1)

Adds responsibility for construction The assignment of new (see Figure 1) is responsible to the Senior is responsible to the Senior Vice President and operation of the ISFSI.

responsibility for ISFSI Vice President NFHO for operation, NFHO for operation, maintenance, and construction and operation is not maintenance, and decommissioning of the decommissioning of BRP and construction and a reduction in commitment.

nuclear power plant in such a manner as to operation of the ISFSI in such manner as to achieve compliance with Plant licenses, achieve compliance with licenses, applicable applicable regulations and the Quality regulations and the Quality Program.

Program.

Page 6 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 15 1.2.2b (Page 4) 1.2.2 (Page 6)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives at Obiectives at the Nuclear Plants the Nuclear Plants Added "/ISFSI" to reflect the current The assignment of new Paragraphs 2, 3, & 4 Paragraphs 3, 4, & 5 and future status of Big Rock Point.

responsibility for ISFSI construction and operation is not Qualification of appropriate Qualification of appropriate a reduction in commitment.

decommissioning personnel, including decommissioninglISFSI personnel, including certification of inspection personnel.

certification of inspection personnel.

Preparation, review and approval of plant Preparation, review and approval of plant/lSFSI procedures and instructions, procedures and instructions.

Functioning as the plant design and Functioning as the plantISFSI design and configuration control authority for configuration control authority for compliance of compliance of plant modifications and plant/ISFSl modifications and design changes design changes to existing plant design to existing plant/lSFSI deslign criteria.

criteria.

16 1.2.2b (Page 4) 1.2.2 (Page 6)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 7 Paragraphs 8 & 9 Maintaining Echelon III calibration facilities Maintaining Echelon III calibration facilities for Separated different functions into Editorial.

for Portable and Laboratory Measuring and Portable and Laboratory Measuring and Test separate paragraphs.

Test Equipment (PL-M&TE) and Health Equipment (PL-M&TE) and Health Physics PL Physics PL-M&TE (HPPL-M&TE).

M&TE (HPPL-M&TE)

The assignment of new Calibration/maintenance of installed plant responsibility for ISFSI instrumentation.

Calibration/maintenance of installed plant/lSFSI construction and operation is not instrumentation.

Added "/ISFSI to reflect the current a reduction in commitment.

and future status of Big Rock Point.

17 1.2.2b (Page 5) 1.2.2 (Page 7)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 15 Paragraph 16 Added "/ISFSI" to reflect the current The assignment of new Plant site inspection program, including Plant site/ISFSI inspection program, including and future status of Big Rock Point.

responsibility for ISFSI inspection of maintenance, testing and fuel inspection of maintenance, testing and fuel construction and operation is not

handling, handling a reduction in commitment Page 7 of 56

Item Revision 19 Revision 20 Reason for Chanqe Basis for Conclusion 18 I

1.2.2b (Page 5) 1.2.2 (Page 7)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 16 Paragraph 17 Preparation, review, and approval of means Preparation, review, and approval of means that Added "/ISFSI" to reflect the current The assignment of new that identify plant structures, systems and identify plantJISFSI structures, systems and and future status of Big Rock Point.

responsibility for ISFSI components, and activities to which this components, and activities to which QPD apply, construction and operation is not QPD apply, as described in Section 2.0, as described in Section 2.0, depending on plant a reduction in commitment.

depending on plant conditions during conditions during dismantlement.

dismantlement.

19 1.2.2b (Page 5) 1.2.2 (Page 7)

Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 19 Paragraph 20 Establishing, implementing and Establishing, implementing and documenting Added "/ISFSI to reflect the current The assignment of new documenting the appropriate training of the appropriate training of and future status of Big Rock Point.

responsibility for ISFSI decommissioning personnel, including decommissioning/lSFSI personnel, including construction and operation is not Quality Program indoctrination and training Quality Program indoctrination and training, a reduction in commitment.

20 1.2.2b (Page 5) 1.2.2 (Page 7)

Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives at Obiectives at the Nuclear Plants the Nuclear Plants Paragraph 20- 1s sentence Paragraph 21-l sentence Replace specific department title Editorial.

Procurement, including preparation,... to Procurement, including preparation,... to the with functional description.

Purchasing purchasing organization.

Page 8 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 21 1.2.2b (Page 5) 1.2.2 (Page 7)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives at Objectives at the Nuclear Plants the Nuclear Plants Paragraph 22 Paragraph 23 Accomplishing plant licensing activities Accomplishing plant/ISFSI licensing activities Added "/ISFSI" to reflect the current The assignment of new including maintaining licensing documents including maintaining licensing documents up-and future status of Big Rock Point.

responsibility for ISFSI up-to-date, interfacing with the NRC, to-date, interfacing with the NRC, accomplishing construction and operation is not accomplishing and/or tracking licensing and/or tracking licensing commitments and a reduction in commitment.

commitments and coordinating internal coordinating internal action on NRC bulletins, action on NRC bulletins, generic letters, etc.

generic letters, etc.

22

,I 1.2.2b (Page 5) 1.2.2 (page 8)

Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives at Objectives at the Nuclear Plants the Nuclear Plants

,It Paragraph 25 Paragraph 26 I

Added "IISFSI" to reflect the current The assignment of new and future status of Big Rock Point.

responsibility for ISFSI Performing the engineering, construction, Performing the engineering, construction, construction and operation is not inspection and testing associated with plant inspection and testing associated with a reduction in commitment.

modification projects as assigned plant/ISFSI modification projects as assigned.

23 1.2.2b (Page 6) 1.2.2 (Page 8)

Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives at Objectives at the Nuclear Plants the Nuclear Plants Paragraph 27 Paragraph 28 The reference to 'Plant Review Deletion of Palisades Committee" was information related information has no impact on Performing reviews to advise the Site Performing reviews to advise the Site General to Palisades only and was removed Big Rock Point's commitments General Manager on matters related to Manager on matters related to nuclear safety, from the Big Rock Point specific nuclear safety, as specified in Appendix B, as specified in Appendix B, Safety Review program.

Plant Review Committee/Safety Review Committee Committee.

24 1.2.3 (Page 6) 1.2.3 (Page 8)

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance Substituted acronym "NPAD" in lieu Editorial.

Assessment Department Assessment Department of organizational name.

Paragraph 1 Paragraph I Added "directly" to reflect the new organizational reporting relationship The Manager, Nuclear Performance The Manager, NPAD, (see Figure 1) is directly for the lead BRP NPAD Assessment Department, (see Figure 1) is responsible to the Senior Vice President, NFHO, representative responsible to the Senior Vice President, for:

INFHO, forI Page 9 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 25 1.2.3 (Page 6) 1.2.3 (Page 8)

Reflects a reassignment of As described in Appendix C, the Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance responsibility for independent review standing committee meets ANSI Assessment Department Assessment Department activities from an organizational unit N18.7 requirements as endorsed Paragraph 3 (NPAD) to a standing committee by Regulatory Guide 1.33 Paragraph 3 was deleted in its entirety.

(RSRC)

This is not a reduction in Performance of the offsite safety review Appendix C continues to describe commitment per functions for the nuclear power plants as responsibilities, qualification requires, and 10 CFR 50.54(a)(3)(vi) described in Appendix C, Independent reporting relationship for the independent safety Safety Review.

review function.

26 1.2 3 (Page 6) 1.2.3 (Page 8)

Reflects a name change (the word Editorial.

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance "Nuclear' deleted) for the Approved Assessment Department Assessment Department Suppliers List.

Paragraph 4 Paragraph 3 Supplier surveys and evaluation including Supplier surveys and evaluation including reviewlapproval of supplier QA programs, reviewlapproval of supplier QA programs, and and maintenance of the Nuclear Approved maintenance of the Approved Suppliers List.

Suppliers List.

27 As described in Appendix C, the 1.2.3 (Page 6) 1.2.3 (Page 8)

Reflects a reassignment of standing committee meets ANSI Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance responsibility for the nuclear safety N18.7 requirements as endorsed Assessment Department Assessment Department assessment from an organizational by Regulatory Guide 1.33.

Paragraph 6 unit (NPAD) to a standing committee This is not a reduction in Paragraph 6 was deleted in its entirety.

(RSRC).

commitment per Assessment of nuclear safety performance Appendix C continues to describe performance 10 CFR 50.54(a)(3)(vi)

Ias described in Appendix C.

of the nuclear safety assessment 28 1.2.3 (Page 6) 1.2.3 (Page 8)

Information related to Palisades only Deletion of Palisades Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance was removed from the Big Rock information has no impact on Assessment Department Assessment Department Paragraph 6 Point specific program:

Big Rock Point's commitments.

Paragraph 8

-Removed 'the Site Vice Recommending to the Senior Vice President, President or'.

Recommending to the Site Vice President NFHO that decommissioning activities including

- Removed 'plant be shutdown'.

or the Senior Vice President NWHO that a spent fuel transfer activities be stopped if such Added, 'decommissioning activities The addition of new information plant be shut down if such action appears action appears necessary.

including spent fuel transfer activities and commitments is not a necessary.

be stopped" to reflect the current and reduction in commitment future status of Big Rock Pont.

Page 10 of 56

Page 11 of 56 Item Revision 19 Revision 20 Reason forCChan~qe Basis for Conclusion 29 1 1 1.2.3 (Page 6) 1.2.3 (Page 8)

Replaced "plant sites" with "site" to Editorial.

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance reflect that program no longer is Assessment Department Assessment Department Paragraph 7 applicable to Palisades.

Paragraph 9 Assessment programs (site and Corporate Assessment programs (plant sites and Office), including follow-up on corrective actions Corporate Office), including follow-up on for audit findings.

corrective action for audit findings.

30 1.2.3 (Page 6) 1.2.3 (Page 8)

Replaced "nuclear plant activities" Editorial.

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance with "BRPIISFSI activities" to reflect Assessment Department Assessment Department that program no longer is applicable Paragraph 10 Paragraph 8 to Palisades.

Review of performance trends associated Review of performance trends associated with with nuclear plant activities including BRP/ISFSI activities including corrective corrective actions.

actions.

31 1.2.3 (Page 6) 1.2.3 (Page 8)

Added "Part 1 - Big Rock Point Editorial.

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance Nuclear Plant" to reflect that program Assessment Department Assessment Department, no longer is applicable to Palisades.

Paragraph 12 Paragraph 10 Maintenance of the Quality Program Maintenance of the Quality Program Description Description for Nuclear Power Plants for Nuclear Power Plants Part I - Big Rock IPointNuclearPlant.

4. "

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 32 1.2.3 (Page 6) 1.2.3 (Page 9)

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance Replaced "In order to implement Editorial.

Assessment Department Assessment Department these responsibilities" with "In Paragraph 14 Paragraph 12 fulfilling the above responsibilities".

In order to implement these responsibilities, In fulfilling the above responsibilities, the Added provision to "use a The affected quality functions the Manager, NPAD, is provided with "Stop Manager, NPAD may use a combination of combination of Consumers and NMC continue to be performed Work" authority whereby he can suspend Consumers and NMC employees. The employees" to permit continued qualified personnel, and any quality related activity or process which Manager, NPAD, is provided with "Stop Work" execution of responsibilities by the Consumers Energy continues to may, in his opinion, adversely affect public authority whereby he can suspend any quality same personnel.

retain responsibility for these safety or the safe operation of Consumers related activity or process which may, in his quality functions. This is not a Energy nuclear plants. A Stop Work order opinion, adversely affect public safety, the safe Replaced "safe operation of reduction in commitment.

that would result in plant shutdown is given decommissioning of BRP, or safe fuel storage Consumers Energy nuclear plants" as a recommendation - NRC licensed operations. A Stop Work Order that would with "the safe decommissioning of Deletion of function applicable operating staff are responsible for result in the suspensiopof in-process spent fuel BRP, or safe fuel storage only to Palisades has no impact determining and carrying out the safest transfer operations is given as a operations", and "plant shutdown" on Big Rock Point's course of actions.

recommendation - the certified fuel handlers with "suspension of in-process spent commitments.

are responsible for determining and carrying out fuel transfer operations" to reflect the the safest course of actions.

activities occurring at BRP.

33

'1 1.2.3 (Page 6 & 7) 1.2.3 (Page 9) il I Abbreviated "Nuclear Performance Editorial.

Responsibilities of the Nuclear Performance Responsibilities of the Nuclear Performance Assessment Department" as Assessment Department Assessment Department "NPAD*.

Paragraph 15 Paragraph 13 The Manager, Nuclear Performance The Manager, NPAD has no other primary Assessment has no other primary duties...

duties...

34 1.2.4 (Page 7) 1.2.4 (Page 9)

Replaced "heat treating" with "heat-Editorial.

Responsibilities of the Equipment Services Responsibilities of the Equipment Services treating',

Department Department I I Paragraph 1 Paragraph 1 Added "and qualifying welders".

