ML18058B882

Rev 13 to Quality Program Description for Operational Nuclear Power Plants.

ML18058B882
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	06/15/1993
From:	Hoffman D, Morris M, Nicholson R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18058B881	List: ML18058B879 ML18058B882
References
CPC-2A, NUDOCS 9306230036
Download: ML18058B882 (99)

Text

Quality

• Program. Description for Operational N uclea.r Power Plants CPC-2A BICI ROCK POINT NUSflDES

• consumers Power POWERIN&

NllCHl&AN"S PROliRE55 General Offices: 212 West Michigan Avenue, Jackson, Ml 49201 * (517) 788-111.1 Frederick W Buckman President and Chief Executive Officer

SUBJECT:

STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMPANY QUALITY PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As President and Chief Executive Officer of Consumers Power Company, I have the ultimate management authority for the Consumers Power Company Quality Program Description for Operational Nuclear Power Plants. The Quality Program Description complies with the quality assurance requirements con-tained in Appendix B of 10CFR50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the additional guidance contained in ANSI Nl8.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of applicability imposed by NlB.7. The Quality Program Description for Operational Nuclear Power Plants outlines the actions that are implemented during the operational phase including fueling, testing, operation, refueling, procurement, mainte-nance, repair, and modification design and construction of the safety-related portions of the nuclear power plants.

I have delegated responsibility for establishing, maintaining and implement-ing the Quality Program Description through the Executive Vice President and Chief Operating Officer of Consumers Power Company to the Vice President, Nuclear Operations, Environmental and Technical Services. I have delegated selected portions of the Quality Program to the Vice President, Fossil and Hydro Operations; Vice President, Human Resources; Vice President, Electric Transmission; and through the Vice Chairman of Consumers Power Company to the Corporate Secretary. This Quality Program Description describes the Consumers Power Company organizations responsible for implementation.

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

A CMS ENERGY COMPANY

Page i i Rev 13 Date: 06/15/93 QUALITY PROGRAM DESCRIPTION FOR -*

OPERATIONAL NUCLEAR POWER PLANTS REVISION 13 APPROVED BY:

"It Date 193 V~~rations, and Technical Services Environmental Date D P Hoffman

~~and R J Nicholson Hydro Operations Date Date Vice President, Human Resources Date H~a~------~~~7- ~/1/93 Date Corporate Secretary T A McNish

Page iii Rev 13

• • QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS Date: 06/15/93 CONTENTS Section Title Page Statement of Responsibility and Authority. 1 Approval Page. ii Contents 111 1.0 Organization 1 2.0 Quality Program . . . . . . . . . . . . . 11 3.0 Design Control . . . 16 4.0 Procurement Document Control 20 5.0 Instructions, Procedures and Drawings. 22 6.0 Document Control . . 25 7.0 Control of Purchased Material, Equipment and Services . 27 8.0 Identification and Control of Items. 30 9.0 Control of Special Processes 31 10.0 Inspection 32 11.0 Test Control 35 12.0 Control of Measuring and Test Equipment. 37 13.0 Handling, Storage and Shipping 39 14.0 Inspection, Test and Operating Status. 40 15.0 Nonconforming Materials, Parts or Components 41 16.0 Corrective Action 43 17.0 Quality Records. 44

• 18.0 Audits . . . . . 46

Page iv Rev 13 Date: 06/15/93 Section Title Page Appendix A Regulatory Guide and ANSI Standard Commitments 48 Part 2 CPCo Exceptions to Operating Phase Standards and Regulatory Guides,_, . . . . . .... 50 FIGURES 1 Consumers Power Company Corporate Organization . . . . . . . . . . . 9 2 Nuclear Operations, Environmental and Technical Services Organization . . . . . . . . . . . . . 10

Page 1 Rev 13 Date: 06/15/93

• 1.0 1.1 ORGANIZATION POLICY Consumers Power Company (CPCo) is responsible for establishing and implementing the Quality Program, as described herein, for the operational phase of its nuclear power plants. Although authority for development and execution of some parts of the program is dele-gated to others, such as contractors and consultants, CPCo retains overall responsibility.

This section of the Quality Program Description (QPD) identifies the CPCo organizations responsible for activities affecting the quality of safety-related nuclear power plant 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 Quality Program; and for assessing the performance of activities affecting the quality of safety-related items. The control of this Quality Program Description is the responsibility of the Nuclear Services organization.

Nuclear Performance Assessment Department (NPAD) functions (audits, surveillances and independent safety reviews) are performed by per-sonnel within formally designated organizational units that report to the Director, Nuclear Performance Assessment or members of other organizations as selected by the Director, Nuclear Performance Assessment. The reporting level of the Nuclear Performance Assess-ment organization affords sufficient authority and organizational freedom, including sufficient independence from the cost and schedule 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.

1.2 IMPLEMENTATION 1.2.1 Source of Authority The President and Chief Executive Officer (see Figure 1 of Company Organization Charts) of CPCo is responsible for safe operation of CPCo nuclear power plants. Authority and responsibility for estab-lishing and implementing the Quality Program for plant operations, maintenance and modifications is delegated through the Executive Vice President and Chief Operating Officer to the Vice President - Nuclear Operations, Environmental and Technical Services. This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer. Other quality-related functions are provided by other organizations as described herein .

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• 1.2.2 Responsibility for Attaining Quality Objectives in the Nuclear Operations. Environmental and Technical* Services Organization The Vice President - Nuclear Operations, Environmental and Technical Services is responsible to the Executive Vice President and Chief Operating Officer for operation and maintenance of CPCo nuclear power plants. Directors and Managers who report to him are responsible for directing the performance of activities that affect safe plant operation and/or safety-related functions of structures, systems and components of the operating nuclear power plants in accordance with Quality Program requirements.

a. The Plant General Manager/Plant Manager (see Figure 2) are responsible to the Vice President, Nuclear Operations, Environmental and Technical Services for operation and maintenance of the nuclear power plants in such a manner as to achieve compliance with Plant licenses, applicable regulations and the Quality Program. Each Plant General Manager or 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 on the authority of the Plant General Manager/ Manager include:

Qualification of plant operating, inspection and maintenance personnel, including certification of inspection personnel.

Preparation, review and approval of plant procedures and instructions.

Plant initiated 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 Purchasing. 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.

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

Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability .

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• • Functioning as the plant design and configuration control author-ity (Big Rock only) for compliance of plant modifications and design changes to existing plant design criteria.

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

Operating experience-reviews including NRC Information Notices.

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 Specifica-tions 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 instrumentation.

Maintaining a calibration recall system.

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

Providing for storage and protection of purchased materials and .

items and items awaiting disposition implementation after removal from service, assuring preservation of identification.

Developing, maintaining and implementing security, fire protec-tion, health physics and emergency plans.

Performing start-up and operational testing, such as precritical and criticality tests, low-power, power ascension and plant tests, and surveillance testing.

Maintaining equipment status control.

Maintaining required controls over chemical standards and reagents.

Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules.

Conducting a water chemistry program in accordance with technical specifications.

Maintaining the Records Management System including required retention, protection and retrievability. This includes collec-ting, storing, maintaining, distributing and controlling plant

• CPC-2A.Rl3 engineering/design documents (Palisades only).

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• Maintenance/operation of the corrective action system.

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

Plant site inspection program, including inspection of main-tenance, testing and fuel handling.

Development and utilization of nuclear plant probabilistic risk assessment models to evaluate safety and plant reliability improvement.

Preparation, review, and approval of Q-list updates (Big Rock Point only) .

Assuring that nonconforming items are identified, segregated and dispositioned.

Reactor engineering (Big Rock only) such as accident-transient and physics analysis of reloads, reactor core and nuclear fuel design and core thermal-hydraulic and nuclear support of plant modifications and operations.

Source verification at fuel supplier facilities, fuel inspection upon delivery and review of fuel supplier quality-related docu-mentation.

b. The Director, Nuclear Performance Assessment Department (see Figure 2), is responsible for:

Assessment of the effectiveness of the Nuclear Operations Quality Program.

Performance of the offsite safety review functions for the nuclear power plants as described in plant technical specifica-tions.

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

Assessment of nuclear safety performance as described in the Technical Specifications.

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

Recommending to the Vice President, Nuclear Operations, Environmental and Technical Services or the Plant General Manager/Managers that a plant be shut down if such action appears

• CPC-2A.Rl3 necessary.

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• Review performance trending associated with NOD activities including corrective action.

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

Reporting audit findings relative to followup on corrective actions and the effectiveness of the Quality Program to CPCo Management.

The Director, Nuclear Performance Assessment has no other primary duties or responsibilities unrelated to Nuclear Performance Assessment that would prevent his attention to Nuclear Perform-ance Assessment matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality consider-ations in his decisions and recommendations, and has direct access to high enough levels of Management to obtain resolution of quality problems.

c. The Director, Nuclear Services (see Figure 2) is responsible for:

Maintenance of the Quality Program Description for Operational Nuclear Power Plants.

