ML20138H798

Rev 4 to QA Program Description for Operational Nuclear Power Plants

ML20138H798
Person / Time
Site:	Palisades, Big Rock Point, 05000000
Issue date:	10/18/1985
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20138H773	List: ML20138H769 ML20138H798
References
CPC-2A, NUDOCS 8510290152
Download: ML20138H798 (115)

Text

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ATTACHMENT I

Consumers Power Company Big Rock Point & Palisades Plants Dockets 50-155 & 50-255 TOPICAL REPORT CPC-2A (REV 4)

QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS October 18, 1985 8510290152 851018 PDR P ADOCK 05000155 124 Pages PDR I

IC1085-0008A-NLO2

1 D List of CPC-2A Pages with Changes in Revision 4 J D Selby Letter 31 11 35 iv 36 1 37 2 38 3 43 4 45 5 46 6 47 7 48 8 49 9 51 10 53 11 55 12 56 19 57 20 60 21 61 22 62 23 64 25 76 26 78 g 29 79 30 83 I

IC-0985-0005A-QA05

QUnllTY ASSURANCE PROGRAM DFSCRIPTION (CPC-2A)

REVISION 3 REVISION 4 Reason For m ange Basis Por Conclusion Statement Of Responsibility and Authority. Statement of Responsibility and Authority.

Paragraph 2 Paragraph 2 1 have delegated the authority for the es- I have delegated the authority for the tabitshment and maintenance of the Quality Reorganisation eliminates PE&c as a Since the change is only a realignment Assurance Program Description to tt'e Execu- estab!!shment and maintenance of the department, transferring all plant modi-Quality Asagrance Program Description to fications to Energy Supply. Also, the of responsibilities, no reduction in tive Vice Prealdent - Energy Supply for the Executive Vice President, Energy cemitment is involved.

operational phase activities, and to the Supply for operational phase activities QA responalbilities of the Director, Faecutive Vice President responalble for Environmental and Quality Assurance are Project Engineering and Construction on and plant modifications, and in turn to combined with those of the Executive the Executive Director, Nuclear Assurance. Director-Nuclear Assurance, certain plant modifications, and in turn The Executive Director, Nuclear Assurance to the Executive Director - Nuclear is also authorized te verify the effective Assurance and the Director Environmental implementation of the Quality Assurance and Quality Assurance, respectively. These Program Description.

Directors are also authorised to verify the ef fective implementation of the Quality Assurance Program Description.

Approval Page Approval Page Executive Vice President Reorganization moved certain responsibi- Since this change is only a realignment Date Executive vice President, Date bilities - determining settings for S H Howell Energy Distribution l electrical protective systems and relay of existing responsibilities, no reduction S H Howell control systems, and design, review and in consiteent is involved.

recommended changes to protective schemes and associated settings - into the Energy Distribution organization.

Vice President Fossil Operations Date As part of the reorganisation, Possil Since this change is only a realignment Vice President. Energy Supply Date Operations was expanded to include C R 811by Services services in support of fossil and nuclear of existing responsibilities, no reduction C R Bilby in commitment is involved.

operating plants and is renamed accordingly.

Vice President, System Operatione Date Reorganization moved certain responal- Since this change is only a realignment C L Hein Vice President. Distribution Date bilities - determining settings for of existing responalbilities, no reduction Operations electrical protective systems and relay R C Lincoln in commitment la involved.

control systems, and deatsn, review and recossmended changes to protective schemes and associated settings - into the Energy Distribution organisation. Other quality related responsibilities for analytical responsibilities were transferred to Energy Supply Services.

Promotion. Since no responsibilities or QA controls Executive Manager, General Date Vice President General Services Services R A Wells Date l are impacted, no reduction in commitment R A Wells is involved.

QA0985-0002A-TJ01 t_ _ -_

2 QUALITY ASSURANCE PROCRAM DESQt!PTION (CPC-2A)

REVISION 3 REVISION 4 Reason For Qiange Basis For O m lusion Content Pese - Ptsures Content Pate - Figures 6 Projects. Engineering and 6 Energy Supply Services Construction Organisation . . . . 20

. . . . 18 Figures were changed to reflect the organ- See basis for remainder of Policy 1.

instion described in the test of Policy 1.