The addition of new information and commitments is not a The Manager, Equipment Services provides The Manager, Equipment Services provides reduction in commitment.

electrical, rotating and stationary equipment electrical, rotating and stationary equipment expertise, including developing and expertise, including developing and qualifying qualifying procedures for welding and heat procedures for welding and heat-treating and Itreating.

qualifying welders.

Page 12 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 35

,'lI "

1.2.5 (Page 7) 1.2.5-7 (Pages 9 & 10)

Some of the responsibilities were This is not a reduction in Responsibilities for Attaining Quality reassigned to different organizational commitment per Obiectives Outside Nuclear, Fossil, and 1.2.5 retained in CPC-2A (Part 1) as paragraphs units, and the names or reporting 10 CFR 50.54(a)(3)(vi).

Hydro Operations 1.2.5, 1.2.6 and 1.2.7. (See change items 36-relationships for some organization 41 below),

units were changed.

All Paragraphs All elements defined in section 1.2.5 of CPC-2A rev 19 still exist within sections 1.2.5. 1.2 6, or 1.2.7 CPC 2A (Part 1) Rev. 20 36 1.2.5 a. (Page 7) 1.2.7 a (Page 10)

Title change for Senior VP, Electric This is not a reduction in Transmission and Distribution.

commitment per The Manager, Electric System Operations The Manager, Electric System Operations (see 10 CFR 50.54(a)(3)(vi).

(see Figure 1) is responsible through the Figure 1) is responsible'through the Senior Vice Reassigned Manager, Electric Vice President, Electric Transmission and President, Electric Transmission and Services responsibilities (from Rev Distribution... and associated settings.

Distribution... and associated settings. He is 19 section 1.2.5 e.) to Manager also responsible for testing and maintaining Electric, System Operations.

electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associate settings.

1.2.5b (Page 7) 1.2.5 (Page 9)

The responsibility for maintaining the This is not a reduction in Responsibility for Attaining Quality Responsibilities of the Plant Operations corporate Records Management commitment per Obiectives Outside Nuclear, Fossil, and Department System was reassigned.

10 CFR 50.54(a)(3)(vi).

Hydro Operations The Director, Plant Operations is responsible for Editorial changes:

Editorial.

The Executive Manager, Fuels & Power maintaining the Records Management System

- Added "ISFSI*.

Transactions is responsible to the Vice including required retention, protection and

- Deleted "(Big Rock only)"

President and Chief Executive Officer -

retrievability. This includes collecting, storing, Replaced "Big Rock Point" Electric for maintaining the Records and maintaining, distributing and controlling with "BRP Site General Management System including required plantISFSI engineering design documents.

Manager' retention, protection and retrievability. This This excludes Big Rock Safeguards...

were made to reflect the activities includes collecting, storing, maintaining, responsibility of the BR 6. Site General Manager.

occurring at BRP, and delete distributing and controlling plant unneeded wording as CPC-2A (Part engineering/design documents (Big Rock

1) is already limited to Big Rock.

only)

This excludes Big Rock Safeguards I_... responsibility of Big Rock Point.

Page 13 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 38 1.2.5c (Page 7) 1.2.7b (Page 10)

Added 'ISFSI" to reflect the activities The addition of new information Responsibility for Attaining Quality Responsibility for Attaining Quality Obiectives occurring at BRP.

and commitments is not a Obiectives Outside Nuclear, Fossil, and Outside Nuclear, Fossil, and Hydro Operations reduction in commitment.

Hydro Operations The Corporate Records Administrator (see The Corporate Records Administrator (see Figure 1) is responsible through the Vice Figure 1) is responsible through the Vice President and Secretary for microfilming of President and Secretary for microfilming of specified quality records and plant/ISFSI specified quality records and plant engineering/design documents.

engineering/design documents.

39 1.2.5d (Page 7) 1.2.6 (Page 9)

'1 Responsibility for Attaining Quality Responsibilities of the Environmental and Obiectives Outside Nuclear, Fossil, and Laboratory Services Department Hydro Operations The Manager, Environmental and Technical The Manager, Environmental and Laboratory Editorial - Consumers Energy Editorial.

Services (E&TS) is responsible, through the (E&LS) is responsible for:

Company organization title changes Vice President, Information Technology and Operations Services for:

Maintaining the Company's Echelon II Maintaining the Company's Echelon II calibration facility for calibrating reference calibration facility for calibrating reference and and secondary standards and general secondary standards and general usage usage portable and laboratory measuring portable and laboratory measuring and test and test equipment.

equipment.

)If, Controlling the calibration recall system for Controlling the calibration recall system for Editorial - Consumers Energy Editorial.

Portable and Laboratory M&TE owned by Portable and Laboratory M&TE owned by E&LS, Company organization title changes E&TS, and other departments, as and other departmentý, as requested.

requested.

Maintaining a Master PL-M&TE List for Maintaining a Master PL-M&TE List for E&LS Editorial - Consumers Energy Editorial.

E&TS PL-M&TE and for other departments, PL-M&TE and for oth~qý departments, as Company organization title changes as requested.

requested.

I Providing a PL-M&TE Inventory List for Providing a PL-M&TE Inventory List for Added "ISFSI" to reflect the activities The addition of new Information Nuclear plants.

BRP/ISFSI occurring at BRP.

and commitments is not a reduction in commitment.

Page 14 of 56

Page 15 of 56 Item Revision 19 Revision 20 Reason for Changie Basis for Conclusion 39 (cont)

Providing chemistry support to Nuclear Providing chemistry support to BRPIISFSI, as Added "ISFSI" to reflect the activities The addition of new information plants, as requested.

requested.

occurring at BRP.

and commitments is not a reduction in commitment.

Preparing, reviewing, approving and Preparing, reviewing, approving and obtaining obtaining additional reviews and approvals additional reviews and approvals if required, of if required, of purchase requests for purchase requests for services, equipment and services, equipment and consumables, and consumables, and submitting such requests to submitting such requests to purchasing for purchasing for procurement action procurement action.

Conducting performance tests on materials, Conducting performance tests on materials, equipment and systems when requested.

equipment and systems when requested I1 Performing nondestructive examination, Performing nondestructive examination, and and controlling/maintaining NDE controlling/maintaining NDE equipment.

equipment.

Providing qualified NDE procedures and Providing qualified NDE procedures and equipment and NDE personnel equipment and NDE personnel.[I Providing chemical and metallurgical analytical Providing chemical and metallurgical services.

analytical services.

Providing necessary corrective action Providing necessary corrective action processing and status reporting for assigned processing and status reporting for corrective action documents assigned corrective action documents

_I__

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 40 1.2.5e (Page 8) 1.2.7a (Pagel10)

Ire Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives Reassigned certain responsibilities This is not a reduction in Obiectives Outside Nuclear, Fossil, and Outside Nuclear, Fossil, and Hydro Operations from the Manager, Electric Services commitment per Hydro Operations Paragraph 1, 2"0 sentence to the Manager Electric, System 10 CFR 50.54(a)(3)(vi).

Paragraph 1, 1 sentence I

Operations.

He is also responsible for testing and The Manager, Electric Services is maintaining electrical protective devices, responsible, though the Vice President, performing design verification testing associated Electric Transmission and Distribution to with electrical protective schemes, devices and the Executive Vice President and Chief application of associate settings.

Execute Officer - Electric for testing and maintaining electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associate settings.

41 1.2.5e (Page 8) 1.2.7c (Page 10)

Responsibility for Attaining Quality Responsibility for Attaining Quality Objectives Some of the responsibilities were This is not a reduction in Obiectives Outside Nuclear, Fossil, and Outside Nuclear, Fossil, and Hydro Operations reassigned to different organizational commitment per Hydro Operations units, and the names or reporting 10 CFR 50.54(a)(3)(vi)

Paragraph 1, 2nd sentence The Manager, Production Support (see Figure relationships for some organization

1) is responsible, through the Senior Vice units were changed.

The Manager Electric Services is also President, Electric Transmission and responsible for operating the Skill Centers Distribution to the President and Chief Executive including the training, and qualifying of Officer - Electric for operating the Skill Centers personnel and equipment for welding including the training, and testing of personnel operations, and equipment for welding operations.

42 Figure 1 (Page 9)

Figure 1 (Page 11)

Revised to organization after transfer Deletion of Palisades Consumers Energy Organizational Chart Consumers Energy Company Organizational of Palisades operating license to information has no impact on Chart NMC.

Big Rock Point's commitments.

This is not a reduction in commitment.

Page 16 of 56 I ý

I, Page 17 of 56 Item Revision 19 Revision 20 Reason for Changqe Basis for Conclusion 43 2.1 (Page 10) 2.1 (Page 12)

REQUIREMENTS REQUIREMENTS Provide for operation of the ISFSI Previous commitments for Big Paragraph 1 Paragraph 1 and reflect that this part of the QPD Rock Point were maintained.

is limited to Big Rock Point.

The assignment of new Policies that define and establish the Policies that define arnd establish the responsibility for ISFSI Consumers Energy Quality Program for Consumers Energy Quality Program for Nuclear construction and operation is not Nuclear Power Plants are stated in the Power Plants (Part 1) - Big Rock Point Nuclear a reduction in commitment.

individual sections of this document. The Plant are stated in the individual sections of this program is implemented through document.

procedures and instructions responsive to The program is implemented through provisions of the Quality Program procedures and instructions responsive to Description and will be carried out for the provisions of the QPD and will be carried out for life of each plant. Plant life is defined as the life of BRP and its associated ISFSI.

the period covered by a valid license under Plant/ISFSI life is defined as the period covered 10 CFR 50.

by a valid license under 10 CFR 50 or IOCFR 72, respectively.

44 2.1 (Page 10) 2.1 (Page 12)

REQUIREMENTS REQUIREMENTS Added 10CFR 72 to provide for The assignment of new Paragraph 3, 1 st sentence Paragraph 3, 1st sentence, operation of the ISFSI at Big Rock responsibility for ISFSI Point.

construction and operation is not Quality Program status, scope, adequacy Quality Program status, scope, adequacy and a reduction in commitment.

and compliance with 10 CFR 50, Appendix compliance with 10 CFR 50, Appendix B and B are regularly reviewed by Consumers 10CFR 72 are regularly reviewed by Consumers Energy Management through reports, Energy Management through reports, meetings meetings and review of audit results.

and review of audit results.

I I_________________

Page 18 of 56 Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 45 2.2.1 (Page 10) 2.2.1 (Page 12)

Paragraph 1, 1st sentence Paragraph 1, 1st sentence The President and Chief Executive Officer -

The President and Chief Executive Officer, Information related to Palisades was Previous commitments for Big Electric, has stated in a formal Electric, has stated in a formal STATEMENT removed from the Big Rock Point Rock Point were maintained.

STATEMENT OF RESPONSIBILITY AND OF RESPONSIBILITY AND AUTHORITY, Specific Program and Big Rock Point The assignment of new AUTHORITY, signed by him, that it is signed by him, that it is corporate policy to activities related to the construction responsibility for ISFSI corporate policy to comply with the comply with the provisions of applicable and operation of the Independent construction and operation is not provisions of applicable legislation and legislation and regulations pertaining to quality Spent Fuel Storage Installation a reduction in commitment.

regulations pertaining to quality assurance assurance for BRP/ISFSI as defined by 10 CFR (ISFSI) were added.

for nuclear power plants as defined by 10 50, Appendix B and 10 CFR 72, Subpart G.

CFR 50, Appendix B. The statement The statement makes this QPD and the makes this Quality Program Description associated implementing procedures and and the associated implementing instructions mandatory and requires compliance procedures and instructions mandatory and by all responsible organizations and individuals.

requires compliance by all responsible organizations and individuals.

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 2.2.3 (Pages 10 & 11)

The affectivity and applicability of this Quality Program Description are as follows:

a.

For Big Rock Point and Palisades, the Quality Program Description became effective on April 1, 1982, with full implementation on January 1, 1983

b.

The Quality Program described in this Quality Program Description is intended to apply for the life of Consumers Energy's nuclear power plants.

c.

The Quality Program applies to activities affecting the quality of structures, systems, components and related consumables during plant operation, maintenance, testing, modifications, and decommissioning Structures, systems, components and related consumables to which this program applies are identified in accordance with the criteria of Regulatory Guide 1.29, as clarified by Items No. 21a and No. 21b in Part2 of Appendix A to this Quality Program Description, and as described below.

46 Information related to Palisades was removed from the Big Rock Point Specific Program and Big Rock Point activities related to the construction and operation of the Independent Spent Fuel Storage Installation (ISFSI) were added.

Previous commitments for Big Rock Point were maintained.

The assignment of new responsibility for ISFSI construction and operation is not a reduction in commitment.

Page 19 of 56 2.2.3 (Page 13)

The effectivity and applicability of this QPD are as follows:

a.

For Big Rock Point, the QPD became effective on April 1, 1982, with full implementation on January 1, 1983.

b.