Preparing, reviewing, approving and implementing procedures for activities carried out by his department.

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

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

Managing the Nuclear Emergency Planning function.

Procurement of nuclear fuel and associated services.

Operating the dosimetry laboratory and maintaining records of personnel radiation exposure.

d. The Director, Nuclear Training (see Figure 2), is responsible for establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program indoctrination and training, and for preparing, reviewing, approving and implementing procedures for activities carried out by his department.

e. The Manager, Nuclear Engineering and Construction (see Figure 2) is responsible, through personnel reporting to him for:

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• Functioning as the design and configuration control authority (Palisades only) for compliance of plant modifications and design changes to existing plant design criteria. This includes prepar-ing, reviewing and approving changes to plant engineering/design documents.

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

Providing, as requested, technical expertise and review capability to Nuclear Operations in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil-structural engineering and application of codes and standards.

Preparing, reviewing, approving and implementing procedures for activities carried out by his department.

Performing tests to verify proper construction and installation of modifications.

• • Procurement of services and equipment to support modifications.

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

Preparation, review and approval of Q-list updates (Palisades only).

Performing analytical studies to appraise the adequacy of elec-trical supply to safety-related equipment in nuclear power plants from the principal power supply facilities of the transmission network and onsite power supply.

Providing reactor engineering support for* Palisades, such as accident-transient and physics analysis of core reloads, reactor core and nuclear fuel design, and core thermal-hydraulic and nuclear discipline support of plant modifications and operations.

f. The Manager, Environmental and Technical Service~ (E&TS) (see Figure 2) is responsible, through personnel reporting to him, for:

Maintaining/testing electrical protective devices.

Performing design verification testing associated with .electrical protective devices, except when such testing is procured from approved outside contractors.

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Page 7 Rev 13 Date: 06/15/93 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&TS, and other departments, as requested.

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

Providing a PL-M&TE Inventory List for Nuclear Operations.

Providing chemistry support to Nuclear Operations, 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 pur-chasing for procurement action.

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

Performing nondestructive examination, and controlling/maintain-ing 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.

1.2.3 Responsibility for Attaining Quality Objectives in the Fossil and Hydro Operations organization.

The Vice President, Fossil and Hydro Operations (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer. Managers reporting to him are responsible for directing the performance of activities in accordance with Quality Program requirements.

a. The Manager, Equipment Services & Field Maintenance Services provides electrical, rotating and stationary equipment expertise and provides field maintenance services for assigned modification and maintenance tasks .

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b. The Manager, Projects, Engineering and Construction, maintains the Records Management System including required retention, pro-tection and retrievability. This includes collecting, storing, maintaining, *distributing and-controlling plant engineering/

design documents (Big Rock only).

1.2.4 Responsibility for Attaining Quality Objectives Outside Nuclear Operations. Environmental and Technical Services and Fossil and Hydro Operations Certain functions that constitute part of the Nuclear Operations Quality Program are performed by CPCo organizational units outside the Nuclear Operations, Environmental and Technical Services Department or Fossil and Hydro Operations. 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 (as the design authority).

a. The Manager, Transmission Engineering (see Figure 1) is responsi-ble through the Vice President, Electric Transmission to the Senior Vice President, Energy Distribution for determining settings for electrical protective systems and relay control schemes, and for design, review and recommending changes to electrical protective schemes and associated settings.

b. The Executive Manager, Corporate Training and Development (see Figure 1), is responsible to the Vice President, Human Resources for operating the Skill Centers and training, and qualifying personnel and equipment for welding operations.

c. The Corporate Records Administrator (see Figure 1) is respon-sible through the Corporate Secretary for microfilming of specified quality records and plant engineering/design documents.

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Page 9 Rev 13 Date: 06/15/93 CHAIRMAN PRESIDENT VICE CHAIRMAN -- AND CHIEF EXECUTIVE OFFICER

~

VICE PRESIDENT I

HUMAN RESOURCES CORPORATE EXECUTIVE SECRETARY VICE PRESIDENT AND CHIEF OPERATING OFFICER EXECUTIVE MANAGER CORPORATE CORP TRAINING RECORDS AND ADMINISTRATOR DEVELOPMENT SR VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT ENERGY DISTRIBUTION NUCLEAR OPERATIONS FOSSIL AND HYDRO ENVIRONMENTAL AND OPERATIONS TECHNICAL SERVICES VICE PRESIDENT MANAGER ELECTRIC PROJECT ENGINEERING -

TRANSMISSION AND CONSTRUCTION MANAGER MANAGER EQUIPMENT SERVICES TRANSMISSION AND FIELD ENGINEERING MAINTENANCE SERVICES Figure 1 - Consumers Power Company Corporate Organization CPC-2A.R13

Page 10 Rev 13 Date: 06/15/93 VICE PRESIDENT NUCLEAR OPERATIONS ENVIRONMENTAL AND TECHNICAL SERVICES NUCLEAR NUCLEAR PLANTS SERVICES MGR/GEN MGR DIRECTOR ENVIRONMENTAL NUCLEAR NOD NUCLEAR NUCLEAR AND TRAINING PROJECTS PERFORMANCE ENGINEERING TECHNICAL DEPARTMENT ASSESSMENT AND SERVICES CONSTRUCTION MANAGER DIRECTOR STAFF DIRECTOR MANAGER Figure 2 - Nuclear Operations, Environmental and Technical Services Organization CPC-2A.R13

Page 11 Rev 13 Date: 06/15/93 2.0 QUALITY PROGRAM 2.1 POLICY Policies that define and establish the Consumers Power Company (CPCo)

Quality Program for Operational Nuclear Power Plants are stated in the individual sections of this document. The program is implemented through procedures and instructions responsive to provisions of the Quality Program Descripcion and will be carried out for the life of each plant.

Quality controls apply to activities affecting the quality of safety-related 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 10CFRSO Appendix Bare regularly reviewed by CPCo Management* through reports, meetings and review of audit results. A preplanned and documented assessment of the nuclear safety performance is conducted as des-cribed in the Technical Specifications.

2.2 IMPLEMENTATION 2.2.1 The Fresident of Consumers Power Company, as Chief Executive Officer, has stated in a formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy.to comply with the provi-sions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10CFRSO Appendix B.

The statement makes this Quality Program Description and the associ-ated 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 assur-ing its effectiveness.

2.2.2 The Quality Program at CPCo 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 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.

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b. The Quality Program described in this Quality Program Description is intended to apply for the life of CPCo's nuclear power plants.

c. The Quality Program applies to activities affecting the quality of safety-related structures, systems, components and related consumables during plant operation, maintenance, testing and all modifications. Those activities having a direct impact on safety-related items shall be controlled. Safety-related struc-tures, systems, components and related consumables are identified in Q-Lists, which are developed and maintained for each plant in accordance with the criteria of Regulatory Guide 1.29 as clari-fied by Items No. 20a and No. 20b in Part 2 of Appendix A to this Quality Program Description.

2.2.4 This Quality Program Description, organized to present the CPCo Quality Program for Operational Nuclear Power Plants in the order of the 18 criteria of 10CFR50 Appendix B, states CPCo policy 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. 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 p~ior to implementation. The submittal of the changes described above shall be made in accordance with the require-ments of 10CFR50. 54.

• The program described in this Quality Program Description will not be changed in any way that would prevent it from meeting the criteria of 10CFR50 Appendix B.

2.2.5 Documents used for implementing the provisions of the Quality Program Description include the following:

a. Administrative procedures specify the standard methods of I accomplishing operational phase activities. Because the Quality Program is an integral part of the operational phase activities, the methods for implementing Quality Program controls are in-tegrated into these documents.

b. When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10CFR50 Appendix B and the contract and are approved by CPCo prior to the start of work.

c. Applicable elements of this Quality Program Description for Operational Nuclear Power Plants are applied to emergency plans, security plans, radiation and fire protection plans for CPCo nuclear power plants. These plans describe quality controls applicable to associated equipment and activities.

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Page 13 Rev 13 Date: 06/15/93 2.2.6 Provisions of the Quality Program for Operational Nuclear Power Plants apply to activities affect~ng the quality of safety-related structures, systems, components and related consumables.

