ML18054B043

Forwards Revs 9 & 10 to CPC-2A, QA Program Description for Operational Nuclear Power Plants. Lists of Affected Pages in Revs 9 & 10 & Change Matrices Encl

ML18054B043
Person / Time
Site:	Palisades, Big Rock Point, 05000000
Issue date:	10/19/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18054B044	List: ML18054B043
References
NUDOCS 8910240124
Download: ML18054B043 (16)

Text

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consumers Power Kenneth W Berry Dirtctor POWERIN& Nuclear licensing MICHl&AN'S PRO&RESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 o (517) 788-1636 October 19, 1989 Nuclear Regulatory Connnission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TOPICAL REPORT CPC-2A (REVISIONS 9 AND 10) QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS Attached are Revisions 9 and 10 of Consumers Power Company Topical Report CPC-2A, Quality Assurance Program Description for Operational Nuclear Power Plants. Revision 9, dated April 1, 1989, and Revision 10, dated October 1, 1989, are Consumers Power Company's annual report being submitted in accordance with 10CFR50.54(A)(3). Also enclosed as Attachments 1 throu~h 4 are lists of affected pages in Revisions 9 and 10 and change matrices comparing Revision 9 with Revision 8 and Revision 10 with Revision 9.

The matrices present the changes made, the reasons for the changes, and the basis for concluding they do not constitute a reduction in our QA Pro~ram commitments. Some of the changes had previously been submitted for, and received, NRC approval. These are clearly indicated in the matrix.

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspectors - Big Rock Point & Palisades Attachments OC1089-0209-NL04 cr- ~ 10~1--o121--

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ATTACHMENTS Consumers Power Company Big Rock Point & Palisades Plants Dockets 50-155 & 50-255

1. Attachment 1 ~~List of pages changed in Rev 9

2. Attachment 2 - Matrix drawing changes made from Rev 8 to Rev 9

3. Attachment 3 - List of pages changed in Revision 10

4. Attachment 4 - Matrix showing changes made from Rev 9 to Rev 10

5. Information copies of CPC-2A, Rev 9

6. Information copies of CPC-2A, Rev 10 October 19, 1989 193 Pages OC1089-0209-NL04

• -*---*---*~---- ____- : - : : - :,.~

ATTACHMENT 1 List of CPC-2A pages changed in Revision 9 Statement of Responsibility and Authority Approval Page 2

3 4

5 6

8 9

10 14 15 23

ATTACHMENT 2 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Basis for Conclusion Revision 9 Reason for Change Revision 8 1 , I

,1.

CllVt!f Ltitl('I' Covr.r 1.ett11r 2nd Paragraph 5.nd llaragrnEh This change recognizes that the The organization described I have delegated the authority I have delegated the authority in the QAPD continues to for the establishment and main- VP-NO is part of the management for the establishment and main- chain with the responsibility meet Criterion I of 10CFR50 tenance of the Quality Assurance tenance of the Quality Assurance Appendix B, in that no Program Description through the and authority for the QA Program.

Program Description to the This has always been the case, changes to the previously Senior Vice President, Energy Senior Vice President, Energy approved organization Supply to the Vice President, but the cover letter did not Supply for operational phase show it. structure have been made.

activities and plant modifi- Nuclear Operations for opera-cations, and in turn to the tional phase activities and plant Director, Quality Assurance. modifications, and in turn to the The Director, Quality Assurance Director, Quality Assurance. The is also authorized to verify Director, Quality Assurance is the effective implementation also authorized to verify the of the Quality Assurance effective implementation of the Program Description. Quality Assurance Program Des-cription.

2 Page 21 Page 2, 1.2.2.a, 5th and 6th Paragraph 1.2.2.a, 5th Paragraph This change recognizes that the Changes related to QA for pro-.