7 Environmental and Quality Assurance Organization . . . . . 21 8 Plant Modifications and Miscel-laneous Projects Organtaation . . 22 QA0985-0002A-TJ01

QUAL.ITY AS$ PRANCE PROGRAM DI:SCRIPTION (OC-2A) 3 REVISION 3 REVISION 4 Reason For Qiange Baats For Conclusion 1.1 POLICY Paragraph 1 1.1 POLICY. Paragraph I Consumers Power Ca pany (CP Co) is tsapon- Consumers Powr Company (CP CO) is respon- Change clarifies that the QA Program alble for establishing and implementing the sible for establishing and implementing The change only clarifies the existing Quality Assurance Program for the opera- discussed le as described in CPC-2A and language, thus no reduction in comm.t-the Quality Assurance Program, as described and not elsews.cre.

tional phase of its nuclear power plants. heree n, for the operational phase of its ment is involved.

Although authority for development and nuclear power plants. Although authority esecution of some parts of the progras is for development and execution of some parts delegated to others, such as contractors of the program is delegated to others, and consultants, CP Co retains overall such as contractors and consultants, CP Co responalbility. retains overall responsibility.

1.1 PO1. ICY. Paragraph 2 1.1 POLICY, Paragraph 2 This section of the Quality Assurance This section of the Quality Assurance Policy 1 identifies the organizations Program Description (QAPD) identifies the Program Description (QAPD) identifies the Since the change only clarifles responsible for activities and their estating language, no reduction CP Co organizational responalbilities for CP Co organisations responsible for major responsibilities rather than activities af fecting the quality of activities af fecting the quality of safety- in commitment is involved.

their total responsibilities.

safety-related nuclear power plant struc- related nuclear power plant structures, tures, systems and components and describes systees and components and describes the the authority and duties assigned to them, authority and duties assigned to them.

it addresses responsibilities for both it addresses responsibilities for both attaining quality objectives and for the attaining quality objectives and for the assurance functions of establishing the assurance functions of establishing and Quality Assutance Program and verifying maintaining the Quality Assurance Program that activities affecting the quality of and verifying that activities af fecting safety-related items are performed in the quality of safety-related items are accordance with QA program requirements. performed in accordance with QA program requirements.

1.1 P01 ICY. Paragraph 3 1.1 POLICY. Paragraph 3 Quality assurance functions (as defined Quality assurance functions f as defined See Reason for Change / Basis for above) are performed by personnel with!n above) are performed by personnel within Conclusion for Statement of formally designated Quality Amaurance foal farmally destenated Quality Assurance (QA) Authority revisions, creaatratta.4 a s, specific areas of organisational units. %:fP areas of responalbility and authority are delegated responsibility and authority are deles.R I to these units by the individual assigned to these units by the individual assigned overall responalbility and authority for overall responsibility and authority for the QA Program. The reporting level of the the QA Program. 1he reporting level of the Nuclear Assurance and the Environmental and Nuclear Assurance organtaation af fords Quality Assurance organisations affords sufficient authority and organisational sufficient authority and organizational freedom, including sufficient independence freedcan, including suf ficient independence from the cost and schedule impacts of QA from the cost and schedule impacts of QA organtration actions, to enable people in organization actions, to enable people in that organization to identify quality pro-those organizations to identify quality blems; to lattiate, recommend, or provide problems; to initiate, recommend, or solutions; and to verify implementation of provide solutions; and to verify implemen- solutions. Q4/QC functions at the nuclear tation of solutions. QA/QC functions at plants are performed by onsite quality QA0985-0002A-TJ01

4 QUALITY ASStrRANCE PROGRAM DESOt!PTION (CPC-2A)

REVTSION 3 REVISION 4 Reason For O ange gasts Por Conclusion the nuclear plants are performed by onsite assurance crganisations that report to the quality assurance organizations that Executive Director, hetear Assurance.

report to the Executive Director-Nuclear Assurance or, as appropriate, by onalte or of fsite quality assurance personnel who report to Environmental and Quality Aamurance 1.2.1 Source of Authority 1.2.1 Source of Authority The President and Chief Executive Officer The President and Q tef Executive Officer (see Figure 1 of Company Organization (see Figure 1 of Company Osgantaation See Reason for mange / Basis for Conclusion for Statement of Authority revision.