Appendix A to this Quality Program Description lists the ANSI Stan-dards and Regulatory Guides to which CPCo commits. Appendix A also describes necessary exceptions and clarifications to the requirements of those documents. The scope of the program and the extent to which its controls are applied-are established as follows:

a. CPCo uses the criteria specified in Regulatory Guides. 1. 26 and 1.29 in engineering evaluation of an item's function in relation to safe operation and shutdown to identify st:rUctures, systems and components to which the Quality Program applies (See Appendix A).

b. This identification by engineering personnel results in the clas-sification of equipment as either safety related or non-safety related, and the inclusion of this classification in an equipment data base. This data base is available for inquiry by individu-als involved in plant operation. The classification of struc-tures, systems and consumables is also identified, documented, and controlled.

c. The extent to which controls specified in the Quality Program are applied to items is determined for each item considering its relative importance to safety. Such determinations are based on data in such documents as the plant risk analysis, plant Techni-cal Specifications and the FSAR/FHSR (See Appendix A).

2.2.7 Activities affecting the quality of safety-related items are accom-plished under controlled conditions. Preparations for such activi-ties include confirmation that prerequisites have been met, such as:

a. Assigned personnel are qualified.

b. Work has been planned to the proper revisions of applicable engi-neering 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.

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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 CPCo are subject to Quality Program design controls ~see Section 3.0, DESIGN CONTROL).

2.2.9 Responsibility and authority for planning and implementing indoctri-nation and training are specifically designated in the CPCo organiza-tion (see Section 1.0, ORGANIZATION).

a. The training and indoctrination program provides for ongoing training and periodic refamiliarization with the Quality Program for Operational Nuclear Power Plants.

b. Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.58, SNT TC-lA, or the ASME Code, or Section 10.2.3 of this Quality Program Description, 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 recertifi-cation 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 personnel involved are performing activities to which the training/qualification 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 CPCo Management. The following activities constitute formal elements of that assessment:

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

b. Management teams assess the nuclear safety performance as described in the Technical Specifications. Conclusions and recommendations are reported to the Executive Vice President &

Chief Operating Officer.

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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Page 16 Rev 13 Date: 06/15/93 3.0 DESIGN CONTROL 3.1 POLICY Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled. Depending on the type of modi-fication, these activities include design and field engineering; the performance of physics, -seismic, stress, thermal, hydraulic, radia-tion and Safety Analysis Report (SAR) accident analyses; the devel-opment and control of associated computer programs; studies of material compatibility; accessibility for inservice 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.

3.2 IMPLEMENTATION 3.2.1 Authority and responsibility for modification activities is under the cognizance of the Nuclear Operations Department as described in Sec-tion 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 crite-ria; 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 struc-tures, 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 (quali-ty) standards (ie, the required dimensions, material properties, features and other characteristics specified for modifications) are required by procedure and by contract, when applicable, to be docu-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 CPC-2A.Rl3

Page 17 Rev 13 Date: 06/15/93 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, funetionally 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 GPCo organization having-responsibility for engineering direction of the design effort.

3.2.6 Checks are performed and documented to verify the dimensional accu-racy and completeness of design drawings and specifications (ie, the products of a design process).

3.2.7 Modification design document packages are reviewed by either Plant Engineering personnel or by Nuclear Engineering and Construction 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 require-ments for documenting inspection and test results.

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 previ~

ously 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 per-formed 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.

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Page 18 Rev 13 Date: 06/15/93 Scaling laws are established and verified, when applicable. Test configurations are clearly documented.

Design reviews are performed by multi-organizational or interdisci-plinary 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 appro-priate 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 establishe.d 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 doc-umentation 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 Nuclear Performance Assessment cover the fre-quency, effectiveness, and technical.adequacy of the use of supervi-sors 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.

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• 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 equivalent, organizations that approved the original design. Infor-mation on approved changes is transmitted to all affected organizations .

• CPC-2A.Rl3

Page 20 Rev 13 Date: 06/15/93 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 POLICY Procurement documents for safety-related structures, systems, compo-nents and services define the characteristics of item(s) to be pro-cured, identify applicable regulatory and industry codes/standards requirements and specify supplier quality assurance program require-ments to the extent nece~sary to assure adequate quality.

4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement planning and for preparation, review and approval of procurement documents are delin-eated in Section 1.0, ORGANIZATION.

Procurement request packages are reviewed and approved prior to sub-mittal 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 Quality Program Description are considered for application to sup-pliers. 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.

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 CPCo review and written concurrence prior to the start of work.

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

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g. Provisions for access to supplier and subtier suppliers' facili-ties 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 docu-ments requiring CPCo approval.

4.2.4 Trained, qualified personnel perform and document reviews of procure-ment 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, func-tion 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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Page 22 Rev 13 Date: 06/15/93 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 POLICY Activities affecting the quality of safety-related structures, sys-tems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances which include accep-tance criteria for determining if an activity has been satisfactorily completed.

5.2 IMPLEMENTATION The authority and responsibility for performing activities affecting the quality of safety-related structures, systems and components are assigned as described in Section 1.0, ORGANIZATION. Management personnel assigned these responsibilities assure that the instruc-tions, 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 worlananship 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 CPCo to control its activities include the following:

1. Administrative Procedures.

2. System procedures that describe the operation of the plant.

3. Start-up procedures that provide for starting the reactor from hot or cold condition and recovering from reactor trips.

4. Shutdown procedures that provide for controlled reactor shutdown or shutdown following reactor trips.

5. Power operation and load changing procedures that provide for steady state power operation and load changing, including re-sponse to unanticipated load changes.

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

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• 7. Fuel-handling procedures that provide for activities such as:

a. Core alterations

b. Refueling

c. Fuel accountability

d. Receipt and shipment of fuel

e. Nuclear Safety measures

8. 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

9. 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

10. Calibration and test procedures that provide for:

a. Periodic calibration and testing of safety-related instrumen~

tation and control systems

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

11. 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 CPC-2A.Rl3

Page 24 Rev 13 Date: 06/15/93

e. The control of radioactive calibration sources

12. Emergency procedures that provide guidance for:

a. Operations during potential emergencies so that a trained

• operator will know in advance the expected course of events that will identify an emergency and the immediate action he should take

b. Identifying symptoms of emergency conditions

c. Monitoring automatic.action

d. Immediate operator action

e. Subsequent operator action

13. Emergency Plan Implementing Procedures

14. 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

15. Modification procedures that provide for:

a. Administrative control and technical support during plant modifications

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

c. Control of the interfaces between CPCo and its suppliers

d. Offsite management control

e. Control of onsite quality-related modification activities that assure the Quality Program is implemented and its effec-

• CPC-2A.Rl3 tiveness is assessed and reported

Page 25 Rev 13 Date: 06/15/93 6.0 DOCUMENT CONTROL 6.1 POLICY Documents controlling safety-related 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 r~lease 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.

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 (eg, calculations, drawings, specifications, analyses) including documents related to computer codes

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 and plant maintenance and operation which implement the Quality Program.

e. Final Safety Analysis Report/Final Hazards Safety Report

f. Reports of nonconformances

g. Plant 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 CPC-2A.Rl3

Page 26 Rev 13

• Date: 06/15/93

-* b.

c.

Identification of the organizations responsible for review, approval, issue and revision 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 com-mencing 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 documenta-tion are prepared in a timely manner.

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Page 27 Rev 13 Date: 06/15/93 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for safety-related material, equipment and services 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 the nuclear power plant site prior to reliance on equipment, material or services for nuclear safety.

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 CPCo qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procure-ment documents. To remain qualified, suppliers involved in active procurements are reevaluated annually and are audited triennially.

If an audit is acquired from an external source, the audit is evalua-ted 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

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 CPC-2A.Rl3

Page 28 Rev 13 Date: 06/15/93 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 engi-neering 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 previ-ous 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 safety-related pro-curement 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.

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 require-ments (eg, 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.

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Page 29 Rev 13 Date: 06/15/93 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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Page 30 Rev 13 Date: 06/15/93 8.0 IDENTIFICATION AND CONTROL OF ITEMS 8.1 POLICY Safety-related materials, parts and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or con-tainers or on records traceable to the items.

8.2 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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Page 31 Rev 13 Date: 06/15/93 9.0 CONTROL OF SPECIAL PROCESSES 9.1 POLICY Special processes affecting safety-related structures, systems and components are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applica-ble codes, standards, specifications, criteria and other special requirements.

9.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at CPCo 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, con-crete placement and nondestructive examination.

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 techni-cal adequacy by other personnel with the necessary technical compe-tence, 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 reexamina-tion at time iritervals 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 equip-ment is qualified in accordance with applicable codes, standards and specifications.

9.2.6 Qualification records are maintained in accordance with Quality Program Description Section 17.

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

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-* 10.0 10.1 INSPECTION POLICY Activities affecting the quality of safety-related structures, sys-tems and components are inspected to verify their conformance with requirements. _Inspections are accomplished by independent verifica-tion 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.

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 and inservice inspection to verify that items and activities conform to specified requirements. Work authorizing documents (eg; 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 ade-quate objective evidence of acceptability.

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 inspec-tion alone is impractical or inadequate.