At Big Rock Point, procurement Control of plant initiated pro- curement were reviewed by NRC curement, including preparation, organizational restructuring planning for the plant includ- for procurement that was as part of its review of Revi-ing preparati.on of and obtain- reviews and approval of purchase sion 8. Subject to the clari-requests for spares, replacement recognized in Revision 8 for ing the required reviews and Palisades has now been im- fications indicated in its approval of purchase requests items, consumables, and materi- letter dated August 2 1 1989, als, items and services. Con- plemented at Big Rock Point for spares, replacement items Plant, as well. NRC has determined that the and consumables; and materials, trol also includes submittal of CP Co QAPD continues to meet items and services for minor purchase requests to Purchasing, 10CFR50 1 Appendix B.

modifications; and submittal vendor surveys for urgent pro-of purchase request packages curements, planning and execu-tion of source surve 11 lance or to Purchasing for procurement inspection, receiving inspection, actions. and review of supplier quality-At Palisades, control of pro- related documentation.

curement for plant, including preparation, reviews and approval of purchase requests for spares, replacements items, consumables, and materials, items and services for minor modifications. Control also includes submittal of purchase requests to Purchasing, vendor surveys for urgent procurements, planning and execution of source surveillance or inspection, re-*

ceiving inspection, and review of supplier quality-related documentation.

MI0989-0125A-QA01

ATTACHMENT 2 . '

QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Revision 8 Revision 9 Reason for Change Basis for Conclusion fa9e 2

, , 2.11 1 6th P1m11r11ph Not addressed. Functioning as the Company de- This change completes an INPO The QAPD, as revised, con-sign and configuration control commitment to clearly identify tinues to meet Criterion I of authority for compliance of each plant as having design Appendix B, in that the plant modifications and design and configuration control authorities and duties of per-changes to existing plan.t

• authority. sons and organizations per- .

design criteria. forming activities affecting the safety-related functions of structures, systems and components are clearly estal>-

blished and delineated in 4 writing.

Page 2, 1.2.2.a, 7th Paragraph Page 2, 1.2.2.a, 7th Paragraph Project responsibility for minor Project responsibility for modi- In conjunction with item (3), See Item 3.

modifications including design, fications, including design, and other changes herein, this procurement, construction and procurements, construction and change recogn.izes the plants as testing activities, whether testing activities as assigned having ultimate control of modi-performed by CP Co or by out- by the Plant General Manager/ fications, and also removes the side contractors. Manager. distinction between "major" and "minor."

5 Page 3 Page 2 1.2.2.a, 9th Paragraph 1.2.2.a, 9th Paragraph Development and maintenance of Developing and maintaining Plant This change is p1Jrely editorial, See Item 3.

Plant Security Plans and Security Plans and administering at the request of the involved contract administration for the contract(s) for the security management, to make the wording the security force, force. parallel that of the remainder of the Section.

6 Page 3, Page 3 Paragraph 1.7 1.2.2.1, 17th Paragraph Not in this revision. Developing and maintaining The responsibility for this See Item 3.

Plant l"ire Protection Plans. function was shifted from the Facilities and Automotive Department, as formerly indi-cated in Section 1.2.4.a, to each plant. See item 14.

MI0989-0125A-QA01

. . --.:....... ~.*..~ ... i., . .*. *-*~

ATTACHMENT 2 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Revision 8 Revision 9 Reason for Change Basis for Conclusion 7

~ ~

~b, 1st Paragraph ~b, 1st and 2nd Paragraphs Performance of the offsite Performance of the offsite This change clarifies the re- See Item 3.

r 1*

safety review functions for safety review functions for sponsibilities of the NSSD with v.j. ~

• /

the nuclear power plants as the nuclear power plants as re*spect to PRA and its uses in described in plant technical described in plant technical severe accident management and specifications, and probabi- specifications. plant reliability improvement.

listic *risk assessment.

Development and maintenance of nuclear plant probabilistic risk assessment models and application of PRA technology to severe accident management and plant reliability improve-ment.

8 Page 4

!.:1.:2 The Vice President, Energy The Vice President, Energy This change, in conjunction with See Item 3.

Supply Services (see Figure 6) Supply Services (see Figure 6) item (3) and others herein, is responsible to the Senior is responsible to the Senior recognizes the plants as "design Vice President, Energy Supply Vice President, Energy Supply authority," and clarifies that for certain services, includ-* for certain services, including ESS will perform such work as ing standards for calibration standards for calibration of authorized and requested by of M&TE, operating the per- M&TE, operating the personnel Nuclear Operations.

sonnel dosimetry laboratory dosimetry laboratory and per-and major modifications to forming assigned modifications CP Co nuclear power plants. to CP Co nuclear power plants.