For the ISFSI, in accordance with 10 CFR 72.4, the NRC Spent Fuel Project Office was notified by letter dated February 17, 2000 of Consumers Energy's intent t6 apply this Quality program to the ISFSI and spent fuel storage cask activities as required by 10 CFR Part 7?.140.

c.

The Quality Program described in this Quality Program Description is intended to apply for the life of BRP and its associated ISFSI.

d.

The Quality Program applies to activities affecting the quality of structures, systems, components and related consumables at BRP/ISFSI.

Structures, systems, components and related consu~nables to which this program applies are identified in accordance with the criteria of Regulatory Guide 1.29, as clarified by Items No. 21a and No. 21b in Part 2 of Appendix A to this QPD, and as described below.

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 2.2.4 (Page 11) 47 2.2.4 (Page 14)

This Quality Program Description, organized to present the Consumers Energy Quality Program for Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states Consumes Energy requirements for each of the criteria and describes how the controls pertinent to each are carried out.

Any changes made to this Quality Program Description that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually as specified by 10 CFR 50.71.e.

Any changes made to this Quality Program Description that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation in accordance with the requirements of 10 CFR 50.54.

Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits.

The program described in this Quality Program Description will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B.

The Quality Program for Palisades and Big Rock Point were separated into site-specific programs for each plant.

Quality Program Description changed to read QPD.

48 2.2.5 (Page 11) 2.2.5 (Page 13)

Quality Program Description Editorial Paragraph 1 Paragraph 1 changed to read QPD.

Documents used for implementing the Documents used for implementing the provisions of the Quality Program provisions of the QPD include the following:

Description include the following:_I__

Page 20 of 56 This QPD, organized,ýo present the Consumers Energy Quality Program for the Nuclear Plants (Part 1) in the order of the 18 criteria of 10 CFR 50, Appendix B, states Consumers Energy requirements for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this QPD that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually as specified by 10 CFR 50.71.e. Any changes made to this QPD that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation in accordance with the requirements of 10 CFR 50.54.

Appendix A to this QPD lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits.

The program described in this QPD will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B.

Editorial.

Editorial

, I

Item Revision 19 Revision 20 Reason for Changie Basis for Conclusion 49 1.f I 2.2.5c (Page 11) 2.2.5c (Page 13)

Information related to Palisades was The assignment of new Paragraph 1, 1' sentence Paragraph 1, 1't sentence removed from the Big Rock Point responsibility for ISFSI Specific Program and Big Rock Point construction and operation is not Applicable elements of the Quality Program Applicable elements of the Quality Program are activities related to the construction a reduction in commitment are applied to emergency plans, security applied to emergency plans, security plans, and operation of the Independent plans, radiation and fire protection plans for radiation and fire protectipn plans for Spent Fuel Storage Installation Consumers Energy nuclear power plants.

BRP/ISFSI.

(ISFSI) were added.

50 2.2.6 (Page 11) 2.2.6 (Page 14)

Editorial Paragraph 1 Paragraph 1,l1t sentence, Information related to Palisades was

., Iremoved from the Big Rock Point Provisions of the Quality Program for Provisions of the Quality Program Description specific program. Remaining Big Nuclear Power Plants apply to activities for Nuclear Power Plants (Part 1) apply to Rock Point commitments affecting the quality of structures, systems, activities affecting the quality of structures, reorganized.

components and related consumables systems, components and related consumables.

selected according to the criteria of either 2.2.6a or 2.2.6b below.

51 2.2.6a (Page 12)

Palisades responsibilities described in 2.2 6a Information related to Palisades was Deletion of Palisades removed from CPC-2A (Part 1) and relocated in removed from the Big Rock Point information has no impact on 2.2 6a Removed in its entirety CPC-2A (Part 2) specific program.

Big Rock Point's commitments.

This is not a reduction in commitment.

52 2.2.6b (Page 12) 2.2.6 (Page 14)

Information related to Palisades was Previous commitments for Big Paragraphs I Paragraph 1, 2 nd & 3d sentences removed from the Big Rock Point Rock Point were maintained.

specific program. Remaining Big Deletion of Palisades

b. For Big Rock Point, Consumers Energy Consumers Energy uses the following criteria in Rock Point commitments information has no impact on uses the following criteria in the selection of the selection of structures, systems, reorganized.

Big Rock Point's commitments.

structures, systems, components, and components, and activities to which the Quality This is not a reduction in activities to which the Quality Program is Program is applied. Application of the Quality commitment.

applied. Application of the Quality Program Program assures that such structures, systems, assures that such structures, systems, components, and activities are monitored and components, and activities are monitored controlled in a manner sufficient to provide and controlled in a manner sufficient to reasonable assurance that they are capable of provide reasonable assurance that they are fulfilling their intended functions.

capable of fulfilling their intended functions Page 21 of 56

Item Revision 19 Revision 20 Reason for Changle Basis for Conclusion 53 2.2.6 b.(1) (Page 12) 2.2.6a (Page 14)

Paragraph 2 Paragraph 1 (1) The Quality Program shall be applied to

a. The Quality Program shall be applied to Information related to Palisades was Editorial.

structures, systems, components, and structures, systems, components, and removed from the Big Rock Point activities identified according to the activities selected based on engineering specific program. Remaining Big method described in 2.2.6.a (1) above; evaluation that uses the guidance of Rock Point commitments Regulatory Guides 1.26 and 1.29 to reorganized.

determine those items and activities whose function is important to safe plant operation and shutdown These items and activities are commonly referred to as "safety related" (see Appendix A).,__

54 I

2.2.6 b (2) (Page 12) 2.2.6b (Page 14)

Paragraph 3 Paragraph 1 (2) The Quality Program shall be applied to

b. The Quality Program shall be applied to Changed section number from (2) to Editorial.

structures, systems, components, and structures, systems, components, and

b.

activities important to the safe storage, activities important to the safe storage, control and maintenance of spent control and maintenance of spent nuclear nuclear fuel (ISSSF);

fuel (ISSSF);

55 2.2.6(3) (Page 12) 2.2 6c (Page 14)

Paragraph 4 Paragraph 1 (3) The Quality Program shall be applied to

c. The Quality Program shall be applied to Changed section number from (3) to Editorial.

structures, systems, components, and structures, systems, components, and

c.

activities important to the monitoring activities important to the monitoring and and control of radiological hazards control of radiological hazards (IMCRH)

(IMCRH).

56 2.2.6 (Page 12ý 2.2.6 (Page 14L, Paragraph 5, 6 sentence Paragraph 5, 6 sentence Such determinations are based on data in Such determinations are based on data in such Reflects decommissioning and ISFSI The addition of new information such documents as the plant safety documents as the post-shutdown Technical activities at Big Rock Point.

and commitments is not a analysis, post-shutdown Technical Specifications, the Updated Final Hazards reduction in commitment.

Specifications, and the UFHSR.

Summary Report (UFHSR), and the Cask Storage System SAR.

Page 22 of 56

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 57 2.2.8 (Page 13) 2.2.8 (Page 15)

Paragraph 1 Paragraph 1

.1 Reflects removal of information The assignment of new Development, control and use of computer Development, control arnd use of computer related to Palisades and the addition responsibility for ISFSI programs affecting nuclear power plant programs affecting nuclear power plant design of activities related to the construction and operation is not design and operation at Consumers Energy and operation at BRPI/ISFPI are subject to construction and operation of the a reduction in commitment.

are subject to Quality Program design Quality Program design controls (see Section Independent Spent Fuel Storage controls (see Section 3.0, DESIGN 3 0, DESIGN CONTROL),

Installation (ISFSI) at Big Rock CONTROL)

Point.

58 2.2.9 (Page 13) 2.2.9a (Page 15)

a.

The training and indoctrination

a.

The training!anid indoctrination Reflects separation of Big Rock Editorial program provides for ongoing program provides for ongoing training Point and Palisades quality training and periodic and periodic, refamiliarization with the programs. "Quality Program for refamiliarization with the Quality QPD.

,1r -,,

Nuclear Power Plants" changed to Program for Nuclear Power Plants

b.

Personnel who perform inspection and read "QPD".

b.

Personnel who perform inspection examination functions are qualified in and examination functions are accordance with requirements of qualified in accordance with Regulatory Guide 1.58, SNT TC-1A, or requirements of Regulatory Guide the ASME Code, or Section 10.2.3 of 1.58, SNT TC-IA, or the ASME this QPD, as applicable.

Code, or Section 10.2.3 of this Quality Program Description, as applicable.

59 2.2.10b (Page 14) 2.2.10b (Page 16)

Paragraph 1 Paragraph 1, 1s & 2n sentences As described in Appendix C, the Reflects the change from an standing committee meets ANSI NPAD - ISRG assesses nuclear safety The Restoration Safety Review Committee organizational unit to a standing N18.7 requirements as endorsed performance as described in Appendix C.

assesses nuclear safety performance as committee for independent review by Regulatory Guide 1.33.

Conclusions and recommendations are described in Appendix C. Conclusions and activities.

This is not a reduction in reported to the Senior Vice President, recommendations are reported to the Senior commitment per Nuclear, Fossil, and Hydro Operations.

Vice President, NFHO.

10 CFR 50.54(a)(3)(vi).

Page 23 of 56

, II u*

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 60 3.1 (Page 15) 3.1 (Page 17)

REQUIREMENTS REQUIREMENTS Paragraph 1, 3d sentence Paragraph 1, 3rd sentence Depending on the type of modification, Depending on the type of modification, these Added wording "UFHSR and ISFSI Editorial.

these activities include design and field activities include design and field engineering; to reflect Big Rock specific design engineering; the performance of physics, the performance of physics, seismic, stress, bases and changed wording 'Safety seismic, stress, thermal, hydraulic, thermal, hydraulic, radiation and UFHSR and Analysis Report (SAR)" to read radiation and Safety Analysis Report (SAR)

ISFSI SAR accident analyses, the development "SAR'.

accident analyses; the development and and control of associated computer programs; control of associated computer programs; studies of material compatibility; accessibility studies of material compatibility; for in-service inspection and maintenance; and accessibility for inservice inspection and determination of quality standards.

maintenance; and determination of quality standards.

61 3.2.1 (Page 15) 3.2.1 (Page 17)

Paragraph 1, 1st sentence Paragraph 1, 1st sentence Authority and responsibility for modification Authority and responsibility for modification Substituted "BRP" for "Nuclear Editorial.

activities is under the cognizance of the activities is under the cognizance of BRP as Plants" to reflect removal of Nuclear Plants as described in Section 1.0, described in Section 1.0, ORGANIZATION.

information related to Palisades.

ORGANIZATION.

62 3 2.9 (Page 17) 3.2.9 (Page 19)

Paragraph 2, 3, & 4 Paragraph 2, 3, & 4 (1), (2), (3)- parenthesis around numbers Parenthesis removed from numbers 1, 2, & 3 Word processing format change. No Editorial.

and period added.

text change.

63 3.2.9 (Page 17) 3.2.9 (Page 19)

Paragraph 7 Paragraph 7 Independent audits by Nuclear Independent audits by NPAD cover....

"Nuclear Performance Assessment' Editorial Performance Assessment cover....

__changed to "NPAD"_II Page 24 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 64 4.2.3 (Page 18) 4.2.3 (Page 21)

Paragraph 1, 2 d sentence Paragraph 1, 2hd sentence Provisions of this Quality Program Provisions of this QPD,are considered for "Quality Program Description" Editorial Description are considered for application application to suppliers, changed to read 'QPD'.

to suppliers.

65 5.1 (Page 20) 5.1 (Page 23)

REQUIREMENTS REQUIREMENTS I

Paragraph 3, Paragraph listing Paragraph 3, Para-graph listing Paragraph Paragraph 5.1 5.1 5.2, item 8 changed to 5, and Editorial 5.2, Item 8 5.2, item 5 5.2, item 14 changed to 10 to 5.2, item 14 5.2, item 10 maintain alignment.

66 5.2 - IMPLEMENTATION (Pgs 20-22) 5 2 - IMPLEMENTATION (Pgs 23-25) 3, 4, 5, 7a, 7b, & 12- (these items were The items related to *Palisades only', were Reflects removal of information Deletion of Palisades' identified as "Palisades only')

removed in their entirety and the remaining related to Palisades and the addition information has no impact on items renumbered.

of activities related to the Big Rock Point's commitments.

Independent Spent Fuel Storage This is not a reduction in Installation (ISFSI) at Big Rock commitment.

15a. Administrative control and technical 11 a. Administrative controls and technical Point.

support during plant modifications.

support during plant/ISFSI modifications.

1 16 Decommissioning procedures that

12. Decommissioning procedures that provide provide for the controlled dismantlement of for the controlled dismantlement of BRP and the plant and restoration of the plant site restoration of the plant site.