10.2.3 Training and qualification programs for personnel who perform inspec-tions, including nondestructive examination, are established, imple-mented and documented in accordance with plant or offsite procedures, I as applicable. These programs meet the requirements of applicable codes and standards. The Plant General Manager/Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility. For CPC-2A.Rl2

Page 33 Rev 13 Date: 06/15/93 activities performed at Palisades that are under the cognizance of Nuclear Engineering and Construction, the Manager, Nuclear Engineering and Construction is responsible for review and concurrence of such programs.

I Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are documented in E&TS procedures.

Qualifications and certifications of inspection and NDE personnel are I

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 (pro-cedures, 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 neces-sary 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 th~

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 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 .

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Page 34 Rev 13 Date: 06/15/93

• 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 CPCo personnel and/or is addressed by CPCo 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 verifi-cation 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 veri-fier 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 CPCo Quality Program and procedures.

b. Individuals are trained and qualified in accordance with Section 10.2.3.

Otherwise, contractors must be certified to ANSI N45.2.6 to perform inspections .

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-* 11.0 11.1 TEST CONTROL POLICY Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems and components 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, pre-operational, start-up, surveillance and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental con-ditions are specified and met. Test results are documented and evaluated.

11.2 IMPLEMENTATION 11.2.1 Organizational responsibilities for testing are described in Sec-tion 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. Pre-operational tests to assure proper and safe operation of systems and equipment prior to start-up tests or operations.

d. Start-up tests, including precritical, criticality, low-power anq power ascension tests, performed after refueling to assure proper and safe operation of systems and equipment.

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

f. Maintenance tests after preventive or corrective maintenance.

11.2.3 Test procedures and instructions include provisions for the follow-ing, 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 require-CPC-2A.Rl3

Page 36.

Rev 13 Date: 06/15/93 ments, completeness of the item to be 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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Page 37 Rev 13 Date: 06/15/93

• 12.0 12.1 CONTROL OF MEASURING AND TEST EQUIPMENT POLICY Measuring and testing equipment used in activities affecting the quality of safety-related systems, components and structures are properly identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within necessary limits.

12.2 IMPLEMENTATION 12.2.1 The authority and responsibility of personnel establishing, imple-menting 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 12.2.5 CPCo uses equipment cannot be potential a system of labels to be attached to measuring and test to display the next calibration due date. Where labels attached, a control system is used that identifies to users any equipment beyond the calibration due date.

Measuring and test equipment (M&TE) and installed plant instrumenta-tion 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 cali-brated 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.

Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being cali-brated. 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 CPC-2A.Rl3

Page 38 Rev 13 Date: 06/15/93

• 12.2.7 if it can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible management.

Reference and transfer standards are traceable to nationally recog-nized 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 r~quired accuracy limits at the time of cali-bration, 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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Page 39 Rev 13 Date: 06/15/93 13.0 HANDLING, STORAGE AND SHIPPING 13.l POLICY Activities with the potential for causing contamination or deteriora-tion that could adversely affect the ability of a safety-related item to perform its intended safety functions, and activities necessary to prevent undetected or uncorrectable damage are identified and con-trolled. These activities include cleaning, packaging, preserving, handling, shipping and storing. Controls are effected through the use of appropriate procedures and instructions implemented by suit-ably trained personnel.

13.2 IMPLEMENTATION 13.2.1 The authority and responsibility of personnel implementing and assur-ing the effectiveness of material cleaning, handling, storing, pack-aging, preserving and shipping activities is described in Section 1.0, ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storing, pack-aging, preserving and shipping of materials, components and systems in accordance with design and procurement requirements. These pro-cedures 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 proce-dures provide for special environments such as inert gas atmos-pheres, 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 dete-rioration 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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Page 40 Rev 13 Date: 06/15/93 14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 POLICY Operating status of safety-related structures, systems and components 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 ma~kings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.

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 inspec-tion 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 organi-zation no longer exists.

14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems and components is clearly identified and documented to pre- ,

vent inadvertent use.

CPC-2A.Rl3

Page 41 Rev 13 Date: 06/15/93 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 15.l POLICY Safety-related materials, parts or components 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.

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 doctimented 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 implementa-tion of activities related to the processing and control of noncon-forming materials, parts or components are described in Section 1.0, ORGANIZATION.

a. Nonconforming items are identified by marking, tagging or segre-gating or by documented administrative controls. Documentation describes the nonconformance, the disposition of the nonc9nfor-mance and the inspection requirements. It also includes signa-ture approval of the disposition.

b. The original inspection planning authority reviews the disposi-tion 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 accept-able 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.

15.2.2 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.

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Page 42 Rev 13 Date: 06/15/93 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 .

• CPC-2A.Rl3

Page 43 Rev 13 Date: 06/15/93 16.0 CORRECTIVE ACTION 16.1 POLICY Conditions adverse to quality of safety-related structures, systems, components or activities, such as failures, malfunctions, deficien-cies, 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 tak-ing 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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Page 44 Rev 13 Date: 06/15/93 17.0 QUALITY RECORDS 17.1 POLICY Records that furnish evidence of activities affecting the quality of safety-related structures, systems and components are maintained.

They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.

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 con-sidered records. These records include:

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

• b.

c.

d.

Qualification of personnel, procedures and equipment Operating logs Maintenance and modification procedures and related inspection results

e. Reportable occurrences

f. Records required by the plant technical specifications

g. Nonconformance reports

h. Corrective action reports

i. Other documentation such as drawings, specifications, procurement documents, calibration procedures and reports 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.

CPC-2A.Rl3 Inspector or data recorder identification

Page 45 Rev 13 Date: 06/15/93

• e.

f.

Evidence as to the acceptability of the results 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.

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. Rec.ords that can only be stored as originals, such as radiographs and some strip charts are retained in a four-hour fire-rated facility .

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Page 46 Rev 13 Date: 06/15/93 18.0 AUDITS 18.1 POLICY A comprehensive system of audits is carried out to provide indepen-dent 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 quali-fied 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.

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 sched-ules that reflect the status and importance to safety of the activi-ties being performed. Audits are conducted in accordance with frequencies stated in the Technical Specifications.

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 impor-tance of the activities being performed. Such audits shall be ini-tiated 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 docu-ments and records to confirm that the Quality Program is effective and properly implemented.

18.2.7 Audit procedures and the scope, plans, checklists and results of individual audits are documented .

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Page 47 Rev 13 Date: 06/15/93 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 Nuclear Performance Assessment Depart-ment. 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 appropri-ate 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 Nuclear Performance Assessment Department to ensure that appropriate corrective action is taken and is effective. Such follow-up includes reaudits when neces-sary. For Vendor Audits, such follow-up shall be performed by the organization performing the audit .

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Page 48 Rev 13 Date: 06/15/93

• QPD MANUAL APPENDIX A. -PART 1 REGUIATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Power Company Quality Program complies with the regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2.

1. 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 Train-ing - Endorses ANSI/ANS 3.1 - (12/79 Draft).

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 Instrumen-tation and Electrical Equipment - Endorses ANSI N45.2.4 - 1972.

7. Regulatory Guide 1.33 - (2/78, Rev 2) - Quality Assurance Program Requirements*(operation) - Endorses ANSI Nl8.7 - 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.l - 1973.

9. Regulatory Guide 1.38 - (5/77, 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 1) - 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.ll - 1974.

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Page 49 Rev 13 Date: 06/15/93

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 - En4orses 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 1) - 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.l (Rev 1) Guidelines for Fire Protec-tion for Nuclear *Power Plants.

21. 10CFRSO, Appendix R, Fire Protection Program for Nuclear Power Facili-ties Operating Prior to January 1, 1979, Sections III G., III J. and III 0.

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Page 50 Rev 13 Date: 06/15/93

• QPD MANUAL APPENDIX A. -PART 2 CPCO EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES

1. General Requirement Certain Regulatory Guides invoke or imply Regulatory Guides and stan-dards in addition to the standard each primarily endorses.

Certain ANSI Standards invoke or imply additional standards.

Exception/Interpretation The CPCo 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 CPCo suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured.

2. Nl8.7 General Exception/Interpretation Consumers Power Company 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 Specialists. Procedures will be established to specify how the Nuclear Performance Specialists will acquire necessary expertise to carry out its review responsibilities in accordance with Plant Technical Specifications.

2a. Nl8.7, 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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Page 51 Rev 13 Date: 06/15/93 Exception/Interpretation Since CPCo has more than one nuclear unit and more than one organization providing services to these units, overall responsibility cannot be centralized in a single on-site position. Instead, responsibilities are as designated within the Quality Program Description.

2b. Sec 4.3.1 Requirement "Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines and shall collec-tively have the experience and competence required to review problems in the following areas: ... "

Exception/Interpretation The Nuclear Performance Specialists 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 Nuclear Performance Specialists will function as described in Plant Technical Specifications and will acquire the services of personnel having such experience and competence as necessary.