Charts) of CP Co is responsible for safe Garts) of CP Co is responsible for safe operation of CP Co nuclear power plants. operation of CP Co nuclear power plants.

Authority and responalbility for establisha Authority and responsibility for establish-ing and implementing the QA Program for ing and implementing the Q4 Program for plant operations, maintenance and those plant operations, maintenance and modifica- l modifications accomplished by the Nuclear tions is delegated through the Executive i Operations Department, is delegated through Vice President, Energy Supply to the Vice the Executive Vice President - Energy President, Nuclear Operations (see Supply to the vice President - Nuclear Pisure 2). This delegation is formalized l Operations (see Figure 2). Similar author- in a STATEEJfT OF RESPONS1sILITY AND ity and responalbility for establishing and AUTHORITY signed by the President and implementing the QA Program for those modt- Glef Executive Officer. Other quality-fications accomplished by the Projects, related functions are provided by other Engineering and Construction organisation organtaations as described herein.

is delegated to the Executive Vice President (see Figure 6). This delegation is formalised in a STATEENT OF RESPONSI-BILITY AND AUTHORITY signed by the President and Chief Executive Of ficer.

1.2.2 1.2.2

a. The Plant General k nager / Plant Super- a. The Plant Ceneral Manager / Plant Super- The term " Managers" is used to provide intendent (see Figure 3) are responsible Since the change is only editorial, no intendent (see Figure 3) are responsible a more generic term for management reductioa in coassitment is involved, to the Vice President - Nuclear Opera- to the Vice President, Nuclear Opera- personnel.

tions for operation and maintenarice of tions for operation and maintenance of the nuclear power plants in such a the nuclear power plants in such a manner as tu achieve cmpliance with manner as to achieve compliance with Plant Itcenses, applicable regulations Plant licenses, applicable regulations and the QA Program. Each Plant General and the QA Program. Each Plant General Manager or Plant Superintendent dele- Manager or Plant Superintendent dele-gates to appropriate fun:tional auper- gatestoappropriatemanagersandstaffl intendents and staf f personnel in his personnel in his organlaation responst-organisation responsibility for carry- bility for carrying out applicable ing out applicable controls required controls required by the Quality by the Quality Assurance Program. QA Assurance Program. QA Program activi-Program activities performed on the ties perfurned on the authority of the authority of the Plant Ceneral Manager Plant Ceneral Manager or Superintendent or Superintendent includes includes QA0985-OOO24-TJOi

r- -

3 5

QtJALITY ASSURANCE PROGAM DESCRIPTION (CPC-2A)

REVISION 1 REVISION 4 Reason Por Gange Basis For Conclusion 1.2.2a. Paragraph 2 1.2.2a. Paragraph 2 Assuring that plant operating and @alification of plant operating and The change clarifies that the Plant General maintenance personnel are properly maintenance personnel. Since change does not alter existing qualified for their duties. Manager / Superintendent is responsibile responsibilities or controls, no for the qualification of plant personnel reduction is commitment is involved.

rather than "assurring" that they are qualifted.

1.2.2a. Paragraph 9 None Controlling a calibration recall system

~ These two responalbilities are added $1nce the change is only a realignment for PL-M&TE our:ed by the plant. to reflect the Plant's responsibility of a responsibility previously assigned for its own MATE. to SP."t.S. It is not a reduction in eosmitment.

1.2.2a, Paragraph 10 hone

- Maintaining a Master List for plant owned PL-MbfE.

1.2.2a. Paragraph 10 1.2.2a, Paragraph 12 Onatte evaluation of corrective action Onsite evaluation of corrective action he reference is deleted to provide documents in accordance with Section 16.0, documents, including initial determination Since the change is only editorial, no consistency with other statements which CORRECTIVE ACTION, including initial of reportability to the NPC. reduction in commitment is involved.

determination of reportability to the NRC.

do not reference Policies.