Directors and Managers re- Directors and Managers report-porting to him are responsible. ing to him are responsible for for directing the performance .directing the performance of of activities in accordance ' activities in accordance with with QA Program requirements. QA Program requirements.

9 Page/ ~

• *

• b, 1st Paragraph ~b, 1st Paragraph Performing the construction, Performing the construction, See Item 8. See Item 3.

preoperational testing and preoperational testing and overall project management overall project management of of generating plant major assigned generating plant modi-modification projects. fication projects.

MI0989-0125A-QA01

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ATTACHMENT 2 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Basis for Conclusion Reason for Change Revision 8 Revision 9 10 Page 6 Page 5 1.2.3.c 1.2.3.c See Item 3.

The Manager, Field Maintenance See Item 8.

The Manager, Field Maintenance Services provides Field Main-Services provides Field Main- tenance Services for assigned tenance Services for major modifications and plant outages.

modifications and plant outages.

11 Page 6 Page 6 1.2.3.d, 1st Paragraph 1.2.3.d., 1st Paragraph See Item 8. Since each plant See Item 3.

Performing the engineering of Performing the engineering is designated as "design generating plant modification associated with genera.ting

• authority," it will determine plant modification projects which organization, if not projects. This includes as assigned by the Plant functioning, as appropriate, itself, may handle lead design as either the lead design General Manager/Manager. or design reviewer functions.

organization when such projects In all cases, the plant will are engineered in-house or as retain its "design authority."

the Company's design reviewer when those projects are done by outside engineering organizations.

12 Page 6 Page 6 1.2.3.e, 1st Paragraph 1.2.3.e, 1st Paragraph This change is.editorial, at the See Item 3.

Maintaining the Records Manage- Maintaining the Records Manage-ment System including required request of the involved manage-ment System including required retention, protection and re- ment, to provide a more clearly retention, protection and re- worded treatment of responsibili-trievability, operating the trievability, operating the General Office (offsite) ties.

General Office (offsite) Document Control Center and Document Control Center and Engineering Records Center, for ma~ntaining the Uniform and for maintaining the Uniform File Index. This includes collecting, storing, main- File Index. Thfs includes collecting, storing, maintaining, taining, distributing and distributing and controlling controlling plant engineering/

design documents through the plant engineering/design Engineering Records Center. documents.

MI0989-0125A-QA01

ATTACHMENT 2 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Basis for Conclusion Revision 9 Reason for Change Revision 8 Page 6 Page 6 '

1.2.4 1.2.4 j.

See Item 8. See Item 3.

Certain functions that consti- }

Certaf.n functions that consti-

~

tute part of the Nuclear Opera- tute part of the Nuclear Opera-tions QA Program are performed _tions QA Program are performed  :*

by CP Co organizational units by CP Co organizational units outside the Nuclear Operations outside the Nuclear Operations Department or Energy Supply Department or Energy Supply Services, as follows: Services. Engineering and de-.

sign tasks executed in support of plant .activities are subject to review and acceptance by the associated plant organization responsible for that activity (as the-design authority).

14 Page 6

1. 2.4.a lbe responslbllty for develop- See Item 3.

The Manager, Facilities and Not in this revision.

ment and maintenance of fire Automotive (see Figure 5) is protection plans was transferred responsible through the Vice. to each plant. Since Facilities President, Corporate Services and Automotive had no other

• to the President and c.o.o. for identified functions, it ls developing and maintaining the deleted from CPC-2A.

Fire Protection Plans for the nuclear power plants.

15 Page 6 Page 6 1.2.4.b 1.2.4.a See Item 3.

The Manager, Administrative The Director, Administrative Title change only.

Opera~ions and Planning (see Operations and Planning (see Figure 5) is responsible Figure 5) is responsible through through the Vice President, the Vice President, Corporate Corporate Services to the Services to the President and President and C.O.O. for Chief Operating Officer for microfilming of specified microfilming of specified QA QA records and plant engi- records and plant engineering/

neering/design documents. design documents.