2c. 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 the Plant Technical Specifications.

2d. 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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Page 52 Rev 13 Date: 06/15/93 Exception/Interpretation The Nuclear Performance Specialists will not review Technical Specifica-tion Changes after NRC approval prior to implementation. The basis for this position is that Nuclear Performance Specialists review all Tech-nical Specification changes prior to submittal to the NRC.

2e. Sec 4.5 Requirement "Written reports of audits specified in ANSI Nl8.7 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 Nuclear Performance Specialists review or arrange for reviews of those audits over which it has cognizance, in accordance with the individual plant Technical Specifications.

Some of the audits required during the operational phase are in areas other than those requiring independent review in accordance with ANSI Nl8.7, Section 4.3.4.

2f. Sec 4.5 Requirement Periodic review of the audit program shall be performed by the indepen-dent review body or by a management representative at least semiannually to assure that audits are being accomplished in accordance with require-ments of technical specifications and of this standard.

Exception/Interpretation Audits of operational nuclear safety related facility activities are performed under the cognizance of the Nuclear Performance Specialists as described in individual plant technical specifications.

2g. Sec 5.2.1 Requirement "The responsibilities and authorities of the plant operating personnel shall be delineated."

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Page 53 Rev 13 Date: 06/15/93 Exception/Interpretation On-site personnel not directly associated with operating activities, as defined in ANSI Nl8 .--7, Section 2. 2, are not considered to be operating personnel.

2h. 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 CPCo considers that this requirement applies only to procedures iden-tified in plant technical specifications. Temporary changes to these procedures shall be approved as described in plant technical specifications.

21. 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."

Exception/Interpretation CPCo 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. 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 occurring during the operational phase that are comparable in nature and extent to related activities occurring CPC-2A.Rl3

Page 54 Rev 13 Date: 06/15/93 during initial plant design and construction: American National Stan-dard Installation, Inspection and Testing of Instrumentation and Elec-tric 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, Inspec-tion 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 Construc~ion 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 Require-ments for the Design of Nuclear Power Plants, N45.2.ll.1974 [9]; and American National Standard Quality Assurance for Protective Coating Applied to Nuclear Facilities NlOl.4-1972 [10]. Considerable care is required in assessing which operational phase activities are comparable 1n nature and extent to activities normally associated with design and construction.

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

2k. Sec 5.2.8 Requirement "A surveillance testing and inspection program ... shall include the establishment of a master surveillance schedule reflecting and status of all planned inplant surveillance tests and inspections.".

Exception/Interpretation Separate master schedules may exist for different programs such as !SI, Pump and Valve Testing and Technical Specification Surveillance Testing.

21. 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."

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Page SS Rev 13 Date: 06/15/93 Exception/Interpretation To the extent necessary, procurement documents require that the supplier have a documented quality assurance program consistent with the perti-nent requirements of ANSI N45.2 or other nationally recognized codes and standards.

2m. Sec 5.2.13.2 Requirement ANSI Nl8.7 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. 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 Based on amplification 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 use of the procedure (such as occurs when the procedure has a step-by-step checkoff associated with it) or detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity.

2o. Sec 5.2.16 Requirement Records shall be made and equipment suitably marked to indicate cali-bration status .

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Page 56 Rev 13 Date: 06/15/93

• Exception/Interpretation See Item 9c.

2p. Sec 5. 2 .17 Requirement For modifications and nonroutine 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 CPCo maintenance personnel and is carried out using CPCo procedures may be inspected by independent verifiers in accordance with Sections 10.2.3, 10.2.7 and 10.2.10 of this program description.

2q. Sec 5.2.17 Requirement If mandatory inspection hold points are required, the specific hold points shall be indicated in appropriate documents. Information concer-ning inspection shall be obtained from the related design drawings, specifications and/or other controlled documents.

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

2r. Sec 5.3.5(3)

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

Exception/Interpretation At CPCo, equipment is returned to its normal operating status, ie, declared operable, by licensed Operations Department personnel, not Maintenance personnel. Operations personnel verify and document equip-ment operability through second level line-up verification or appropri-ate functional testing .

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Page 57 Rev 13 Date: 06/15/93 2s. 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 incor-porated 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.

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 Nuclear Performance Assessment Specialists. In addition, the corrective action system is audited in accordance with Technical Specifications.

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 Power Company interprets the commitment to audit technical specification/license conditions contained in 18.2.2(a) of this QPD, and in section 6.5.2.8(a) of both Palisades and Big Rock Point technical specifications, as follows:

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Page 58 Rev 13 Date: 06/15/93 Consumers Power Company maintains a matrix that identifies all applica-ble 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, 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 compliance history.

4a. ANS 3.1, General Exception/Interpretation Lead auditors are trained and qualified to Regulatory Guide 1.146. All other personnel are trained and qualified as designated in the plant Technical Specifications.

Sa. RG 1.8. C.3.1, General Exception/Interpretation Lead auditors are trained and qualified to Regulatory Guide 1.146. All other personnel are trained and qualified as designated in the plant Technical Specifications.

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Page 59 Rev 13 Date: 06/15/93 Sb. Cl.2.2 Requirement "When an individual is hired to temporarily function as a plant*

employee, such as for contracted services, evidence of previous educa-tion, experience and training should be provided and reviewed by the appropriate professional-technical group leaders. The appropriate group leaders should then determi-ne the content for that individual's train-ing, including plant-specific training. As a minimum, each individual should receive General Employee Training."

Exception/Interpretation CPCo understands that this requirement applies both to CPCo employees from another site and to contract personnel who are temporarily assigned to a nuclear power plant either as replacements for regular employees or to augment the staff during outages. CPCo 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 requiring unescorted access receive the *site general orienta-tion as embodied in General Employee Training.

6a. N45.2.l. Sec 2.4 Requirement Those personnel who perform inspection, examination or testing activi-ties 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 CPCo 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.l. Sec 3.1 Requirement N45.2.l establishes criteria for classifying items into "cleanness levels," and requires that items be so classified .

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Page 60 Rev 13 Date: 06/15/93

-* Exception/Interpretation Instead of using the cleanness level classification system of N45.2.l, the required cleanne*ss for specific i-tems *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, clean-ness inspections are performed prior to system closure. Such inspec-tions are documented.

6c. Sec 5 Requirement "Fitted and tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed."

Exception/Interpretation CPCo sometimes uses other nonhalogenated material, compatible,with the parent material, since plastic film is subject to damage and does not always provide adequate protection.

7a. N45.2.2, General Requirement N45.2.2 establishes requirements and criteria for classifying safety-related items into protection levels.

Exception/Interpretation Instead of classifying safety-related items 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. 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."

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Page 61 Rev 13 Date: 06/15/93 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 Reg 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 N~S.2.23,,N45.2.6 or Paragraph 10.2.7.

7c. Sec 3.4.1 and Appendix A, 3.4.1(4) and (5)

Requirement

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

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

• Exception/Interpretation Based on comparison of these statements to ANSl/ASME NQA-2 1983, CPCo

• believes the intent was to establish the following as requirements:

(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. 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 neces-sary 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 .

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Page 62 Rev 13 Date: 06/15/93 7e. Sec 5.2.2 Requirement nThe inspections shall be performed in an area equivalent to the level of storage.n 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. Sec 6.2.4 Requirement "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted.n Exception/Interpretation

• 7g.

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 nusedn in these areas.

Sec 6.3.4 Requirement nAll items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes.n Exception/Interpretation See N45.2.2, Section 3.9 (Exception 7d.).

7h. Sec 6.4.1 Requirement ninspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its con-tainer ... is being maintained.n

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Page 63 Rev 13 Date: 06/15/93 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.

Sa. 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, CPCo 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 o.r modifications work, are developed on a case-by-case basis. Factors considered in developing the proce-dures 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 proce-dures, 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 qualifi-cation, control of design, conforming and protected materials, and availability of specified documents.

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

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• 9b. 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. CPCo assures that they are available to the site as necessary.

9c. 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 Instru-mentation (IP!) mandates that calibration labels or tags not be affixed to !PI. Instead, each instrument is uniquely identified and is trace-able to its calibration record.

A scheduled calibration program assures that each instrument's calibra-tion is current.

lOa. 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 Power, persons having engineering managerial responsibility for inspections and tests* may be certified to Level III, or may meet other qualification criteria established for the

• within the scope of N45.2.5

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Page 65 Rev 13 Date: 06/15/93

• 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.

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 CPCo uses the requirements of Nl8.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The Nl8.7 requirements are more applicable to an operating plant.

lOc. 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. n Exception/Interpretation Torque wrenches are controlled as measuring and test equipment in accor-dance with ANSI Nl8.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 lla. 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."