1.2.2a. Paragraph 10 1.2.3a. Parmaraph 11 Operating tue dostmetry laboratory (includ- Operating the dostaetry laboratory (includ- The responsibility for the dosteetry ing preparatica and maintenance of occupa- ing preparation and maintenance of occupa- Since the change only involves a realign-laboratory is reassigned by the recent ment of an esisting responsibility, thus tional radiation and esposure records). tional radiation and esposure records). reorganization to Energy Supply Services. no reduction in commitment is involved.

1.2.2 1.2.2

c. The Eaecutive Director - Nuclear Plan- d. Other positions reporting to the the responsibility for NODS, biennial ains and Administration (see Figure 3) Vice President, Nuclear Operations Since the change only involves a realign-assessment and Corporate Emergency ment of an existing responsibility, thus as administrative control of Nuclear (not shan in Figure 3) are Planning are retained under the Vice Operations Department Standarda and the responalble for: --- Prealdent, Nuclear Operations. Other no reduction in commitment is involved.

biennial assessment of 04 Program QA program controla are reassigned to effectiveness and delegates authority Administrative control of Nuclear Energy Supply Services, for other QA Program controls to the operations Department Standards Directors of Nuclear Services. Nuclear and the biennial assessment of QA Operations Training, Nuclear Planning, Program offectiveness.

QA0985-0002A-TJ01

QUALITT ASSURANCE PROCRAM DES 31PTION (CPC-2A) .

REVISION 3 REVISION 4 Reason Por m ange gasta For Conclusion the Senior Staf f Engineer-Plant Pro-jects and the Emergency Planning Admin-tetrator. Controlled activities include:

Establishing, implementing and docu- 1.2.3c, Paragraph 2 menting the training of IKD operations and technical support personnel, to- Establishing, taptementing and documenting cluding QA Program Indoctrinattom and the training of operations and technical training of NOD personnel. support personnel, including QA Program Indoctrination and training, and operating the Skilla Center.

Preparing and obtatatng required See 1.2.3c, Paragraph 3, below rewtews and approvals of purchase requests.

1.2.2d, Paragraph 3,1.2. 3a , Paragraph 16,

1. 2. 3b , Faragraph 4, and 1. 2. 3c , Fa ragraph 5 Providing necessary corrective action Providing necessary corrective action processing and sta % s reporting for processing and status reporting for assigned corrective action documents. assigned corrective action documents.

1.2.2d, Paragraph 4 Coordinating Corporate Emergency Coordinating Corporate Emergency Planning. Planning.

1.2. 3c, Paragraph 3 Preparing and obtaining required Preparing and obtaining reviews and approval reviews and approval of ccetracts of contracts and providing approved procure-and providing approved procurement ment pwkages to Purchasing f or action, as packages to Purchasing for action, assigned.

as assigned.

1.2.2 1.2.2

d. The Director - Nuclear Licenatng (see c. The Director, Nuclear Licensing (see mange reflects most common types Ptgure 3) is responalble for: Pisure 3) is responalble fors of NRC doctments.

Since the change is only editorial, providing examples of documents, no change in commitment is involved.

Accomplishing plant licensing activt- Accomplishing plant licensing acts en-ties including maletalning licensing ties including maintaining licensing documents up-to-date, interfacing with documenta up-to-date, interfacing with tt.e NRC, accomplishing and/or tracking the NRC, accomplishing and/or tracking licensing commitments and coordinating Itcensing commitments and coordinating internal action on NRC bulletins, Internal action on NRC bulletins, circulars, notices, etc. gineric letters, etc.

QA0985-OOO2A-TJ01 e

QUALITY ASSL1 TAN (T PROGRAM DESCRIPTION (CPC-2A) 1 REVISION 3 REVISION 4 Reason For mange 1.2.3 Responsibility for Attaining Quality Basis For Conclusion

1. 2. 3 Object ives in the Projects. Engineering and Construction Orsanisation The Executive Vice President (see P!gure 6) b. he Executive hnager, Engineering and to responalble for major modtitcations to he change reflects the transfer of he change only realtans the responst-CP Co nuclear power plaats (ie, any nuclear Field Operations (EFO) is responsible, responsibility for major modifica-through Managers and Directors report- projects as a result of the bilities for major modtitcations under power plant modificattom assigned to PE&C), ing to him fort under Engineering and Field Operations Directors and Managers reporting to him are elimination of the PEAC Department.