HI0989-0125A-QA01

ATTACHMENT 2  : .

QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A) .

.i

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Revision 8 Revision 9 Reason for Change Basis for Conclusion 16 ,.

~

r.2-:-51 9th Paragraph Not in this revisf.on. QA engineering associated with This change recognizes that the See Item 3.

modification design, procurement, functions identified could be construction and testing, in- performed by either (or both) cluding verification that plant or General Office QA staff.

quality-related test prerequi- Thus, the description is elevated*

sites have been accomplished, to be listed under the Director, identification and participa- QA, instead of twice under both tion in resolution of installa- plant and GO QA.

tion inspection and test problems and nonconformances, and maintenance and reporting of status of hardware and test quality and corrective action.

(This function will* be carried out by plant and/or general office QA staff, as assigned by the Director, QA.)

17 Page 9 Page 9 1.2.5.a, 5th Paragraph 1.2.5.a At Big Rock Point, review of Not in this revision. See Item 2. See Item 2.

and concurrence with quality requirements of procurement request packages for plant site-originated procurements.

18 Page 9 Page 9 1.2.5.a, 9th Paragraph 1.2.5.a, 6th Paragraph Plant site quality control Plant site quality control See Item 2. See Item 2.

inspe~tion program, including inspection program, including receiving inspection (at Big inspection of maintenance, Rock) and inspection of main- modifications, testing and tenance, modifications, fuel handling.

testing and fuel handling.

MI0989-0125A-QA01

ATTACHMENT 2 i;~**

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QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A) f.,'*.

Revision 8 Revision 9 Reason for Change Basis for Conclusion 19 r11gt1 io ~

1.2.~.li r.r.-J."b i

Quality Assurance Support Quality Assurance Section Heads The listing for modification See Item 3.

Section Heads (Corporate Office) (Corporate Office) are responsi- design and* procurement was are responsible to the Director, ble to the Director, Quality elevated to the listing under Quality Assurance for the Assurance for the Nuclear the Director, QA. See Item 16.

Nuclear Operations QA Audit Operations QA audit program, Other changes are editorial Program, QA Program Dev.elop- QA program development, and only.

ment, Corporate Office QA special studies including the Engineering for modifications following:

Design and Procurement and Special Studies including the following:

20 Page 10 Page 10 1.2.5.b, 13th Paragraph 1.2.5.b Corporate Office QA Engineering Not in this revision. This item was elevated to be See Item 3.

associated with modification listed under the Director, QA, design a~d procurement, including as the function could be per-preparation of necessary quality formed by either plant or assurance plans for integration General Office QA, or both, as with project plans, performance directed. Some supplier veri-of source surveillance/inspection fications may also be performed at supplier facilities, review of by the plant staff per item (2).

supplier quality-related docu-mentation and maintenance and reporting of status of hardware and test quality and corrective action (offsite),

21 Page 14 Page 14 ',I I.

Figure 4 Figure 4 Title Box: Title Box: This change recognizes the dele- See Item 3.

tion of "support" as part of the "QA Support "General Office QA Department Title for QA. This Section Heads" Section Heads" is editorial; the reporting relationships previously existing were not affected.

MI0989-0125A-QA01

ATTACHMENT 2 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Basis for Conclusion Revision 9 Reason for Change Revision 8

\.

Page 15 Page 15 Figure 5 t:.

Figure 5 See Item 3.

One title box for Manager See Item 14 and Item 15.

Eliminated Manager Facilities Facilities and Automotive and Automotive from chart. under Vice President. Also Changed one title to Director Manager Administrative Opera-Administrative Operations tions and Planning.

and Planning.

23 Page 23 Page 23 Bd Bd See Item 3.

Authority and responsibility See Item 8.