Page 25 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 67 6.1 (Page 23) 6.1 (Page 26)

REQUIREMENTS REQUIREMENTS Paragraph 3, 1 st sentence Paragraph 3, 1s sentence

• Personnel authorized to approve Personnel authorized to approve procedures The position of Site Vice President Editorial.

procedures specified by Plant or specified by Permanently Defueled Technical was only applicable to Palisades Permanently Defueled Technical Specifications are limited to an appropriate Specifications are limited to an appropriate senior department manager, based on the senior department manager, based on the activities addressed in the specific procedure, activities addressed in the specific predesignated in writing by the Site General procedure, predesignated in writing by the Manager.

ISite Vice President/Site General Manager.

68 6.2.2 (Page 23) 6.2.2d (Pgs 26-27)

d. Instructions and procedures for

d. Instructions and procedures for activities Changed -"plant maintenance" to Editorial.

activities such as fabrication, such as fabrication, construction, modification, "plant/IlSFSI maintenance' to reflect construction, modification, installation, installation, inspection, test, plant/ISFSI operation of ISFSI at BRP.

inspection, test, plant maintenance and maintenance and operation, and operation, and decommissioning which decommissioning which implement the Quality implement the Quality Program.

Program

e. Update Final Safety Analysis e UFHSR Updated Final Safety Analysis Editorial.

Report/Updated Final Hazards Safety Report and Plant Technical Report Specifications (Palisades) was only applicable to Palisades.

g. Plant Technical Specifications Deleted and renumbered remaining item.

Used abbreviation for Updated Final (Palisades)

Hazards Safety Report.

g. Permanently Defueled Technical

h. Permanently Defueled Technical Specifications I_____ Specifications_(BigRockPoint)_III Page 26 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 69 7.1 (Page 25) 7.1 (Page 28)

REQUIREMENTS REQUIREMENTS Paragraph 1, 3r sentence Paragraph 1, 3d sentence i

Objective evidence of quality that Objective evidence of quality that demonstrates Changed *the nuclear power plant The assignment of new demonstrates conformance with specified conformance with specified procurement site" to "BRP/ISFSI to reflect responsibility for ISFSI procurement document requirements is document requirements is available to operation of the ISFSI at Big Rock construction and operation is not available to the nuclear power plant site BRP/ISFSI prior to relibnce on equipment, Point.

a reduction in commitment.

prior to reliance on equipment, material or material or services.

Editorial.

services.

70 9.2.1 (Page 28) 9.2.1 (Page 32)

Paragraph 1,Ist sentence Paragraph 1, Ist sentence

'1 Processes subject to special process Processes subject to special process controls at Changed 'Consumers Energy" to The assignment of new controls at Consumers Energy are those for BRP/ISFSI are those for which full verification or "BRP/ISFSI".

responsibility for ISFSI which full verification or characterization by characterization by direct inspection is construction and operation is not direct inspection is impossible or impossible or impractical.,

a reduction in commitment.

Iimpractical 71 9 2.6 (Page 28) 9.2.6 (Page 32)

Paragraph 1 Paragraph 1.

Qualification records are maintained in Qualification records are maintained in Abbreviated 'Quality Program Editorial.

accordance with Quality Program accordance with QPD Section 17.

Description" as "QPD".

Description Section 17.

72 9.2.7 (Page 28) 9.2.7 (Page 32)

Paragraph 1 Paragraph 1 The Nuclear Performance Assessment The NPAD audits/assesses special process Abbreviated "Nuclear Performance Editorial.

Department audits/assesses special activities, including qualification activities to Assessment Department" as process activities, including qualification assure they are satisfactorily performed "NPAD'.

activities to assure they are satisfactorily nperformed.

Page 27 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 73 10.2.3 (Page 3T 10.2.3 (Page 34 Paragraph 1, 3 sentence Paragraph 1, 3 9sentence The Site Vice President/Site General The Site General Manager is responsible for The position of Site Vice President Editorial.

Manager is responsible for review and review and concurrence with plant training and was only applicable to Palisades.

concurrence with plant training and qualification programs that are under his direct qualification programs that are under his responsibility.

direct responsibility.

Pa p

Paragraph 2 Paragraph 2 Training and qualification programs for Training and qualification programs for Environmental and Laboratory Services (E&LS)

"E&TS" changed to "E&LS", and Editorial.

E&TS personnel who perform inspections, personnel who perform inspections, including words "Environmental and including nondestructive examination, are nondestructive examination, are documented in Laboratory Services" added to reflect documented in E&TS procedures.

E&LS procedures organizational name change.

74 10.2.6 (Page 30) 10.2.6 (Page 35)

Corrected grammar by adding word Editorial.

Paragraph 2 Paragraph 2 "the" before "result of codes,".

Independent verification should be Independent verification should be designated designated when the activity/task being when the activity/task being verified is verified is necessary to ensure critical necessary to ensure critical characteristics are characteristics are in conformance with in conformance with requirements and/or the requirements and/or the verification is result verification is the result of codes, standards, of codes, standards, regulations, or regulations, or commitments.

Icommitments.

75 11.1 (Page 32) 11.1 (Page 37)

Deleted "pre-operational, start-up,"

Deletion of Palisades' REQUIREMENTS REQUIREMENTS as they applied to Palisades only in information has no impact on Paragraph 1, 3d sentence Paragraph 1, 3d sentence this section. Big Rock Point is not Big Rock Point's commitments.

licensed to start-up or operate.

This is not a reduction in The test program includes qualification (as The test program includes qualification (as commitment applicable), acceptance, pre-operation, applicable), acceptance, surveillance, and start-up, surveillance, and maintenance maintenance tests.

testsII Page 28 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 76 I

11.2.2 (Page 32) 11.2.2c & d Removal of information related only Deletion of Palisades'

a.

Pre-operational tests to assure to Palisades.

information has no impact on proper and safe operation of Removed sections c & d in their entirety and Big Rock Point's commitments.

systems and equipment prior to renumbered remaining ýections.

This is not a reduction in start-up tests or operation commitment.

(Palisades Only).

b.

Start-up tests, including precritical, criticality, low-power, and power ascension tests, performed after refueling to assure proper and safe operation of systems and equipment. (Palisades Only)

'7 18.2.9 (Page 44) 18.2.9 (Page 49)

Abbreviated "Nuclear Performance Editorial Paragraph 1, 1st sentence Paragraph 1, 1Vt sentence Assessment Department" as "NPAD".

Audit data are analyzed by the Nuclear Audit data are analyzed by the NPAD.

Performance Assessment Department.

78 18.2.10 (Page 44) 18.2.10 (Page 49)

Abbreviated "Nuclear Performance Editorial Paragraph 1, 2nd sentence Paragraph 1, 2 n sentence Assessment Department" as "NPAD".

Follow-up for internal audits is performed Follow-up for internal audits is performed by the by the Nuclear Performance Assessment NPAD to ensure that appropriate corrective Department to ensure that appropriate action is taken and is effective.

corrective action is taken and is effective 79 APPENDIX A, Part 1 (Page 46)

APPENDIX A, Part I (Page 51)

Removal of information related only Deletion of Palisades' Item #21

1. 21 to Palisades.

information has no impact on Big Rock Point's commitments.

21. 10 CFR 50, Appendix R, Fire protection Removed in its entirety, and renumbered This is not a reduction in Program for Nuclear Power Facilities remaining item commitment.

Operating Prior to January 1, 1979, Sections III G., IIIj. and III 0. (Not 1_applicable to Big Rock Point)

Page 29 of 56

,ITI-.I 1n Renaon for Change I

Basis for Conclusion Item Revision 19 ReviiouII u Asdsrbe nApndxCIh 80 APPENDIX A, Part 2 (Page 52)

1. 2 - Exception/Interpretation Consumers Energy has established an organization, the Restoration Safety Review Committee, (RSRC) for independent review activities.

The standard numeric and qualification requirements may not b'e met by the RSRC.

Procedures will be established to specify how the RSRC will acquire necessary expertise to carry out its review responsibilities in accordance with Appendix C, Restoration Safety Review Committee.

Reflects the change from an organizational unit to a standing committee for independent review activities.

As described in Appendix C, the standing committee meets ANSI N18.7 requirements as endorsed by Regulatory Guide 1.33.

This is not a reduction in commitment per 10 CFR 50.54(a)(3)(vi)

_Appendix C, Independent Safety Review.

APPENDIX A, Part 2 (Page 48)

APPENDIX A, Part 2 (Page 53)

Reflects the organization of the Editorial.

1. 2a - Exception/Interpretation

1. 2a - Exception/Interpretation Consumers Energy Company, I

operation of the ISFSI at Big Rock Since Consumers Energy has more than Since Consumers Energy has more than one Point, and replaces *Quality Program one nuclear unit and more than one organization providing services to BRPIISFSI, Description* with abbreviation organization providing services to these overall responsibility cannot be centralized in a "QPD".

units, overall responsibility cannot be single on-site position. Instead, responsibilities centralized in a single on-site position.

are as designated within the QPD.

Instead, responsibilities are as designated within the Quality Program Description

_I Page 30 of 56 APPENDIX A, Part 2 (Page 47)

1. 2 - Exception/Interpretation Consumers Energy has established an organizational unit, Nuclear Performance Assessment Department, for independent review activities.

The standard numeric and qualification requirements may not be met by the Nuclear Performance Assessment Department staff. Procedures will be established to specify how NPAD will acquire necessary expertise to carry out its review responsibilities in accordance with F

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 82 11 APPENDIX A, Part 2 (Page 48)

APPENDIX A, Part 2 (Part 53)

Reflects the change from an As described in Appendix C, the

1. 2b - Exception/Interpretation

1. 2b - Exception/Interpretation organizational unit to a standing standing committee meets ANSI committee for independent review N18.7 requirements as endorsed The Nuclear Performance Assessment The RSRC will not have members specified by activities by Regulatory Guide 1.33.

Department will not have members number or by technical disciplines and its This is not a reduction in specified by number or by technical members may not have the experience and commitment per disciplines and its members may not have competence required to review problems in all 10 CFR 50.54(a)(3)(vi) the experience and competence required to areas listed in this section; however, the RSRC review problems in all areas listed in this will function as described in Appendix C, section; however, the Nuclear Performance Restoration Safety Review Committee, and will Assessment Department will function as acquire the services of personnel having such described in Appendix C, Independent experience and competence as necessary.

Safety Review, and will acquire the services of personnel having such experience and competence as necessary.

83 APPENDIX A, Part 2 (Page 48)

APPENDIX A, Part 2 (Page 53)

Reflects the change from an As described in Appendix C, the

1. 2c - Exception!Interpretation

1. 2c - Exception/Interpretation organizational unit to a standing standing committee meets ANSI committee for carrying out N18.7 requirements as endorsed Subjects requiring review will be as Subjects requiring review will be as specified in independent review activities, by Regulatory Guide 1.33.

specified in Appendix C, Independent Appendix C, Restoration Safety Review This is not a reduction in Safety Review.

Committee commitment per 10 CFR 50.54(a)(3)(vi).

84 APPENDIX A, Part 2 (Part 48)

APPENDIX A, Part 2 (Page 53)

Reflects the change from an As described in Appendix C, the

1. 2d - Exception/Interpretation

1. 2d - Exception/Interpretation organizational unit to a standing standing committee meets ANSI Paragraph 1, 1= sentence Paragraph 1, 1r" sentence committee for carrying out N18.7 requirements as endorsed independent review activities, by Regulatory Guide 1.33.

The Nuclear Performance Assessment The RSRC will not review Technical This is not a reduction in Department will not review Technical Specification Changes after NRC approval prior commitment per Specification Changes after NRC approval to implementation.

10 CFR 50.54(a)(3)(vi).

prior to implementation._III Page 31 of 56

jPage 32 of 56 Item Revision 19 Revision 20 Reason for Changie Basis for Conclusion 85 1

APPENDIX A, Part 2 (Page 49)

APPENDIX A, Part 2 (Page 54)

1. 2e - Exception/Interpretation

1. 2e - ExceptionlInterpretation Paragraph 1 Paragraph 1 The Nuclear Performance Assessment The RSRC shall review or arrange for reviews of Reflects the change from an As described in Appendix C, the Department shall review or arrange for those audits over which it has cognizance, in organizational unit to a standing standing committee meets ANSI reviews of those audits over which it has accordance with Appendix C, Restoration Safety committee for carrying out N18.7 requirements as endorsed cognizance, in accordance with Appendix Review Committee.

independent review activities, by Regulatory Guide 1.33 C, Independent Safety Review.

This is not a reduction in Some of the audits required during the commitment per Some of the audits required during the operational and decommissioning phase are in Added 'and decommissioning" to 10 CFR 50.54(a)(3)(vi) operational phase are in areas other than areas other than those requiring independent more accurately reflect Big Rock those requiring independent review in review in accordance with ANSI N18.7, Section Point activities.

accordance with ANSI N18.7, Section 4.3.4.

4.3.4.