The thange also abbreviates the and thus does not reduce commitments.

responalble for directing the performance Performing the engineering, construc-of activities that af fect easigned modtil- tion, preoperational testing and over-description of lower tiers of cations in accordance with QA Program management responsibilities to be requirements, all project management of generating consistent with the remainder of plant major modification projects. Policy 1.

h is includes functioning, as appro-priate, as either the lead design organtaatton den auch projects are engineered in-house or as the Capany's design reviewer den those projects are done by outside engineering organizations.

a. he Executive Manager - Plant Modifica-tions and Miscellaneous Projects (PMbMP)

(see Figure 8) is responsible for per-foretag in a quality manner the engi-neering, construction, preoperational testing and overall project management of generating plant modtiteetton pro-jects. For operational nuclear power plants, this includes the responsibility f or performing design, construction, schedule control, testing and coste, for those modification projects assigned to the PfEMP Organization, as follows:

The Esecutive mnager - Plant Modtitca-tions and Miscellaneous Projects is responsible for the following depart-ments reporting to him.

(1) Engineering Department - his Department has the responsiblitty for providing the technical esper-time and direction for mator modifications. As such, it will function, as appropriate, as either the lead design organization een such projects are engineered in-house or as the Ca pany's design reviewer een those projects are QA0985-0002A-TJ01 o

8 QtJALITY ASSURANCE PROGRAM DFSdtIPTION (CPC-2A)

REVISION 3 REVISION 4 Reason For Change Basts For Conclusion done by outside engineering orgen-trattoes. It achieves this role by providing the project engineers and supporting staf f to the project management matris organizations.

(2) Staff Consultant - The Staf f Con-sultant performs special studies relating to vertuus activities and needs as requested by the Executive knager. Statf Consultant accom-p!!shes his work either through his own ef forts or by means of work groups or task forces sa he deter-eines necessary.

(3) Project knagement Department -

Reporting to the k nager of Project Management ares (a) Individual Project knagers assigned to manage specific generating plant modtitcations projects and miscellaneous projects. Each knager has overall responsibility for accomplishing, in a quality manner, the design, construc- .

tion, testing, costs, schedul-ing and contract adatatstration for each assigned project utti-1 stas the resources of PM&MP and other Company departments as necessary.

(b) The knager, Construction and Testing Department - The Construction and Testing Depart-ment is responsible for provid-ing staff support and technical expertise on construction and testing matters to the Pmet projects.

This Department also provides qualtfled field supervisory personnel in the construction and testing disciplines for assignment as departmental representatives to each project team.

CA09es-ooo2A-TJon

Qt!ALITY ASSl!RANCE PROGRAM DESCRIPTION (CPC-2Al 9 REVli!ON 3 REVislON 4 Reason For Change 1.2.) Rasts For Conclusion

1. 2. 4

b. The Manager - Electric Transmission - e. The Dire .or, Management and Budget Engineering an.1 Construction Depart- With the recent reorganization, recorda- Since the change does not change the (see F1eare 2) is responsible through related responsib111ttes are consolidated ment is responsible for collecting, the Exa.utive Vice President, Energy controls over recorda but only the etcrottiming, storing, malataining, Supply for maintaining the Records under one organtaatton to provide improve- organtaation responsibilities, no distributing and controlling plant ments in the records management program. reduction in commitment la involved, Manae ment System including required engineering /aesign documents through re' atton, protection and retrieva-the Engineering Recorda Center, t

• itty, operating the General Office t sifsite) Document Control Center and fos st'etaining the Uniform File Inden.

This includes collection, storing, maintaining, distributing and control-

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

1.2.4 Resrmatbility for Attatning Quality 1.2.4 Responsibiltry for Attaining Quality Object t wes Outalde Nuclear Operations and Objectives Outside Nuclear Operations and ~

Frol u ta, Engineering and Construc tion Energy Supply Services Certata functions that constitute part of Certain functions that constitute part of The change results from the elimination the Nur lear Operations QA Program are per- the Nuclear Operatione QA Program are per- of the PEAC Department in the recent Since the change only reflects a shif t formed by CP Co organizational units out- formed by CP Co organtaattonal units out- in responsibilities, no reduction in side the Nuclear Operations Department or reorganisation and the transfer of the side the Nuclear Operations Department or commitment has occurred.