• CPC-2A.Rl3

Page 66 Rev 13 Date: 06/15/93

-* Exception/Interpretation See Exception/Interpretation 2j for those inspectors who must be cer-tified to this standard. Others are-qualified to Paragraph 10.2.7 of CPC-2A.

Qualification of plant personnel who are involved with testing associ-ated 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.l 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 CPCo endorses this position, as also stated in lla, above, except that offsite support organizations involved in testing may apply .ANSI N45.2.6. Some of these departments have already developed their qualif-ication programs based on ANSI N45.2.6, and provide services throughout the operations phase of CPCo Nuclear Plants.

12b. Sec C.5 Requirement "In addition, the individual should be capable of reviewing and approv-ing 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 approv-ing inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination

• CPC-2A.Rl3

Page 67 Rev 13 Date: 06/15/93

• and test objectives, this is not construed by CPCo as requiring person-nel who review, approve or evaluate such procedures to be certified as Level III personnel.

12c. 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 certif-ication program is based upon these recommendations, and more signifi-cantly, 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.

12d. 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 (ie, 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."

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-j ob performance demonstrations.

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Page 68 Rev 13 Date: 06/15/93

-* 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, lla 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. Sec 2.9 Requirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may pro-ceed. These prerequisites include personnel and procedure qualifi-cation, control of design, material selection and fabrication, and availability of specified documents.

~ I Exception/Interpretation I During the operations 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.

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

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Page 69 Rev 13 Date: 06/15/93

• 13d. 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. Sec 4.5.1 Requirement "Installed systems and components shall be cleaned, flushed and conditioned according to the requirements of ANSI N45.2.l. Special consideration shall be given to the following requirements: .... "

(Requirements are given for chemical conditioning, flushing and process controls.)

Exception/Interpretation Systems and components are cleaned, flushed and conditioned as deter-mined 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 .

• CPC-2A.Rl3

~: '

Page 70 Rev 13 Date: 06/15/93 14b. 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, qual-ity assurance records should be classified as NFPA Class 1 records .... "

Exception/Interpretation CPCo 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 indi-vidual performing the design .... "

Exception/Interpretation CPCo follows the requirements of ANSI N45.2.ll-1974, Section G.l, 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 CPC-2A.Rl3

Page 71 Rev 13 Date: 06/15/93 (see Section 3.2.9, herein). This approach is necessary to 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(l)

Requirement This section requires that for operational phase activities, RG 1.33 "Quality Assurance Program Requirements (Operations)" are to be fol-lowed. 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. 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 audite4 periodically.

16c. Sec C3b(l)

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

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

CPC-2A.Rl3

Page 72 Rev 13 Date: 06/15/93 17a. N45.2.13. Sec 3.2.2 Requirement N45.2.13 requires that technical requirements be specified in procure-ment documents by reference to technical requirement documents. Tech-nical requirement documents are to be prepared, reviewed and released under the requirements established by ANS~ N45.2.ll.

Exception/Interpretation For replacement parts and materials", CPCo follows ANSI Nl8.7, 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 iden-*

tified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance."

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

Exception/Interpretation Refer to Item 21.

17c. 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.

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Page 73 . .=:-.:--:----

Rev 13 "*'

Date: 06/15/93 17d. 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 (ie, changes to the procurement document provisions identified in ANSI Nl8.7, 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. 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 Power 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 allowance with Paragraph 10.2.7. However, personnel performing source surveillances may not be certified to any of those requirements.

17f. 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.

CPC-2A.R13

Page 74 Rev 13 Date: 06/15/93 17g. Sec 10.3.4 (as modified by RG 1.123, C6e)

Requirement nPost-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier.n Exception/Interpretation In exercising its ultimate responsibility for its quality program, CPCo establishes post-installation test requirements, giving due considera-tion to supplier recommendations.

18a. 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/Interpreta-tion 20a, is used to determine what systems and equipment are included in the Quality Program.

19a. Branch Technical Position ASB9.5.l and 10CFRSO Appendix R.

Sections III G.. III J. and III 0., General Exception/Interpretation Fire protection measures, equipment and the individual plant Fire Pro-tection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10CFRSO Appendix R except for the specific exemptions approved by the NRC.

20a. 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 I and should be designed to withstand the SSE.

CPC-2A.Rl3

Page 75 Rev 13 Date: 06/15/93 Exception/Interpretation Both CPCo nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on crLteria available prior to Revision 3 of this Regulatory Guide being issued. The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respectively, 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 CPCo primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 20b, below).

20b. RG 1.29, General Requirement Apply pertinent Quality Assurance requirements of 10CFRSO, 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 Risk Assessment and the Technical Specifi-cations, and other docketed analyses to determine the degree which Appendix B of 10CFRSO applies .

• CPC-2A.Rl3

• ENCLOSURE 2 Consumers Power Company Palisades Plant Docket 50-155 - Big Rock Point Plant Docket 50-255 - Palisades Plant CHANGE MATRIX FOR CPC-2A, REVISION 13 June 15, 1993

r Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion Page i Page i 2nd Paragraph 2nd Paragraph I have delegated responsibility I have delegated responsibility Reorganization No change in the Level of for establishing, maintaining for establishing, maintaining conmitment to the Quality and implementing the Quality and implementing the Quality Program Program Description through the Program Description through the Executive Vice President and Executive Vice President and Chief Operating Officer of Chief Operating Officer of Consumers Power company to the Consumers Power Company to the Vice President, Nuclear Vice President, Nuclear Operations. I have delegated Operations, Environmental and selected portions of the Technical Services. I have Quality Program to the Vice delegated selected portions of President, Energy Supply the Quality Program to the Vice Services, Vice President, Human President, Fossil and Hydro Resources; Vice President, Operations; Vice President, Electric Transmission; and Human Resources; Vice through the Vice Chairman of President, Electric Consumers Power Company to the Transmission; and through the Corporate Secretary. Vice Chairman of Consumers Power to the Corporate Secretary.

2 Page ii Pase ii Approval Page Approval Page Vice President, Nuclear Vice President, Nuclear Reorganization - Environmental No change in Level of Operations Operations, Environmental and and Technical Services combined conmitment to the Quality Technical Services with Nuclear Operations. Program.

3 Page ii Approval Signature Vice President, Energy Supply Not in this Revision. Reorganization - No change in level of Services Quality Program conmitments conmitment to the Quality realigned under Vice President, Program.

Nuclear Operations and Vice President, Fossil and Hydro Operations.

Page 1

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 4

Page ii Approval Signature Not in this Revision. Vice President, Fossil and Reorganization - No change in level of Hydro Operations Quality Program corrmitments corrmitment to the Quality realigned under Vice President, Program.

Nuclear Operations and Vice President, Fossil and Hydro Operations.

5 Page iv Page iv Contents Page - Figure 2 Contents Page - Figure 2 Nuclear Operations Department Nuclear Operations, Reorganization - Environmental No change in level of organization Environmental and Technical and Technical Services is corrmitment to the Quality Services organization combined with Nuclear Program.

Operations.

6 Page 1 Page 1 1.2.1 - 2nd Sentence 1.2.1 - 2nd Sentence Authority and responsibility Authority and responsibility Reorganization - Environmental No change in level of for establishing and for establishing and and Technical Services combined corrmitment to the Quality iq>lementing the Quality implementing the Quality with Nuclear Operations. Program.

Program for plant operations, Program for plant operations, maintenance and modifications maintenance and modifications is delegated through the is delegated through the Executive Vice President and Executive Vice President and Chief Operating Officer to the Chief Operating Officer to the Vice President, Nuclear Vice President, Nuclear Operations. Operations, Environmental and Technical Services.

Page 2

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 7

Responsibility for Attaining Responsibility for Attaining Reorganization - Environmental No change in level of Quality Objectives in the Quality Objectives in the and Technical Services combined commitment to the Quality Nuclear Operations Organization Nuclear Operations, with Nuclear Operations. Program.

Environmental and Technical Services Organization The Vice President, Nuclear The Vice President, Nuclear Operations is responsible to Operations, Environmental and the Executive Vice President Technical Services is and Chief Operating Officer for responsible to the Executive operation and maintenance of Vice President and Chief CPCo nuclear power plants. Operating Officer for operation and maintenance of CPCo nuclear power plants.

8 Page 4 Page 5 1.2.2a, 25th Paragraph 1.2.2c. 9th Paragraph Operating the Dosimetry Operating the Dosimetry Reorganization - Dosimetry No change in commitment to the Laboratory (Palisades only) and Laboratory and maintaining Laboratory no longer reports to Quality Program.

maintaining records of records of personnel radiation the plant organization.

personnel radiation exposure. exposure.