86 APPENDIX A, Part 2 (Page 49)

APPENDIX A, Part 2 (page 54)

Reflects the change from an As described in Appendix C, the

1. 2f-Exception/Interpretation

1. 2f-Exception/Interpretation organizational unit to a standing standing committee meets ANSI Paragraph 1 Paragraph I committee for carrying out N18.7 requirements as endorsed independent review activities, by Regulatory Guide 1.33.

Audits of nuclear facility activities are Audits of nuclear facility activities are performed This is not a reduction in performed under the cognizance of the under the cognizance of the RSRC as described commitment per Nuclear Performance Assessment in Appendix C, Restoration Safety Review 10 CFR 50.54(a)(3)(vi)

Department as described in Appendix C, Committee 1_Independent Safety Review._II

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 87 APPENDIX A, Part 2 (Page 50)

APPENDIX A, Part 2 (Page 55)

1. 2h. - Exception/interpretation

1. 2h.. - Exception/interpretation I

b. The change is approved by two members

b. The change is approved by two members (or Information related to Palisades was Deletion of Palisades (or designated alternates) of the PRCISRC, designated alternates) of the SRC, at least one removed from the Big Rock Point information has no impact on at least one of whom holds a Senior of whom is a Certified Fuel Handier;, and Specific Program.

Big Rock Point's commitments.

Reactor Operators License (Palisades) or is This is not a reduction in a Certified Fuel Handler (Big Rock Point);

c. The change is documented, subsequently commitment.

and reviewed by the SRC within 30 days of issuance, and approved by an appropriate*

c. The change is documented, senior department manager predesignated by subsequently reviewed by the PRC/SRC the Site General Manager.

within 30 days of issuance, and approved by an appropriate* senior department Determination of theappropriate senior manager predesignated by the Site Vice department manager is based on the activities President/Site General Manager.

addressed in the specific procedure, and will be predesignated in writing by the Site General Determination of the appropriate senior Manager.

department manager is based on the

, I activities addressed in the specific procedure, and will be predesignated in writing by the Palisades Plant Site Vice President/Big Rock Point Site General Manager.

88 APPENDIX A, Part 2 (Page 51)

APPENDIX A, Part 2 (Page 56)

1. 2j. Requirement

1. 2j. Requirement Paragraph 1, 1 sentence Paragraph 1, Is sentence The following standards contain useful The following standards contain useful guidance Deleted 'occurring during the Editorial guidance concerning design and concerning design and construction-related operational phase" to more construction-related activities associated activities associated with modifications and accurately reflect the status of Big with modifications and shall be applied to shall be applied to those activities that are Rock Point.

those activities occurring during the comparable in nature and extent to related operational phase that are comparable In activities occurring during initial plant design nature and extent to related activities and construction:

occurring during initial plant design and construction:

Page 33 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 89 APPENDIX A, Part 2 (Page 54)

APPENDIX A, Part 2 (Page 59)

1. 2r. - Exception/interpretation

1. 2r. - Exception/Interpretation Paragraph 1, 1 sentence Paragraph 1, 1" sentence Replaced "by licensed Operations Editorial.

At Consumers Energy, equipment is At Consumers Energy, equipment is returned to Department personnel: to "by returned to its normal operating status, i.e.,

its normal operating status, i.e., declared qualified Operations Department declared operable, by licensed Operations operable, by qualified Operations Department personnel" to reflect that operating Department personnel, not Maintenance personnel, not Maintenance personnel.

licenses are no longer retained by personnel.

Big Rock Point personnel.

90 APPENDIX A, Part 2 (Page 54)

APPENDIX A, Part 2 (Page 60)

Reflects the change from an As described in Appendix C, the

1. 3a - Exception/ Interoretation

1. 3a - Exception/ Interpretation organizational unit to a standing standing committee meets ANSI Paragraph 1,Ist sentence Paragraph 1, Is sentence committee for independent review.

N18.7 requirements as endorsed by Regulatory Guide 1.33.

Performance trends are reviewed by the Performance trends are reviewed by the RSRC.

This is not a reduction in Nuclear Performance Assessment commitment per Specialists.

10 CFR 50.54(a)(3)(vi).

91 APPENDIX A, Part 2 (Page 56)

APPENDIX A, Part 2 (Page 61)

1. 5b. - Exception/Interpretation

1. 5b. - ExceptionfInterpretation Paragraph 1, 1st sentence Paragraph 1, 1s sentence Consumers Energy understands that this Consumers Energy understands that this Replaced "a nuclear power plant" Editorial.

requirement applies both to Consumers requirement applies both to Consumers Energy with "BRP", and deleted "during Energy employees from another site and to employees from another site and to contract outages" to reflect application of contract personnel who are temporarily personnel who are temporarily assigned to BRP program to only Big Rock Point assigned to a nuclear power plant either as either as replacements for regular employees or replacements for regular employees or to to augment the staff.

augment the staff during outages.

92 APPENDIX A, Part 2 (Page 58)

APPENDIX A, Part 2 (Page 63)

1. 7b. - Exception/Interpretation

1. 7b. - Exception/Interpretation Paragraph 1, 15 sentence Paragraph 1, 1 $ sentence Offsite inspection, examination, or testing Offsite inspection, examination, or testing Replaced "Reg Guide" with Editorial.

activities are audited or inspected by activities are audited or inspected by persons "Regulatory Guide'.

persons qualified and certified in qualified and certified in accordance with ANSI accordance with ANSI N45.2.23-1978, as N45.2.23-1978, as endorsed by Regulatory endorsed by Reg Guide 1.146, or by Guide 1.146, or by personnel meeting the personnel meeting the requirements of requirements of 10.2.7, respectively.

10 2.7,_respectively._IIII Page 34 of 56

Item Revision 19 Revision 20 Reason for Chanue Basis for Conclusion 93 APPENDIX A, Part 2 (Page 59)

APPENDIX A, Part 2 (Page 64)

Editorial - Word processing format N/A

1. 7e. N45 2 2, Sec 5.2.2

1. 7e N45 2 2, Sec 5.2.2 1 change. No text change.

94 APPENDIX A, Part 2 (Page 60)

APPENDIX A, Part 2 (Page 66)

1. 9a. - Exception/Interpretation

1. 9a. - Exception/Interpretation Paragraph 1, 1st sentence Paragraph 1, 1't sentence During the operations phase, this During the decommissioning phase, this Replaced 'operations' with Editorial requirement is considered to be applicable requirement is considered to be applicable to "decommissioning" to reflect current to modifications and initial start-up of modifications and initial start-up of electrical condition of Big Rock Point.

electrical equipment.

equipment.

95 APPENDIX A, Part 2 (Page 61)

APPENDIX A, Part 2 (Part 67)

1. 1 0 b. - E xcept io n/Onterp retatio n

1. 1 0b. - E xceptio n/Interp retation Paragraph 1, 2nonsentence Paragraph 1, 2nd sentence Replace 'an operating plant* with 'a Editorial plant undergoing decommissioning' The N18.7 requirements are more The N18.7 requirements, are more applicable to to reflect current condition of Big applicable to an operating plant.

a plant undergoing decommissioning Rock Point.

96 APPENDIX A, Part 2 (Page 62)

APPENDIX A, Part 2 (Pane 68)

1. 12a. - Exception/Interpretation

1. 12a. - ExceptionlInterpretation Paragraph 1, 2 nd sentence Paragraph 1, 2na sentence Some of these departments have already Some of these departments have already Replaced 'operations phase of Editorial developed their qualification programs developed their qualification programs based on Consumers Energy Nuclear Plants" based on ANSI N45.2.6, and provide ANSI N45.2.6, and ptovlde services throughout with 'decommissioning of BRP' to services throughout the operations phase of the decommissioning of BRP.

reflect current condition of Big Rock Consumers Energy Nuclear Plants.

o1 Point.

97 I

APPENDIX A, Part 2 (Page 64)

APPENDIX A, Part 2 (Page 70)

1. 13b - Exception/interpretation

1. 13b. - Exception/interpretation Paragraph 1, 1st sentence Paragraphi, 1 st sentence Editorial Replaced "operations Editorial.

During the operations phase, this During the decommissioning phase, this phase' with 'decommissioning requirement is considered to be applicable requirement is considered to be applicable to phase" to reflect current condition of Ito modifications of mechanical equipment.

modifications of mechanical equipment.

Big Rock Point.

Page 35 of 56

item Revision 19 Revision 20 Reason for Chan-ae Basis for Conclusion 98 APPENDIX A, Part 2 (Page 65)

APPENDIX A, Part 2 (Page 71)

1. 13e. - Requirement

1. 13e. - Requirement, Paragraph I Paragraph I "Installed systems and components shall be "Installed systems and components shall be Deleted redundant information "of No change made to the cleaned, flushed, and conditioned cleaned, flushed, and cqnditioned according to ANSI N45.2.1 Special attention shall exception or interpretation of the according to the requirements of ANSI the requirements:...." (Requirements are given be given to the following requirement.

N45.2.1 Special attention shall be given to for chemical conditioning, flushing and process requirements'.

the following requirements:.... "

controls.)

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

99 APPENDIX A, Part 2 (Page 68)

APPENDIX A, Part 2 (Page 74)

1. 17b. - Requirement

1. 17b. - Requirement Paragraph 1 Paragraph 1 "Procurement documents shall require that "Procurement documents shall require that the Deleted "all" from phrase Editorial the supplier have a documented quality supplier have a documented quality assurance

"...portions all of ANSI N45.2..."

assurance program that implements program that implements portions of ANSI portions all of ANSI N45.2 as well as N45.2 as well as applidable quality assurance applicable quality assurance program program requirements of other nationally requirements of other nationally recognized recognized codes and standards."

codes and standards."

100 APPENDIX A, Part 2 (Page 70)

APPENDIX A, Part 2 (Page 77)

1. 21a - Exception/Interpretation

1. 21a - Exception/Interpretation Paragraph I Paragraph 1 Both Consumers Energy nuclear plants (Big BRP was designed, constructed and licensed Information related to Palisades was Deletion of Palisades Rock Point and Palisades) were designed, based on criteria available prior to Revision 3 of removed from the Big Rock Point information has no impact on constructed and licensed based on criteria this Regulatory Guide being issued. The Specific Program.

Big Rock Point's commitments available prior to Revision 3 of this specific design criteria and seismic designations This is not a reduction in Regulatory Guide being issued. The are reflected in the UFHSR and in other commitment specific design criteria and seismic docketed analysis. Thus the design bases and designations are reflected in the UFHSR seismic designations do not correspond to those and UFSAR, respectively, and in other of Regulatory Guide 1.29.

docketed analysis. Thus the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.

Page 36 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 101 APPENDIX B (Page 72)

APPENDIX B (Page 79)

Title Title f'

OPD MANUAL APPENDIX B APPENDIX B SAFETY REVIEW COMMITTEE (SRC) (BIG Information related to Palisades was Deletion of Palisades PLANT REVIEW COMMITTEE ROCK POINT) removed from the Big Rock Point information has no impact on (PALISADES)

Specific Program.

Big Rock Point's commitments.

SAFETY REVIEW COMMITTEE (SRC)

This is not a reduction in (BIG ROCK POINT)

__commitment.

102 APPENDIX B (Page 72)

APPENDIX B (Page 79) I

1. BI. - FUNCTION

1. B1. - FUNCTION I'

Paragraph I Paragraph 1 The Plant Review Committee (PRC)/Safety The Safety Review Committee (SRC) shall Information related to Palisades was Deletion of Palisades Review Committee (SRC) shall function to function to advise the Site General Manager on removed from the Big Rock Point information has no impact on advise the Site Vice President/Site General all matters related to nuclear safety.

Specific Program.

Big Rock Point's commitments.

Manager on all matters related to nuclear This is not a reduction in safety.

commitment.

103 APPENDIX B (Page 72)

APPENDIX B (Page 79)

1. B2. - COMPOSITION

1. 82. - COMPOSITION Paragraph 1 Removed in its entirety - related to Palisades Information related to Palisades was Deletion of Palisades The Palisades PRC is composed of nine PRC only removed from the Big Rock Point information has no impact on regular members. The qualification level Specific Program.

Big Rock Point's commitments.

for PRC members shall be at least This is not a reduction in equivalent to those described in Section 4.4 of ANSI N1i8.1-1971. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Site Vice President.

Page 37 of 56

Item Revision 19 Reflsion 20 Reason for Change Basis for Conclusion 104 APPENDIX B (Page 72)

APPENDIX B (Page 79)

1. B2. - COMPOSITION

1. 12. - COMPOSITION Paragraph 2, 1 sentence Paragraph 2, 1st sentence The Big Rock Point SRC is composed of a The BRP SRC is composed of a Chairman and Editorial --"BRP" substituted for "Big Editorial.

Chairman and a minimum of four members a minimum of fourJmembers from the BRP Rock Point".

from the Big Rock Point staff.

staff.

105 APPENDIX B (Page 72)

APPENDIX B (Page 79)

Changed "Engineering," to Editorial.