Pro bcts. Engineering and Construction, majority of PE6C responalbilities to Energy Supply Services, as follows: , Energy Supply Services.

as follows:

1.2.4 1.?.4

a. The Director - Property Protection a. The Director, Property Protection (aes Figure 5) la responsible through The changs is made to show the current As the change only reflects title changes.

Services (see Figure 5) is responsible titles of senior management in the the Executive Manager - General Services through the Vice President, General no reduction in commitment is involved, to the Senior Vice President - Energy Energy Distribution organization.

Distribution for developing and nata- Services to the Eaccutive Vice President-taining the Fire Protection and Plant Energy Distribution for developing and maintaining the Fire Protection and Plant Security Plans for the nuclear power Security Plans for the nuclese power plants and for contract administretton plants and for contract adstnistration for the security force. for the security force.

1.2.4 1.2.4

b. The Manager - Administrative Services b. The Manager, Information and Operations Title changes are made to reflect (see Figure 5) la responalble through Management (see Figure 5) la responsible the current organtaation, As the change only reflects title changes, the Eaecutive Manager - General Ser- through the Vice President, Ceneral no reduction in commitment is involved, vices to the Senior Vice Prealdent - Services to the Executive Vice Prest-QA09sbOOO2A-TJ01

(FALITY ASSURANCE PROCRAM DESOt!PTION (CPC-2A)

REVISION 1 REVISION 4 Reasm For Qiange gasts For Conclusion Energy Distributton for microfilming dent, Energy Distributton for microf tin-of specified QA records and furnishing ing of specified QA records and plant copies of the mictofilm recor#- W engineering / design documents, the requised retent'on, protection and retrievability.

1.2.4 1.2.4

c. The Director - harchasing (aes Figure 5) c. The knager, Purchasing and Materials See above.

is responst%3e through the Emecuttse See above, Management (see Figure 5), is responst-Manager - Ceneral Services to the Senior ble through the Vice President, Ceneral to the bestor 91ce President-Energy Services to the Executive Vice Prest-Distributton for initiating procurement dent. Emergy Distributton for tattiattra action based on approved purchase procurement action based on approved requests received from organisations purchase requests received from organt-performing or supporting plant opera- sations performing or agporting plant tien, maintenance or modtiteattoa. operation, maintenance or modification.

1.2.4

d. The knager - System Protection and Laboratory Services (see Figure 2) is responsible, through the Esecutive Manager - Productica and Transmission and the Vice President - System Opera-tions, to the Eaecutive Vice President -

Energy Supply for the following quality-related functicas:

1.2.la Maintaining / testing electrical The Emecutive Manager, Operating and Under the reorganization, this responst- The change er.ly involvies a transfer of protective devices. Technical Services (OfS) is responsible , bility uas transferred to Operating and an established responsibility and thus tor: Maintaining / testing electrical Technical Services.

protective devices. does not involve a reduction in commitment, 1.2.6 Determining settings for electrical f. The Manager, Distributton, Fngineering The responsibility was reassigned The change only involves a transfer of protective systems and relay control and Construction Department (see to Energy Distributton. an estat,11shed responsiblitty and thus systass. Figure 5) is responsible ... for:

Determining settings for electrical does not involve a reduetta in commitment.

Reviewing / recommending changes to systems, and for design, review and electrical protective schases and recommending changes to electrical associated settings. protective schemes and associated settings.

4A0985-0002A-TJ01

QtIALITY ASSURANCE PROCRAM DESO IPTION ( OC-2A) 11 REVISION 3 kIVISION 4 Reason Por G ange Basta Por conclusion 1.2.3a. Paragraph 3 Performing design vertitcattom testing Performing design vertitcation testing associated with the above items, except The responsiblitty is reassigned to Since the revistun is only a realignment when auch testing is procured from associated with electrical protective Operating and Technical Services.

approved outside contractors, devices, eacept then such testing is of responsibilities, no change in procured from approved outside commitment is involved.

contractors.