Authority and responsibility for modification activities is for modification activities under the cognizance of the under the cognizance of the Nuclear Operations Department Nuclear Operations Department and the Energy Supply Services as described in Section l.O, Departments are described in ORGANIZATION. This authority Section 1.0, ORGANIZATION. and responsibility includes

'Illis authority and responsi- the preparation, review, approv-bility includes the prepara- al and verification of the following design documents:

tion, review, approval and a) System descriptions; b) verification of the following design documents: a) System Design input and criteria; c) Drawings-and specifications; descriptions; b) Design input and d) Engineering analyses and criteria; c) Drawings and and associated computer pro-specifications; and d) Engi-neering analyses and associated grams.

computer programs.

MI0989-0125A-QA01

ATTACHMENT ~

List of CPC-2A pages changed in Revision 10 Approval Page 4

5 9

16 20 53 67 69 70

ATTACHMENT 4 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Revision 9 Revision 10 Reason for Change Basis for Conclusion ... '..:/

Pase 4 ~ .

• *2* b, Paragraph I+ ~b, Paragraph I+ j.

r' Assessing the effectiveness of the Assessing the effectiveness of the Due to a reorganization, The function ls still Corporate Health Physics program Corporate Health Physics program the Dosimetry Laboratory being performed; it is and maintaining standards for con- and maintaining standards for con- now reports to the Corpor- just the responsibility trol of Radiological Materials and trol of Radiological Materials and ate Health Physicist who of a different department.

personnel exposure and recommending personnel .exposure and recommending is a member of the staff ....

program improvements to reduce on- program improvements to reduce on- of the Nuclear Safety *-:"

si te and of fsite radiation expos- si te and offsite radiation expos- Services Department.

ure caused by plant operations. ure caused by plant operations, operating the Dosimetry Laboratory

• and maintaining records of person- 11 I.

nel radiation exposure.

Page I+

1.2.3.

Page 4 1.2.3

- ,,~J The Vice President, Energy Supply The Vice President, Energy Supply The Dosimetry Laboratory See item above.

Services (see Figure 6) is respon- Services (see Figure 6) is responsi- is now under Nuclear Opera-sible to the Senior Vice President, ble to the Senior Vice President, tions rather than Energy Energy Supply for certain services, Energy Supply for certain services, Supply Services.

including standards for calibra- including standards for calibration tion of M&TE, operating the per- of M&TE, and performing assigned sonnel dosimetry laboratory and modifications to CPCo nuclear power performing assigned modifications plants. Directors and Managers to CPCo nuclear power plants.* reporting to him are responsible for Directors and Managers reporting to directing the performance of activi-him are responsible for directing ties in accordance with QA Program the performance of activities in requirements.

accordance with QA program requirements.

Page I+ Page 4 1.2.3.a 1.2.3.a The Manager, Laboratory and Field The Manager, Energy Supply Technical Title change. Merely a change in the Services (L&FTS) is responsible, Services (ESTS) is responsible, name of the department.

througJt personnel reporting to him, through personnel reporting to him, for: for:

ra~el

• • • a, Paragraphs I+ and 5

~

~a, Paragraphs I+ and 5 Controlling the calibration recall Controlling the calibration recall Title change. Merely a change in the system for Portable and Laboratory system for Portable and Laboratory name of the department.

M&TE owned by L&FTS, and other M&TE owned by ESTS, and other departments, as requested~ departments, as requested.

Maintaining a Master PL-M&TE List Maintaining a Master PL-M&TE List for L&FTS PL-M&TE and for other for ESTS PL-M&TE and for other departments, as requested. departments, as requested.

MI0909-0009A-QA06

ATTACHMENT 4 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Revision 9 Revision 10 Reason for Change Basis for Conclusion Page 5 Page S I 1.2.3.a, Paragraph 9 1.2.3.a, Paragraph 9 Operating the Dosimetry Laboratory Not in this revision. Resporis~~ility transferred See Item 1.

(including preparation arid main-tenance of occupational radiation and exposure records).

~ ~

~a, Paragraph 5* *-i-~~a, Paragraph 5 Review and concurrence with pro- Review and concurrence with pro- Clarification of QC's role QC's responsibility has curement quality requirements for curement quality requirements for since receipt inspection not changed. This is nuclear fuel, source audit/surveil- nuclear fuel, source audit/surveil- is normally performed by just a clarification.

lance/inspection at fuel supplier lance/inspection at fuel supplier Material Management except facilities, fuel receiving inspec- facilities, fuel inspection upon

• for fuel.

tion, and review of fuel supplier delivery, and review of fuel sup-quality-related documentation. plier quality-related documentation.