1. B2. - COMPOSITION

1. 12. - COMPOSITION "Engineering and Licensing, and',

Paragraph 2, 3rd and 4u sentences Paragraph 2, 3d and 4, sentences and replaced "Environmental, and Nuclear Fuel Projects Departments",

The SRC shall include representatives from The SRC shall include representatives from the with "Environmental Services" to the Operations, Engineering, Radiation Operations, Engineering and Licensing, and reflect current organization of Big Protection and Environmental, and Nuclear Radiation Protection and Environmental Rock Point.

Fuel Projects Departments. The members Services. The members shall be designated in, shall be designated in administrative writing, by the Site General Manager.

Replaced "administrative Editorial.

procedures by the Site General Manager.

procedures" with ", writing,'.

106 APPENDIX B (Page 72)

APPENDIX B (Page 7,9)

1. B3. - ALTERNATIVES

1. 83 - ALTERNATIVESI Paragraph 1 Paragraph 1 Alternate members of the PRCISRC shall Alternate members of the SRC shall be Information related to Palisades was Deletion of Palisades be appointed in writing by the PRC/SRC appointed in writing by the SRC Chairman to removed from the Big Rock Point information has no impact on Chairman to serve on a temporary basis.

serve on a temporary basis. No more than one Specific Program.

Big Rock Point's commitments.

No more than two alternates shall alternate shall participate as a voting member at This Is not a reduction in participate as voting members at any one any one time in BRP SRC activities, commitment.

time in Palisades PRC activities, nor more than one alternate in Big Rock Point SRC activities.

Page 38 of 56

item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 107 APPENDIX B (Page 72)

APPENDIX B (Page 79)

1. B4. - MEETING FREQUENCY

1. B4. - MEETING FREQUENCY I

The Palisades PRC shall meet at least once Removed in its entirety - related to Palisades Information related to Palisades was Deletion of Palisades per calendar month with special meetings only.

removed from the Big Rock Point information has no impact on as required.

Specific Program.

Big Rock Point's commitments.

The BRP SRC shall meet at least monthly while This is not a reduction in The Big Rock Point SRC shall meet at least fuel is stored in the spent fuel pool during the commitment.

monthly while fuel is stored in the spent fuel pre-dismantlement and dismantlement phases pool during the pre-dismantlement and During the safe storage phase (no fuel in the Editorial -

BRP" substituted for'Big Editorial dismantlement phases. During the safe spent fuel pool), SRC shall meet at least Rock Point".

storage phase (no fuel in the spent fuel quarterly.

pool), SRC shall meet at least quarterly.

108 APPENDIX B (Page 72)

APPENDIX B (Page 79)

1. 15. - QUORUM

1. 85. - QUORUM A quorum of the Palisades PRC shall A quorum of the BRP SRC shall consist of the Information related to Palisades was Deletion of Palisades consist of the Chairman or alternate and Chairman or alternate Chairman and two removed from the Big Rock Point information has no impact on four members or alternates. A quorum of members, which may not include more than one Specific Program.

Big Rock Point's commitments.

the Big Rock Point SRC shall consist of the alternate member.

This is not a reduction in Chairman or alternate Chairman and two commitment.

members or alternates.

Editorial - "BRP" substituted for "Big Editorial.

Rock Point.

109 APPENDIX B (page 72)

APPENDIX B (Page 7,9)

1. 86. - RESPONSIBILITIES

1. 86. - RESPONSIBILITIES Information related to Palisades was Deletion of Palisades Paragraph 1, 1st sentence Paragraph 1, 1st sentence removed from the Big Rock Point information has no impact on Specific Program.

Big Rock Point's commitments.

The PRCISRC shall be responsible for The SRC shall be responsible for nuclear safety This is not a reduction in nuclear safety review of.

review of....

commitment.

qt Page 39 of 56

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 110 APPENDIX B (Page 73)

APPENDIX B (Page 79)

1. B6.a - RESPONSIBILITIES

1. B6.a. - RESPONSIBILITIES Paragraph 1 Paragraph 1

a. All procedures and programs specified a All procedures and programs specified by the Information related to Palisades (Site Deletion of Palisades by the Technical Specifications and Technical Specifications and changes thereto, Vice President) was removed from information has no impact on changes thereto, and any other procedures and any other procedures or changes thereto as the Big Rock Point Specific Program.

Big Rock Point's commitments.

or changes thereto as determined by the determined by the Site General Manager to This is not a reduction in Site Vice President/Site General Manager affect nuclear safety; all proposed tests or commitment.

to affect nuclear safety; all proposed tests experiments that affect nuclear safety; all or experiments that affect nuclear safety; all proposed changes or modifications to plant Added "ISFSI* to reflect current Editorial.

proposed changes or modifications to plant systems or equipment or the ISFSI that affect condition of Big Rock Point.

systems or equipment that affect nuclear nuclear safety.

safety.

111 APPENDIX B (Page 73)

APPENDIX B (Page 79)

1. B6.b. - RESPONSIBILITIES

1. B6.b. - RESPONSIBILITIES Paragraph 1 Paragraph I All proposed changes to Operating License All proposed changes to Operating License, the Added "ISFSI License" and "Spent The addition of new information and Technical Specifications.

ISFSI License, Technical Specifications, and the Fuel Storage System Certificate of and commitments is not a Spent Fuel Storage System Certificate of Compliance" to reflect current reduction in commitment.

Compliance.

condition of Big Rock Point.

112 APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B6.c. - RESPONSIBILITIES

1. B6.c. - RESPONSIBILITIES Paragraph 1, 2"7 sentence Paragraph 1, 2-sentence Deleted name "Nuclear Performance As described in Appendix C, the (A report shall be prepared covering (A report shall be prepared covering evaluation Assessment Department" and added standing committee meets ANSI evaluation and recommendations to prevent and recommendations to prevent recurrence "RSRC" to reflect current condition of N18.7 requirements as endorsed recurrence and be forwarded to the Vice and be forwarded to the Vice President, NFHO, Big Rock Point.

by Regulatory Guide 1.33.

President-NFHO and to the Manager, the Manager, NPAD, and the RSRC)

This is not a reduction in Nuclear Performance Assessment commitment per Department (NPAD))

10 CFR 50.54(aX3)(vi).

113 APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B6.d. - RESPONSIBILITIES

1. B6 d. - RESPONSIBILITIES Plant operations to detect potential safety PlantJISFSI operations to detect potential safety Added "/ISFSI to reflect current Editorial.

hazards.

hazards.

condition of Big Rock Point.

I Page 40 of 56

"Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 114lI APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B6.e. - RESPONSIBILITIES

1. B6.e. - RESPONSIBILITIES Deleted "Site Vice President" and There is no reduction in Reports of special reviews and Reports of special reviews and investigations as added "RSRC" to reflect current commitment as this change investigations as requested by the Site Vice requested by the Site General Manager, the condition of Big Rock Point.

meets the intent of President/Site General Manager or NPAD.

Manager, NPAD, or RStkC.

10 CFR 50.54(a)(3)(vi).

115 APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B6.g. - RESPONSIBILITIES

1. B6 g. - RESPONSIBILITIES Added '72.74, and 72.75" to reflect The addition of new information All reportable events as defined in 10 CFR All reportable events as defined in 10 CFR current condition of Big Rock Point.

and commitments is not a 50.72 and 50 73.

50.72, 50.73, 72.74, and 72.75 L

reduction in commitment APPENDIX B (Page 73)

1. B6.h - RESPONSIBILITIES All items identified under B9 3 below as significant to nuclear safety (Palisades only)

APPENDIX B (Page 73)

1. B6.i. - RESPONSIBILITIES Monthly reports from Safety/Design Review (Palisades only).

APPENDIX B (Page 73)

1. B6.k. - RESPONSIBILITIES Paragraph 1 Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Site General Manager and to the Manager, Nuclear Performance Assessment Department (Big Rock Pont Ionly).-

APPENDIX B (Page 80)

1. B6.h. - RESPONSIBILITIES Removed in its entirety; related to Palisades only. Remaining items renumbered.

Information related to Palisades was removed from the Big Rock Point Specific Program.

-i i

1 APPENDIX B (Page 80)

1. B6.i. - RESPONSIBILITIES Removed in its entirety, related to Palisades only. Remaining items renumbered.

APPENDIX B (Page 80)

1. B6.i. - RESPONSIBILITIES Paragraph 1 Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Site General Manager, the Manager, NPAD, and RSRC Information related to Palisades was removed from the Big Rock Point Specific Program.

Deleted words "and to", "Nuclear Performance Assessment Department (Big Rock Pont only)*.

Replaced words with ", The Manager, NPAD, and RSRC".

Deletion of Palisades information has no impact on Big Rock Point's commitments.

This is not a reduction in commitment.

Deletion of Palisades information has no impact on Big Rock Point's commitments.

This is not a reduction in commitment.

Editorial Page 41 of 56 116 117 118 I

I

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 119 APPENDIX B (page 73)

APPENDIX B (Page 80)

1. B6. - RESPONSIBILITIES

1. B6. - RESPONSIBILITIES Last paragraph Last paragraph PRC/SRC review of the above items may SRC review of the above items may be Information related to Palisades was Deletion of Palisades be performed by routing, subject to the performed by routing, subject to the removed from the Big Rock Point information has no impact on requirements of B7. below. The Palisades requirements of B7. below.

Specific Program.

Big Rock Point's commitments.

PRC may delegate review of items a. and f.

This is not a reduction in to Safety/Design Review staff, as described commitment.

in B9. below.

120 APPENDIX B (Page 73)

APPENDIX B (Page 80)

Information related to Palisades was Deletion of Palisades

1. B7. - AUTHORITY

1. B7. - AUTHORITY removed from the Big Rock Point information has no impact on Specific Program.

Big Rock Point's commitments.

The PRC/SRC shall:

The SRC shall:

This is not a reduction in commitment.

121 APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B7.a. - AUTHORITY

1. B7.a. - AUTHORITY Recommend in writing to the Site Vice Recommend in writing to the Site General Deleted "Site Vice President/" and Editorial.

President/Site General Manager approval Manager approval or disapproval of items changed "j." to "i.'.

or disapproval of items considered under considered under B6.a. through i. above.

3B6.a. through j. above.

122 APPENDIX B (Page 73)

APPENDIX B (Page 80)

Information related to Palisades was Deletion of Palisades

1. B7.b. -_AUTHORITY

1. B7.b. - AUTHORITY removed from the Big Rock Point information has no impact on Specific Program.

Big Rock Point's commitments.

Render determinations in writing with Render determinations in writing with regard to This is not a reduction in regard to whether or not each item whether or not each item considered under Also, reflects changes to commitment considered under B6.a, b, c, f (Palisades B6.a, b, and c, above needs prior NRC 10CFR50.59, which discontinued only) and h above constitutes an

approval, use of the term "unreviewed safety Editorial.

1_unreviewed safety question.,II question.!_II Page 42 of 56

Page 43 of 56 Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 123 APPENDIX B (Page 73)

APPENDIX B (Page 80)

1. B7.c. - AUTHORITY

1. B7.c. - AUTHOR ITI Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 Information related to Palisades was Deletion of Big Rock Point to the Senior Vice President - Nuclear, the Senior Vice President, NFHO, the Manager, removed from the Big Rock Point Information has no impact on Fossil, and Hydro Operations and to the NPAD, and RSRC of any disagreements Specific Program.

Palisades' commitments. This Nuclear Performance Assessment between the SRC and the Site General is not a reduction in Department of any disagreements between Manager, however, the Site General Manager commitment.

the PRC/SRC and the Site Vice shall have responsibility for the resolution of President/Site General Manager, however, such disagreements.

Remaining position titles and Editorial.

the Site Vice President/Site General departmental names were Manager shall have responsibility for the abbreviated, and "RSRC" added.

Sresolution of such disagreements.

124 APPENDIX B (Page 74)

APPENDIX B (Page 81)

1. 87. - AUTHORITY

1. B7. - AUTHORITY Paragraph 5 Paragraph 5 The PRC/SRC Chairman may recommend The SRC Chairman may recommend to the Site Information related to Palisades was Deletion of Big Rock Point to the Site Vice President/Site General General Manager approval of those items removed from the Big Rock Point information has no impact on Manager approval of those items identified identified in B6, above based on a routing Specific Program.

Palisades' commitments This in B6. above based on a routing review review provided the following conditions are is not a reduction in provided the following conditions are met:

met:

IIcommitment I "

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 125 APPENDIX B (Page 74)

APPENDIX B (Page 81)

1. B7. - AUTHORITY

1. B7. - AUTHORITY Paragraph 5-Paragraph 5 For Palisades:

Removed in its entirety - related to Palisades Information related to Palisades was Deletion of Palisades only removed from the Big Rock Point information has no impact on (1) at least five PRC members including the Specific Program.

Big Rock Point's commitments.