9 Page 5 Page 5 1.2.2.b, 9th Paragraph 1.2.2.b, 9th Paragraph Performance Trending of NOD Review performance trends To provide consistency with No change in commitment to the activities including corrective associated with NOD activities ANSI 18.7. See Exception/ Quality Program. NPAD is actions. including corrective actions. Interpretation 3a of this responsible for review of Program Description. performance trends per Exception/Interpretation 3a of the Quality Program Description.

Page 3

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 10 Page 5 1.2.2.c. 5th Paragraph Administrative control of the Not in this Revision. CPCo is eliminating the NOD CPCo has chosen the option of Nuclear Operations Department Standards from the hierarchy of the use of Administrative standards. documents. Procedures rather than the NOO Standards. The NOD Standards were originally developed when the Midland Plant was still under construction and much of the engineering function was Located in Jackson. With each plant now performing most key functions onsite, the NOD Standards were no Longer serving their intended purpose.

11 Responsibility for Attaining Not in this Revision. Reorganization - No change in Level of Quality Objectives in the Quality Program commitments commitment to the Quality Energy Supply Services realigned under Vice President, Program.

Organization Nuclear Operations and Vice President, Fossil and Hydro The Vice President, Energy Operations.

Supply Services (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer for certain services, including standards for calibration of M&TE.

Directors and Managers reporting to him are responsible for directing the performance of activities in accordance with Quality Program requirements.

Page 4

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 12 Pase 6 1.2.2.f

a. The Manager, Environmental The Manager, Environmental and Reorganization - No change in Level of and Technical Services Technical Services CE&TS) (see Quality Program commitments commitment to the Quality CE&TS) is responsible, Figure 2) is responsible, realigned under Vice President, Program.

through personnel reporting through personnel reporting to Nuclear Operations and Vice to him, for: him, for: President, Fossil and Hydro Operations.

Maintaining/testing Maintaining/testing electrical electrical protective protective devices.

devices.

Performing design verification Performing design testing associated with verification testing electrical protective devices, associated with electrical except when such testing is protective devices, except procured from approved outside when such testing is contractors.

procured from approved outside contractors. Maintaining the Company's Echelon II calibration facility Maintaining the Company's for calibrating reference and Echelon II calibration secondary standards and general facility for calibrating usage portable and Laboratory

+reference and secondary measuring and test equipment.

standards and general usage portable and Laboratory Controlling the calibration measuring and test recall system for Portable and equipment. Laboratory M&TE owned by E&TS, and other departments, as Controlling the calibration requested.

recall system for Portable and Laboratory M&TE owned Maintaining* a Master PL-M&TE by E&TS, and other List for E&TS PL-M&TE and for departments, as requested. other departments, as requested.

Maintaining a Master PL-M&TE List for E&TS PL-M&TE Providing a PL-M&TE Inventory and for other departments, List for Nuclear Operations.

as requested.

Providing chemistry support to Providing a PL-M&TE Nuclear Operations, as Inventory List for Nuclear requested.

Operations.

Page 5

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion Providing chemistry support Preparing, reviewing, approving to Nuclear Operations, as and obtaining additional requested. reviews and approvals if required, of purchase requests Preparing, reviewing, for services, equipment and approving and obtaining consumables, and submitting additional reviews and such requests to purchasing for approvals, if required, of procurement action.

purchase requests for services, equipment and Conducting performance tests on consumables, and submitting materials, equipment and such requests to purchasing systems when requested.

for procurement action.

Performing nondestructive Conducting performance examination, and tests on materials, controlling/maintaining NOE equipment and systems when equipment.

requested.

Providing qualified NOE Performing nondestructive procedures and equipment and examination, and NOE personnel.

controlling/maintaining NOE equipment. Providing chemical and metallurgical analytical Providing qualified NOE services.

• procedures and equipment and NOE personnel. Providing necessary corrective action processing and status Providing chemical and reporting for assigned metallurgical analytical corrective action documents.

services.

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

Page 6

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 13 Not in this Revision.

Responsibility for Attaining Reorganization - No change in Level of Quality Objectives in the Quality Program commitments commitment to the Quality Fossil and Hydro Operations realigned under Vice President, Program.

Organization. Nuclear Operations and Vice President, Fossil and Hydro The Vice President, Fossil and Operations.

Hydro Operations (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer. Managers reporting to him are responsible for directing the performance of activities in accordance with Quality Program requirements.

14 Page 7 1.2.3.a

b. The Manager, Equipment The Manager, Equipment Services Reorganization - No change in Level of Services & Field & Field Maintenance Services Quality Program commitments commitment to the Quality Maintenance Services provides electrical, rotating realigned under Vice President, Program.

provides electrical, and stationary equipment Nuclear Operations and Vice rotating and stationary expertise and provides field President, Fossil and Hydro equipment expertise and maintenance services for operations.

provides field maintenance assigned modification and services for assigned maintenance tasks.

modification and maintenance tasks.

Page 7

QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 15 Page 7 1.2.3.b

c. The Manager, Projects, The Manager, Projects, Reorganization - No change in Level of Engineering and Engineering and Construction, Quality Program commitments commitment to the Quality Construction, maintains the maintains the Records realigned under Vice President, Program.

Records Management System Management System including Nuclear Operations and Vice including required required retention, protection President, Fossil and Hydro retention, protection and and retrievability. This Operations.

retrievability. This includes collecting, storing, includes collecting, maintaining, distributing and storing, maintaining, controlling plant distributing and Engineering/Design doci.ments controlling plant (Big Rock only).

engineering/design documents (Big Rock only).

16 Responsibility for Attaining Responsibility for Attaining Quality Objectives Outside Quality Objectives Outside Nuclear Operations and Energy Nuclear Operations.

Supply Services Environmental and Technical Services and Fossil and Hydro Certain functions that Operations*

• constitute part of the Nuclear Operations Quality Program are Certain functions that Reorganization - Quality No change in Level of performed by CPCo constitute part of the Nuclear Program commitments realigned commitment to the Quality organizational units outside of Operations Quality Program are under Vice President, Nuclear Program.

the Nuclear Operations performed by CPCo organizations Operations and vice President, Department of Energy Supply units outside the Nuclear Fossil and Hydro Operations Services Operations, Environmental and Technical Services Department or Fossil and Hydro operations.

Page 8

Revision 12 Revision 13 QUALITY PROGRAM DESCRIPTION CCPC*2A)

REVISION 13 Reason for Change Basis for Conclusion 17 Page 9 Page 9 Figure 1 Figure 1 President and Chief Executive President and Chief Executive Reporting relationship No change in level of Officer and Executive Vice Officer and Vice President and clarified. conmitment to the Quality President and Chief Operating Chief Operating Officer Program.

Officer identified in two identified in one box with a separate boxes. doted line between titles.

18 Page 9 Page 9 Figure 1 Figure Vice President, Human Resources Vice President, Human Resources Reporting relationship No change in the level of reporting line to President and reporting line to Executive clarified. conmitment to the Quality Chief Executive Officer. Vice President and Chief Program.

Operating Officer.

19 Page 9 Page 9 Figure 1 Figure Vice President, Nuclear Vice President, Nuclear Reorganization - Quality No change in level of Operations Operations, Envirorvnental and Program conmitments realigned conmitment to the Quality Technical Services under Vice President, Nuclear Program.

Operations and Vice President, Fossil and Hydro Operations Page 9

c~ -

QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 20 Page 9 Page 9 Fisure 1 Figure 1 Executive Manager, Corporate Executive Manager Corporate Editorial Editorial Training Training and Development 21 Pase 9 Fisure 1 Vice President, Energy Supply Not in this Revision. Reorganization - No change in Level of Services Quality Program conmitments conmitment to the Quality realigned under Vice President, Program.

Nuclear Operations and Vice President, Fossil and Hydro Operations.

22 Page 9 Figure 1 Not in this Revision. Vice President, Fossil and Reorganization - No change in Level of Hydro Quality Program conmitments conmitment to the Quality realigned under Vice President, Program.

Nuclear Operations and Vice President, Fossil and Hydro Operations.

23 Pase 9 Page 10 Figure 1 Figure 2 Manager Environmental and Manager Environmental and Reorganization - No change in the level of Technical Services Technical Services Environmental and Technical conmitment to the Quality Services realigned under Vice Program.

President, Nuclear Operations.

Page 10

QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 24 Page 10 Figure 2 Box identifying Nuclear Not in this Revision. Editorial Editorial Operations Department.

25 Page 10 Page 10 Figure 2 Figure 2 Vice President, Nuclear Vice President, Nuclear Reorganization - Quality No change in level of Operations Operations, Environmental and Program comnitments realigned comnitment to the Quality Technical Services under Vice President, Nuclear Program.

Operations and Vice President, Fossil and Hydro Operations 26 Page 10 Figure 2 Performance Specialist, 7 Not in this Revision. The Nuclear Performance The level of comnitment remains Members Assessment Department the same (see Item 2b in organization is an unnecessary Appendix A, Part 2). The NPAD level of detail in this Quality organization is described in Program Description. Plant Technical Specification.