Page 16 Page 16 Figure 6 Figure 6 Title is Manager, Lab and Field Shows the title change to Manager, Title change. Merely a change in the Technical Services. Energy Supply Technical Services. name of the department.

Page 20 2.2.9.i Not in this revision. The Quality Assurance Department Agreement with NRC con- Prior NRC approval.

provides training in quality assur- tained in August 2, 1989 ance principles related to procure- letter from Chief, Opera-ment for those personnel performing tions Branch, Division of procurement documents, source veri- Reactor Safety, Region III.

fication and receipt inspection.

Page 53 15.2.1.e The Quality Assurance Department verif(es through audit or surveil-lance that, when it is not "the original inspection planning auth-ority, the dispositions of 15.2.1.b Page 53

15. 2.1.e The Quality Assurance Department reviews "use as is" or "repair"

-dispositions which result in devi-ation from original design or specification requirements.

Agreemunt tained in letter in letter of I

with NRC con*

August 2, 1989 response to our Hay 19, 1989.

Prior NRC approval per 8/2/89 letter.

• and the alternate acceptance cri-teria of 15.2.1.c are being prop-erly performed and reviewed.

HI0909-0009A-QA06

ATTACHMENT 4 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

,1 Revision 9 Revision 10. Reason for Change Basis for Conclusion Pa15e 67 1fx.ccrlon/Int@rprl!t11tion 2.m Sec .1.15 '*

Not in this revision. Requirement The change allows greater Prior NRC approval per Plant procedures shall be reviewed flexibility in how the 8/2/89 letter.

by an individual knowledgeable in biennial r.eview require-the area affected by the procedure ment can be met. It will no less frequently than every two allow for follow-up reviews years to determine if changes are to be done by persons most necessary or desirable. likely to notice procedural ~ 'J inadequacies.

Exception/Inter~retation Based on amplif cation provided in ANSI/ANS 3.2-1982, Section 5.2.15, Consumers Power Company interprets that this requirement for routine follow-up review can be accomplished in several ways, including (but not limited to): documented step-by-step checkoff associated with it) or detailed scrutiny of the proce- _,;

dure as part of a documented train- ..."

ing program, drill, simulator exercise, or other s*uch activity. ,.~:

Page 67 . Page 67 Exception/Interpretation 2.m-2.o Exception/Interpretation 2.m-2.p See Revision 10. Renumbered due to new 2.m. Renumbering only. Renumbering only.

Page 69 and 70 Exception/Interpretation 3.b RG 1.33, Sec C.4.b Not in this revision. Requirement The change is requested to Approved per NRC establish scope and fre- letter of 8/2/89.

The conformance of facility quency controls for audits operations to provisions con- of plant Technical Specifi-tained within the technical cation requirements. It specifications and applicable provides for the division license conditions - at least of Tech Spec requirements once per 12 months. into specific areas, and the complete coverage of Exception/Interpretation the entire Tech Specs over a 5 year span (maximum).

Consistent with guidance pre- It is consistent with the sented in NRC letters dated NRC guidance referenced in March 29, 1983 (RLSpessard to the change.

JMTaylor) and January 30, 1984 HI0909-0009A-QA06

ATTACHMENT 4 QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

Revision 9 Revision 10 Reason for Change Basis for Conclusion ,

(JGPartlow to RLSpessard), Con-sumers Power Company interprets the comn1itment to audit techni-cal specification/license con-ditions contained in 18.2.2(a)

I of this QAPD, and in Section 6.5.2.S(a) of both Palisades r:**.

and Big Rock Point Technical Specifications, as follows:

.\:.

Consumers Power Company main-tains a matrix that identifies I, all applicable Technical Speci- ,*

fication line items to be audi- i~

ted. The matrix is updated annually to conform to approved Technical Specification changes.

During each 12 month period, a selected sample of line items in each of the following elements "

~

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. Onsite Committee

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 com-pliance history.

MI0909-0009A-QA06