Chairman and no more than 2 alternates, This is not a reduction in shall review the item, concur with commitment.

determination as to whether or not the item constitutes an unreviewed safety question, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the PRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers for additional comments 126 APPENDIX B (Page 74)

APPENDIX B (Page 81)

1. 87. -AUTHORITY

1. 87. -AUTHORITY Paragraph 6 - For Big Rock Point-Paragraph 6 (1) at least three SRC members, including (1) at least three SRC members, including the Removed 'For Big Rock Point:"

Editorial.

the Chairman and not more than one Chairman and not more than one alternate, heading; *item constitutes an alternate, shall review the item, concur with shall review the item, concur with determination unreviewed safety questions",

determination as to whether or not the item as to whether or not the item requires prior NRC replaced with "item requires prior constitutes an unreviewed safety question, approval, and provide written comments on the NRC approval' and provide written comments on the item; item; (2) all comments shall be resolved to the (2) all comments shall be resolved to the satisfaction of the reviewers providing the satisfaction of the reviewers providing the comments; and (3) if the SRC Chairman comments; and (3) if the SRC Chairman determines that the comments are significant, determines that the comments are the item (including comments and resolutions) significant, the item (including comments shall be recirculated to all reviewers.

and resolutions) shall be recirculated to all I

reviewers.

Page 44 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 127 APPENDIX B (Page 74)

APPENDIX B (Page 81)

1. B7. - AUTHORITY

1. B7. - AUTHORITY ' I Last Paragraph Last Paragraph The item shall be reviewed at PRC/SRC The item shall be reviewed at SRC meeting in Information related to Palisades was Deletion of Palisades meeting in the event that: (1) Comments the event that: (1) Comments are not resolved; removed from the Big Rock Point information has no impact on are not resolved; or (2) the Site Vice or (2) the Site General Manager overrides the Specific Program.

Big Rock Point's commitments President/Site General Manager overrides recommendations of the SRC; or (3) a proposed This is not a reduction in the recommendations of the PRC/SRC; or change to the Technical Specifications involves commitment.

(3) a proposed change to the Technical a safety limit, a limiting safety system setting or Specifications involves a safety limit, a a limiting condition for operation; or (4) the item limiting safety system setting or a limiting was reportable to the NRC.

condition for operation; or (4) the item was reportable to the NRC 128 APPENDIX B (Page 74)

APPENDIX B (Page 81)

1. B8. - RECORDS

1. B8. - RECORDS Information related to Palisades was Deletion of Palisades Paragraph 1 Paragraph 1 removed from the Big Rock Point information has no impact on Specific Program.

Big Rock Point' commitments.

The PRClSRC shall maintain written The SRC shall maintain written minutes of each This is not a reduction in minutes of each PRC/SRC meeting and SRC meeting and shall provide copies to the Replaced "Independent Safety commitment.

shall provide copies for Independent Safety RSRC.

Review" with "RSRC" to reflect Review.

current Big Rock Point organization.

Editorial.

129 APPENDIX B (Page 74 and 75)

APPENDIX B (Page 81)

1. B9. TECHNICAL SUPPORT FOR

1. B9.

Information related to Palisades was Deletion of Palisades PALISADES PRC removed from the Big Rock Point information has no impact on Removed in its entirety - relates to Palisades Specific Program.

Big Rock Point's commitments.

Sections B9.1-B9.4 removed in their only This is not a reduction in Ientirety.

commitment 130 APPENDIX C, (Page 76)

APPENDIX C, (Page 82)

Reflects the change from an As described in Appendix C, the Title Title organizational unit (NPAD) to a standing committee meets ANSI standing committee (RSRC) for N18.7 requirements as endorsed OPD MANUAL APPENDIX C independent review activities, by Regulatory Guide 1.33.

APPENDIX C RESTORATION SAFETY REVIEW This is not a reduction in INDEPENDENT SAFETY REVIEW COMMITTEE commitment per 10 CFR 50.54(a)(3)(vi)

Page 45 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 131 rI" APPENDIX C (Page 76)

APPENDIX C (Page 8?)

Added to the Table - 1) item C1 ANSI/ANS N18.7-1976, as Table Table Exception/Interpretation 2 (describes endorsed by Regulatory Guide Ibuse of RSRC), 2) C2 with 1.33 Rev. 2, provides Paragraph Exceptions/Interpretations Paragraph Exceptions/Interpretations Exception/Interpretation 2 (describes requirements for independent use of RSRC) and 22 (qualification review to be conducted by an C1.

2c, C1.

2, 2c, of restoration safety review function organizational unit or a standing C4.1(d) 2d, C2 2, 22 personnel), 3) C3 - same as C2 plus committee. The CPC-2A C4.1(k) 2e, 2f C3 2, 2b, 22 2b (how Big Rock Point meets N18.7 changes describing Big Rock C4.1 2c section 4.3.1; 4); C4.1 - same as Point change to an Restoration C4.1(b) 2d, C1; and 5) moves C4.1 (d) to C4.1 Safety Review Committee C4.1(i) 2e, 2f (b) and C4.1 (k) to C4.1 (i),

(RSRC) from an Independent respectively.

Safety Review Group (ISRG) is not a reduction in commitment because the new RSRC, as described, meets the N1i8.7 requirements for a standing committee.

132 APPENDIX C (Page 76)

APPENDIX C (Page 82)

C1. - FUNCTION C1. - FUNCTION

'i The Independent Safety Review Group The Restoration Safety Review Committee Reflects the change from an This is not a reduction in (ISRG) shall function to provide (RSRC) shall function to provide independent organizational unit (NPAD) to a commitment per independent review of activities in the areas review of activities in the areas of.

standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

of:

independent review activities.

a. Nuclear power plant

a. Nuclear power plant operation/decommissioning operation/decommissioning

b. Nuclear engineering

b. Nuclear engineering

c. Chemistry and radiochemistry

c. Chemistry and radiochemistry

d. Metallurgy

d. Metallurgy e Nondestructive testing

e. Nondestructive testing

f. Instrumentation and control

f. Instrumentation and control

g. Radiological safety

g. Radiological safety

h. Mechanical and electrical engineering

h. Mechanical and electrical engineering

i. Administrative controls and quality

i. Administrative controls and quality assurance practices assurance practices

j. Emergency Planning

j. Emergency Planning

k. Training

k. Training Page 46 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 133 I

APPENDIX C (Page 76)

APPENDIX C (Page 82)

Reflects the change from an ANSI/ANS N18.7-1976, as C2. - COMPOSITION C2. - COMPOSITION organizational unit (NPAD) to a endorsed by Regulatory Guide standing committee (RSRC) for 1.33 Rev. 2, provides The ISRG shall include the Manager, The RSRC shall report to the Senior Vice independent review activities, requirements for independent NPAD, who reports to the Vice President -

President, NFHO and shall consist of a review to be conducted by an NFHO, and a full-time staff of persons Chairman and members appointed by the organizational unit or a standing reporting to the Manager, NPAD and Senior Vice President - NFHO. RSRC committee. The CPC-2A designated as Nuclear Performance members shall meet or exceed the qualifications changes describing Big Rock Specialists for the ISR function. The described in Section 4.7 of ANSI/ANS 3.1-1987.

Point change to an Restoration Manager, NPAD, and the Nuclear The RSRC members shall have no direct Safety Review Committee Performance Specialists shall meet or responsibility for activities subject to their (RSRC) from an Independent exceed the qualifications described in review.

Safety Review Group (ISRG) is Section 4.7 of ANSI/ANS 3.1-1987. The not a reduction in commitment ISRG shall have no direct responsibility for because the new RSRC, as activities subject to its review, described, meets the N18.7 requirements for a standing committee.

134 APPENDIX C (Page 76)

APPENDIX C (Page 82 and 83)

Reflects the change from an ANSI/ANS N18.7-1976, as C3. - CONSULTANTS C3. -SUPPORT PERSONNEL organizational unit (NPAD) to a endorsed by Regulatory Guide standing committee (RSRC) for 1.33 Rev. 2, provides If sufficient expertise is not available within If sufficient expertise is not available within the independent review activities, requirements for independent the ISRG to review particular issues, the RSRC to review particular issues, the RSRC review to be conducted by an ISRG shall have the authority to utilize shall have the authority to utilize consultants or Maintains qualification requirements organizational unit or a standing consultants or other qualified organizations other qualified organizations for expert advice, and prohibits support personnel from committee. The CPC-2a for expert advice.

Support personnel shall meet or exceed the having direct responsibility for changes describing Palisades qualifications described in Section 4.7 of activities assigned for review, change to an Off-Site Safety ANSI/ANS 3.1-1987. Support personnel shall Review Committee (OSRC) have no direct responsibilit for activities they from an Independent Safety review.

Review Group (ISRG) is not a reduction in commitment because the new OSRC, as described, meets the N18.7 requirements for a standing

,.committee.

135 APPENDIX C (Page 77)

APPENDIX C (Page 83)'

Reflects the change from an This Is not a reduction in C4.1 - REVIEW C4.1 - REVIEW organizational unit (NPAD) to a commitment per standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

The ISRG shall review.

The RSRC shall review independent review activities.

Page 47 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 136 APPENDIX C (Page 77)

APPENDIX C (Page,83)

C4.1 - REVIEW C4.1 - REVIEW C4.1a., b., & c.

C4.1a.

a. The safety evaluations for:. 1) changes

a. 50.59 and 72.48 evaluations for proposed Adds 72.48 evaluations to reflect The addition of new information to procedures, equipment or systems, changes in the facility, procedures or conduct operation of ISFSI at Big Rock Point.

and commitments is not a and 2) tests or experiments completed of tests or experiments completed under the reduction In commitment.

under the provisions of 10 CFR 50.59 to provisions of 10 CFR 50.59 and 72.48 to verify that such actions do not constitute verify that an acceptable safety analysis is Replaced notion of unreviewed Editorial an unreviewed safety question.

provided and prior NRC approval was safety questions with concept of prior b Proposed changes to procedures, requested as required by 10 CFR 50.59 and NRC approval requested.

equipment or systems which involve an 72 48 unreviewed safety question as defined in 10 CFR 50.59.

c. Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50 59.

137 APPENDIX C (Page 77)

APPENDIX C (Page q3),

C4.1 - REVIEW C4.1 - REVIEW C4.1d.

C4.1b. & c.

Adds 72.48 evaluations to reflect The addition of new information

d. Proposed changes to Technical

b. Proposed changes to Technical operation of ISFSI at Big Rock Point.

and commitments is not a Specifications or the Operating License.

Specifications, the ISFSI License, or the reduction in commitment Spent Fuel Cask Storage System Certificate of Compliance to. verify that the changes are Separates Technical Specification Editorial consistent with applicable requirements and and the Operating License to two that an acceptable safety analysis is paragraphs (b and c).

provided.

c. Proposed changes to the Operating License.

138 APPENDIX C (Page 77)

APPENDIX C (Page 83)

C4.1 - REVIEW C4.1 - REVIEW C4.1e. Violations of codes, regulations, C4.1d. Violations of codes, regulations, orders, Adds *Cask Storage System The addition of new information orders, Technical Specifications, license Technical Specifications, license Certificate of Compliance' to reflect and commitments is not a requirements, or of internal procedures requirements, Cask Storage System operation of ISFSI at Big Rock Point.

reduction In commitment.

or instructions having nuclear safety Certificate of Compliance, or of internal significance procedures or instructions having nuclear safety significance.

Page 48 of 56

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion 139 APPENDIX C (Page 77)

APPENDIX C (Page 83)

C4.1 - REVIEW C4.1 - REVIEW C4.1f. Significant operating abnormalities C4.1e. Significant operating abnormalities or Added 'or the ISFSI" to reflect Editorial.

or deviations from normal and expected deviations from normal and expected conditions at Big Rock Point.

performance of unit equipment that performance of unit equipment or the ISFSI affects nuclear safety.

that affects nuclear safety.

140 APPENDIX C (Page 77)

APPENDIX C (Page 83)

Information related to Palisades was Deletion of Palisades C4.1 - REVIEW C4.1 - REVIEW removed from the Big Rock Point information has no impact on Specific Program.

Big Rock Point' commitments.

C4.1i. Reports and meeting minutes of the C4.1h. Reports and meeting minutes of the This is not a reduction in Plant Review Committee/Safety Review SRC.

commitment.

Committee.

Abbreviated Safety review Committee as SRC".

Editorial.

141 APPENDIX C (Page 77)

APPENDIX C (Page 83)

C4.1 - REVIEW C4.1 - REVIEW Information related to Palisades was Deletion of Palisades C4.1j. Fire Protection Program and C4.1j. Removed in its entirety. Remaining item removed from the Big Rock Point information has no impact on Implementing Procedure Changes renumbered Specific Program.

Big Rock Point' commitments.

(Palisades only).

This is not a reduction in commitment.

