ML18066A910
| ML18066A910 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/07/1997 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18066A911 | List: |
| References | |
| NUDOCS 9703180222 | |
| Download: ML18066A910 (4) | |
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consumers Power l'OWERlllli llllClllliAll-S l'IUllillUS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 7, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas C. Bordlne Manager, Licensing QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS - REVISION 17 In a letter dated December 11, 1995, we submitted a Technical Specifications Change Request to revise the administrative controls contained in the Technical Specifications.
The proposed change revised the Administrative Controls section to emulate the CE Standard Technical Specifications by removing the Review and Audit requirements of Section 6.5 and the record retention requirements of Section 6.10 from the Technical Specifications and relocating them in the Consumers Power Company Quality Program Description, Topical Report CPC-2A. The change also deleted several requirements which duplicate requirements of 10 CFR 50, and proposed numerous administrative changes which would result in the Administrative Control Section being nearly identical to the Standard Technical Specifications, Combustion Engineering Plants, NUREG 1432, both in content and arrangement.
The original submittal was supplemented by later submittals dated January 18, 1996, September 3, 1996, October 2, 1996, and October 18, 1996.
In partial response to these submittals, the NRC issued Amendment 174 to the Facility Operating License. In subsequent follow-up conference calls concerning the status of
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the remaining changes still under review, we have discussed the format of and our J
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2 Power Plants - CPC-2A. Our December 11, 1995, Technical Specification Change Request proposed moving controls related to review and audit and procedural controls from the Technical Specifications to our Quality Program Description. We have included the Technical Specification requirements in a section of CPC-2A entitled "Policy". During a conference call, the NRC reviewer sought assurance that the portions of the program description entitled "Policy" were commitments for implementation and not just statements of intent. This letter responds to the reviewer's concern.
Topical Report CPC-2A in its entirety comprises the Quality Program Description, (QPD) for the Palisades Plant and is implemented as such. Various portions of the Quality Assurance Program Description contain statements that affirm the document as a whole represents Program requirements and not merely intentions.
The Statement of Authority Letter states... "The Quality Assurance Progr_am Description contains mandatory requirements which must be implemented and enforced by all responsible organizations and individuals."
Section 2.1, under Quality Program states... "Policies that define and establish the CPCo Quality Program for Operational Nuclear Power Plants are stated in the individual sections of this document."
Section 2.2.1, referencing the Statement of Authority Letter states... "This statement. makes the QPD and the associated implementing procedures and instructions mandatory and requires compliance by all responsible organizations and individuals... "
Section 2.2.4 states... "This QPD, organized to present the CPCo Quality Program for Operational Nuclear Power Plants in order of the 18 criteria of 10 CFR 50, Appendix B, states CPCo policy for each of the criteria and describes how the controls pertinent to each are carried out."
The entire document is, therefore, considered subject to the controls of 1 O CFR 50.54, and a change to any section, including the "policy" sections, that might reduce our commitments regarding the quality program would require NRC approval. Therefore, we make no distinction between sections labeled "policy" and any other part of the document when it comes to implementation.
Attached is a copy of the latest revision to the Quality Program Description for Nuclear Power Plants - Topical Report CPC-2A to facilitate your reviews of the remaining proposed Technical Specifications changes.
SUMMARY
OF COMMITMENTS
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This letter contains no new commitments and no revisions to existing commitments.
Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 3
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ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS-CPC-2A REVISION 17 Pages