27 Page 10 Figure 2 Performance Trending Supervisor Not in this Revision. To make the language consistent No change in the level of with Exception/Interpretation comnitment to the Quality 3a on Page 57 of the Quality Program. NPAD is responsible Program Description. for review of performance trends per Exception/

Interpretation 3a of this Quality Program Description.

Page 11

QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 28 Page 10 Figure 2 Assessment Program Supervisor Not in this Revision. The Nuclear Performance The level of commitment remain Assessment Department the same. No change made in organization is an unnecessary the Assessment Program.

level of detail in the Quality Program Description.

29 Page 10 Page 10 Figure 2 - Page Caption Figure - Page Caption Nuclear Operations Department Nuclear Operations, Reorganization - Environmental No change in the level of Organization Environmental and Technical and Technical Services combined commitment to the Quality Services with Nuclear Operations. Program.

30 Page 12 2.2.5.a Nuclear Operations Department Administrative Procedures CPCo is eliminating the NOD CPCo has chosen the option of Standards (NODS) and/or specify the standard methods of Standard from the hierarchy of the use of Administrative Administrative Procedures accomplishing operational phase documents. Procedures rather than the NOD specify the standard methods of activities. Because the Standards. The NOD Standards accomplishing operational phase Quality Program is an integral were originally developed when activities. Because the part of the operational phase the Midland Nuclear Plant was Quality Program is an integral activities, the methods for still under construction and part of the operational phase implementing Quality Program much of the engineering activities, the methods for controls are integrated into function was located in implementing Quality Program these documents. Jackson. With each plant now controls are integrated into performing most key functions these documents. onsite, the NOD Standards were no longer serving their intended purpose.

Page 12

QUALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 31 Pase 12 Page 12 2.2.5.c 1st Sentence 2.2.5c 1st Sentence Applicable elements of the Applicable elements of the Editorial Editorial operations Quality Program are Quality Program Description for applied to emergency plans, Operational Nuclear Power security plans, radiation and Plants are applied to emergency fire protection plans on CPCo plans, security plans, nuclear power plants. radiation and fire protection plans for CPCo nuclear power plants.

32 Pase 14 Page 14 2.2.9(b) 2.2.9(b)

Personnel who perform Personnel who perform Clarification Incorrect reference made in Rev inspection and examination inspection and examination 12.

functions are qualified in functions are qualified in accordance with requirements of accordance with requirement of Regulatory Guide 1.58, SNT TC- Regulatory Guide 1.58, SNT TC-1A, or other ASME Code, or 1A, or other ASME Code, or Section 10.2.7 of this Quality Section 10.2.3 of this Quality Program description, as Program description as applicable. applicable.

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ENCLO CHANGE QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 33 Page 32 and 33 Page 32 and 33 10.2.3, 1st Sentence 10.2.3, 1st Sentence Training and qualification Training and qualification Clarification programs for personnel who programs for personnel who perform inspections, including perform inspections, including nondestructive examination, are nondestructive examination, are established, implemented and established, implemented and documented in accordance with documented in accordance with Section 2.0 of the QPD does not Section 2.0, QUALITY PROGRAM. plant or offsite procedures, as contain the training and applicable. qualified program for These programs meet the inspection personnel. This requirements of applicable These programs meet the level of detail is contained codes and standards. The Plant requirements of applicable within plant procedures.

General Manager/Manager is codes and standards. The Plant responsible for review and General Manager/Manager is Also, offsite groups, concurrence with any such responsible for review and specifically NOE, are not part programs that are not under his concurrence with plant training of the plant organization, direct responsibility except and qualification programs that their training and for activities performed at are under his direct qualification program are Palisades that are under the responsibility. For activities described in the E&TS cognizance of Nuclear performed at Palisades that are procedures.

Engineering and Construction. under the cognizance of Nuclear In those cases, the Manager, Engineering and Construction, Nuclear Engineering and the Manager, Nuclear Construction is responsible for Engineering and Construction is review and concurrence for such responsible for review and programs. Qualification and concurrence for such *programs.

certification of inspection and NOE personnel are maintained. Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are documented in E&TS procedures.

Qualification and certifications of inspection and NOE personnel are maintained.

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QUALITY PROGRAM DESCRIPTION CCPC-2A)*

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 34 Page 36 Page 36 11.2.3, 2nd to Last Paragraph 11.2.3, 2nd to Last Paragraph Test procedures and Test procedures and Clarification Offsite groups like E&TS have instructions are reviewed by instructions are reviewed for the technical expertise to the engineering organizations technical content and quality perform review of their test for technical content and aspects by the plant procedures for technical and quality aspects. engineering organization, or quality aspects.

the offsite technical organization, as applicable.

35 Page 58 Page 58 4a ANS 3. 1 ANS 3. 1 Exception/Interpretation Exception/Interpretation Since lead auditors are trained Lead auditors are trained and Clarification With the transfer of the and qualified to Regulatory qualified to Regulatory Guide Quality Assurance function to Guide 1.146, the CPCo 1.146. All other personnel are the line organization as conmitment in this Quality trained and qualified as approved in Revision 12, Program Description to ANS 3.1 designated in the plant personnel training and is limited to those requirement Technical Specifications. qualification is now according which apply to the training and to the Plant Technical qualifications of personnel Specifications. Personnel who leading audits. perform audits are still trained and qualified to meet RG 1.146; Page 15

QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 36 Page 58 Page 58 RG 1.8, C.3.1 RG 1.8. C3.1 Exception/Interpretation Exception/Interpretation Since lead auditors are trained Lead auditors are trained and Clarification With the transfer of the and qualified to Regulatory qualified to Regulatory Guide Quality Assurance function to Guide 1.146, the CPCo 1.146. All other personnel are the line organization as conrnitment in this Quality trained and qualified as approved in Revision 12, Program Description is limited designated in the plant personnel training and to those requirements which Technical Specifications. qualification is now according apply to the training and to the Plant Technical qualifications of personnel Specifications. Personnel who leading audits. perform audits are still trained and qualified to meet RG 1.146.

37 Page 71 Page 71 16c Exception/Interpretation 16c Exception/Interpretation In addition to the exemptions In addition to the exemptions Editorial Name change only.

of RG 1.144, CPCo considers of RG 1.144, CPCo considers that Authorized Inspection that Authorized Inspection Agencies, National Bureau of Agencies, National Institute of Standards or other State and Standards and Technology or Federal Agencies which may other State and Federal provide services to CPCo are Agencies which may provide not required to be audited. services to CPCo are not required to be audited.

38 Page n Page n 17b Exception/Interpretation 17b Exception/Interpretation Refer to Item 2k. Refer to Item 2l Editorial Editorial Page 16

Revision 12 Revision 13 EN CLO CHANGE QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Reason for Change Basis for Conclusion 39 Page 73 Page 73 17f Exception/Interpretation 17f Exception/Interpretation Refer to Item 2l. Refer to Item 2m Editorial Editorial 40 Page 74 Page 74 18a Exception/Interpretation 18a Exception/Interpretation RG 1.26 was used as a reference RG 1.26 was used as a reference To avoid confusion in the use *As stated in Rev 12, Exception to establish piping system to establish piping system of Regulatory Guide 1.26 and 18a implies that safety-related boundaries, but not for boundaries, but not for Regulatory Guide 1.29. determinations are based upon defining specific quality defining specific quality the content of RG 1.29 (subject groups or making safety-related groups or making safety-related to Exception/Interpretation determinations. Regulatory determinations. Regulatory 20a). Exception 20a states in Guide 1.29, subject to Guide 1.29, subject to Paragraph 2, "The criteria of Exception/Interpretation 20a, Exception/Interpretation 20a, this Regulatory Guide are used is used to determine what is used to determine what at CPCo primarily in the systems and equipment are systems and equipment are identification of systems, safety-related. included in the Quality structures, and components to Program. which the Quality Program is applied (see 20b below)." As the Quality Program applies to those items which may not perform a safety-related function but are considered important to plant operability, as well as those items considered safety-related, Exception 18a should be changed as requested above to avoid confusion in the use of RG 1.26 and RG 1.29.

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QUALITY PROGRAM DESCRIPTION CCPC-2A)

REVISION 13 Revision 12 Revision 13 Reason for Change Basis for Conclusion 41 Page 75 Page 75 20a Exception/Interpretation 20a Exception/Interpretation 2nd Paragraph 2nd Paragraph The criteria of this Regulatory The criteria of this Regulatory Editorial Editorial Guide are used at CPCo Guide are used at CPCo primarily in the identification primarily in the identification of system, structure, and of system, structure, and components to which the QA components to which the Quality Program is applied (see 20b, Program is applied (see 20b below). below).

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