142 APPENDIX C (Page 77)

APPENDIX C (Page 83)i, C4.1 -. REVIEW C4.1 - REVIEW Last Paragraph, 1 st & 2nd sentences Last Paragraph, 1V & 2" sentences ISRG review of the subjects in C4 above RSRC review of the subjects In C4 above shall Reflects the change from an This Is not a reduction in shall be performed by an assigned Nuclear be performed by memlpers or support personnel organizational unit (NPAD) to a commitment per Performance Specialist selected on the selected on the basis of technical expertise standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

basis of technical expertise relative to the relative to the subject beirgg reviewed. If the independent review activities.

subject being reviewed. If the assigned assigned reviewer determines the need for Nuclear Performance Specialist determines interdisciplinary review, a committee consisting the need for interdisciplinary review, a of the RSRC Chairman, or his designate, and at committee consisting of the Manager, least four RSRC members or qualified support NPAD, or his designate, and at least four personnel, shall be assigned.

Nuclear Performance Specialists, shall be assigned.

Page 49 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 143 APPENDIX C (Page 77)

APPENDIX C (Page 84)

Reflects the change from an This is not a reduction in C5 - AUTHORITY C5 - AUTHORITY organizational unit (NPAD) to a commitment per standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

The ISRG shall report to and advise the The RSRC shall report to and advise the Senior independent review activities.

Vice-President, NFHO, of significant Vice-President, NFHO, of significant findings findings associated with those areas of associated with those areas of responsibility Reflects a title change from "Vice-Editorial.

responsibility specified in C4 above and specified in C4 above and Appendix D, Audit President, NFHO" to 'Senior Vice Appendix D, Audit Frequencies.

Frequencies.

President, NFHO ".

144 APPENDIX C (Page 77)

APPENDIX C (Page 84)

Reflects the change from an This Is not a reduction in C6 - RECORDS C6 - RECORDS organizational unit (NPAD) to a commitment per standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

Records of ISRG activities shall be Records of RSRC activities shall be maintained, independent review activities.

maintained. Reports shall be prepared and Reports shall be prepared and distributed as distributed as indicated below.

indicated below Reflects a title change from 'Vice-Editorial.

President, NFHO" to 'Senior Vice

a.

The results of reviews performed

a. The results of reviews performed pursuant President, NFHO.

pursuant to C4 above shall be reported to C4 above shall be reported to the Senior to the Vice-President, NFHO, at least Vice-President, NFHO, at least monthly.

monthly.

b. A report assessing Big Rock's overall

b.

A report assessing each plant's overall nuclear safety performance shall be nuclear safety performance shall be provided to senior Consumers Energy provided to senior Consumers Energy management annually.

management annually.

145 APPENDIX D (Page 79)

APPENDIX D (Page 85)

Removed "QPD Manual" from the Editorial.

Title Title title.

QPD MANUAL APPENDIX D APPENDIX D AUDIT FREQUENCIES IAUDIT FREQUENCIES Page 50 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 146 APPENDIX D (Page 79)

APPENDIX D (Page 85)

DI. -AUDITS D1. -AUDITS Paragraph 1 Paragraph 1 Audits of operational and decommissioning Audits of operational and decommissioning Reflects the change from an This is not a reduction in activities subject to this Program are activities subject to this Program are performed organizational unit (NPAD) to a commitment per performed by the NPAD staff under the by the NPAD staff under the cognizance of the standing committee (RSRC) for 10 CFR 50.54(a)(3)(vi).

cognizance of Nuclear Performance RSRC. These audits encompass:

independent review activities.

Specialists. These audits encompass:

147 APPENDIX D (Page 79)

APPENDIX D (Page 85)

DIa.. - AUDITS DI.a. -AUDITS The conformance of plant operation to The conformance of plant operation to Added, "the Spent Fuel Storage The addition of new information provisions contained within the Technical provisions contained within the Technical Cask System Certificate of and commitments is not a Specifications and applicable license Specifications, applicable license conditions, Compliance' to reflect the condition reduction in commitment.

conditions at least once per 12 months.

and the Spent Fuel Storage Cask System of Big Rock Point.

Certificate of Compliance at least once per 12 months.

148 APPENDIX D (Page 79)

APPENDIX D (Page 85)

D1.c. - AUDITS DI.c. -AUDITS r

The performance of activities required by The performance of activities required by the Abbreviated "Quality Program Editorial.

the Quality Program Description for QPD for Nuclear Power Plants (CPC-2A) to Description" as "QPD'.

Operational Nuclear Power Plants (CPC-meet the criteria of 10 CFR 50, Appendix B at 2A) to meet the criteria of 10 CFR 50, least once per 24 months.

Appendix B at least once per 24 months.

149 APPENDIX D (Page 79)

APPENDIX D (Page 85)

Added, "/ISFSI" to reflect the The addition of new information D1.f. -AUDITS D1.f. -AUDITS condition of Big Rock Point.

and commitments is not a Paragraph 1 Paragraph I reduction in commitment.

Any other area of plant operation Any other area of plant/ISFSI operation Reflects a title change from 'Vice-Editorial.

considered appropriate by NPAD or the considered appropriate by NPAD or the Senior President, NFHO" to "Senior Vice Vice President - NFHO.

Vice President, NFHO.

President, NFHO".

Page 51 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 150 APPENDIX E (Page 80)

APPENDIX E (Page 87)

Title Title QPD MANUAL APPENDIX E Removed "QPD Manual' from the Editorial.

APPENDIX E RECORD RETENTION title.

RECORD RETENTION 151 APPENDIX E (Page 80)

APPENDIX E (Page 87)

El.

El.

Paragraph 1 Paragraph I In addition to the applicable record In addition to the applicable record retention Added 2Id sentence to reflect 10CFR The addition of new information retention requirements of Title 10, Code of requirements of Title 10, Code of Federal 72 record retention requirements.

and commitments is not a Federal Regulations, the following records Regulations, the following records shall be reduction in commitment.

shall be retained for at least the minimum retained for at least the minimum period period indicated:

indicated. Where 10CFR 72 or the Part 72 license conditions do not specify a retention period for a record, the records shall be retained until the NRC terminates the license.

152 APPENDIX E (Page 80)

APPENDIX E (Page 87)

E2.c. All reportable events as defined in 10 E2.c. All reportable events as defined in 10 CFR Added reference to 72.74, and 72.75.

The addition of new information CFR 50.72 and 50.73.

50.72, 50.73, 72.74, and 72.75.

and commitments is not a reduction in commitment.

153 APPENDIX E (Page 80)

APPENDIX E (Page 87)

E3.

E3.

The following records shall be retained for The following recordsshall be retained for the Added reference to Part 72.

The addition of new information the duration of the Facility 10 CFR 50 duration of the Facility 10 CFR 50 or Part 72 and commitments is not a License:

License:

reduction in commitment.

154 APPENDIX E (Page 80)

APPENDIX E (Page 87)

Information related to Palisades was Deletion of Palisades removed from the Big Rock Point information has no impact on E3.a. Record and drawing changes E3.a. Record and drawing changes reflecting Specific Program.

Big Rock Point' commitments.

reflecting facility design modifications made facility design modificatigns made to systems This is not a reduction in to systems and equipment described in the and equipment described in the BRP UFHSR.

commitment.

Palisades Updated Final Safety Analysis A

Report or Big Rock Point Updated Final Abbreviated Big Rock Point Updated Editorial Hazards Summary Report.

Final Hazards SummarynReport

_I Page 52 of 56

Item Revision 19 Revision 20 Reason for Change Basis for Conclusion 1 5 5 APPENDIX E (Page 80)

APPENDIX E (Page 88)

E3.g. Records of Quality Assurance E3.g. ecords of Quality Assurance activities Abbreviated "Quality Program Editorial.

activities required by the Quality Program required by the QPD.

Description' as "QPD".

Description.

156 APPENDIX E (Page 80)

APPENDIX E (Page 88)

E3.h. Records of reviews performed for E3.h. Records of reviews performed for changes Added reference to 10 CFR 72.48.

The addition of new information changes made to procedures or equipment, made to procedures or equipment, or reviews of and commitments is not a or reviews of tests and experiments tests and experiments pursuant to 10 CFR reduction in commitment.

pursuant to 10 CFR 50.59 and 10 CFR 50.59, 10 CFR 50.82 and 72.48.

50.82.

157 APPENDIX E (Page 80)

APPENDIX E (Page 86)

Information related to Palisades was Deletion of Palisades removed from the Big Rock Point information has no impact on E3.1. Records of meetings of the PRC/SRC, E3.1 Records of meetings of the SRC, and Specific Program.

Big Rock Point's commitments.

and reviews performed by NPAD, according reviews performed by the RSRC, according to This is not a reduction in to Appendixes B and C.

Appendices B and C.

commitment.

Reflects the change from an organizational unit (NPAD) to a This is not a reduction in standing committee (RSRC) for commitment per independent review activities.

10 CFR 50.54(a)(3)(vi).

158 APPENDIX E (Page 81)

APPENDIX E (Page 88)

Information related to Palisades was Deletion of Palisades removed from the Big Rock Point information has no impact on E.3.k Records of secondary water sampling E3.k. Removed in its entirety. Remaining items Specific Program.

Big Rock Point's commitments.

and quality (Palisades only) renumbered.

This is not a reduction in commitment.

159 APPENDIX E (Page 81)

APPENDIX E (Page 88)

E.3.1. - Records of the service lives of all E3.1. Removed in its entirety. Remaining items Information related to Palisades was Deletion of Palisades hydraulic and mechanical snubbers renumbered.

F removed from the Big Rock Point information has no impact on covered by Technical Specifications. This Specific Program.

Big Rock Point's commitments.

shall include the date at which the service This is not a reduction in life commences and associated installation commitment.

and maintenance records (Palisades only)

Page 53 of 56

Page 54 of 56 Item Revision 19 Revision 20 Reason for Chancte Basis for Conclusion 160 APPENDIX E (Page 81)

APPENDIX E (Page 88)

E4.

E4. The following records shall be retained as Reflects Big Rock Point ISFSI.

The addition of new information long as the associated material Is stored Meets the intent of 10 CFR 72.48.

and commitments is not a Blank and for a period of five years after the reduction in commitment.

material is transferred out of the ISFSI:

a.

Records of receipt, inventory (including location), disposal, acquisition, and transfer of all spent fuel and high level waste in storage.

161 APPENDIX E (Page 81)

APPENDIX E (Page 88)

E5.

E5. The following records shall be retained until Reflects Big Rock Point ISFSI.

The addition of new information the NRC terminates the 10 CFR Part 72 Meets the intent of 10 CFR 72.48.

and commitments is not a Blank General License forithe ISFSI:

reduction in commitment.

a.

Records of the current inventory of all spent fuel and high-level waste.

b.

Current material control and accounting procedures.

c.

ISFSI and Cask Storage System records pertaining to the design, fabrication, erection, testing, tnaintenance, and use of structures systems and components important to safety..'I

Item Revision 19 Revision 20 Reason for Chan-ge Basis for Conclusion APPENDIX E (Page 81)

E6.

Blank 162 Reflects Big Rock Point ISFSI.

Meets the intent of 10 CFR 72.48.

The addition of new information and commitments is not a reduction in commitment.

I __________________________________________

L _____________________________

Page 55 of 56 APPENDIX E (Pages 88-89)

E6.

The following records shall be retained and forwarded to the appropriate NRC Regional Office prior to the ISFSI General License termination:

a.

Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment or site. These records may be limited to instances when contamination remains after any clean-up procedures or when there is a reasonable likelihood that contaminants may have spread to inaccessible areas as in the case of possible seeppge into porous materials such as concrete. The records must include any known informatibno on identification of involved nyclides, quantities, forms, and concentrations.

b.

As-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored, and of locations of possible inaccessible contamination such as buried pipes which may be subject to contamination. If required drawings are 'referenced, each relevant document need not be indexed individually. If drawings are not available, the licensee shall substitute appropriate records of available infprmation concerning these areas, and locations.

Item Revision19 Revision 20 Reason for Changte Basis for Conclusion APPENDIX E (Page 81)

E6.

Blank I__L_

_II APPENDIX E (Page-89)

E6.

c.

A list contained in a single document and updated no less than every 2 years of the following:

(1) All areas designated and formerly designated as restricted areas as defined under 10 CFR 20.1003; and (2) All areas outside of restricted areas that require documentation under 10 CFR 72.30(d)(1).

d.

Records of the cost estimate performed for the decommissioning funding plan or of the amount certified for decommissioning, and records of the funding method used for assuring funds if either a funding plan or certification is used.

e.

Records of the results of measurements and calculations used to evaluate the release of radioactive effluents to the environment. This includes those records of the results of measurements and calculations used to evaluate the release of radioactive effluents to the environment under the standards for protection against radiation in effect prior to January 1, 1994.

Reflects Big Rock Point ISFSI.

Meets the intent of 10 CFR 72.48.

The addition of new information and commitments is not a reduction in commitment.

Page 56 of 56 163