1.2.3a, Paragraph 4 Maintaining the Campany's Echelon II Maintaining the Campany's Echelon II calibrattom f actitty for calibrating See above. See above.

reference and secondary standards and calibration factitty for calibrating reference and secondary standards and general usage portable and laboratory general usage portable and laboratory M&TE. measuring and test equipment.

1.2.3a. Paragraph 5 Controlltr.g the callbrattom recall Contrattlag the calibration recall system for Portable and Laboratory See above. See above, DETE.

system for Portable and Laboratory MkTE owned by OETS, and other depart-meats, as requested.

1.2.3a. Paragraphs 6 and 7 hone

~ Maintaining a Master PL-METE List for 06TS These additions were made to clearly PL-MkTE and for other departments, as identify the responsibility for maintaining By adding additional responsibilities, requested. our commitment is, in fact, increased.

METE IIsts (see also 1.2.2a, Paragraphs 9 and 10).

Maintaining a Ccapany PL-M&TE Inventory List.

1.2.3a. Paragraph 9 Ducumenting justification for, and Documenting juat titcat tun for, and The responsiblitty is reassigned to author 13 tag use of, reference cali- authortaing use of, reference salibration Operating and Technical Services. Since the revision is only a realtgruner4 bratton standards having an accuracy standards having an accuracy less than of responsibilities, no change in less them four times that of secondary four times that of secondary standards commitment is involved, standards betag calibrated, being calibrated.

1.2.3a. Paragraph 10 Preparing, and obtaining the required Preparing and obtaining the required reviews See above.

reviews and approvals of, purchase See above, and approvals of purchase requests for requests for services, equipment and services, equipment and consumables, and consumables, and submitting such submitting such requests to Purchasing for requests to Purchasing for procurement procurement action.

action.

s QA0985-OOO2A-TJGI

QtJALITY ASSURANCY PROCRAM DESCRIPTION (CPC-2A) 12 REVISION 3 REVISION 4 Reason For Change Basis For Conclusion 1.2.la. Paragraph 12 Conducting performance tests on mate- Conducting performance tests on materials, rials, equipment and systems, as See above. See above.

equipment and systems.

requested.

1.2.la. Paragraph Il Perferning mondestructive esamination, Perforatng nondestructive emaninattun, and and controlling / maintaining NDE See above. See above.

equipment. controlling / maintaining NDE equipment.

I.2.3a. Paragraph 14 Providing qualified NDE procedures and Providing qualif ted N0E procedures and equipment and NDE personnel. See above. See above, equipment and NDE personnel, a

1.2.3a. Paragraph IS Providing chemical and metallurgical Providing chemical and metallurgical analytical services, See above. See above.

analytical services.

I.2.4 I.2.3c, Paragraph 4

e. The Director - Operating Services (see Developing and qualifying special process Figure 2) la responsible through the This respansibility is transferred to Since the change is only a reallgreent procedures and qualifying personnel and Planning. Training and Administration Vice President - Fossil Operations to equipment for uelding and heat treating, of responsibt!!ty, no reduction in the Esecutive Vice President - Energy in the recent reorganization, commitment is involved.

Supply for developing and qualifytag 1.2.3c Paragraph 2 special process procedures and qualify-ing personnel and equipment for uelding Establishing, leptementing and doctamenting See above.

and heat treating, operating the Skill the training of operations arps technical See above.

Centers for training of personnel, and support personnel, including QA Program as requested, for technical support to indoctrination and training, and operating leuclear Operations in the areas of the Skill Centers.

metallurgy, uelding, chemistry, electrical, mechanical and civ11-structural engineering.

1.2.ib. Paragraph 5 Providing as requested, technical support Ihts responsibility is transferred to to Nuclear Operations in the areas of Since the change is only a reallgiment of Engineering and Field Operations in of responsibility, no reduction in metallurgy, electrical, mechanical and the recent reorganization.

elvil-structural engineering. commitment is involved.

4A0985-0002A-TJ01

Qt:ALITY ASSURANCE PROCRAM DESGIPTION (CTC-2Ap 13 REVISION 3 REVISION 4 Reason For Gange Basis For Conclusion 1.2.3a, Parmaraph a Providing Chemistry Support to Nuclear This responsib(11ty is transferred to OperatAs, as requested. Operating and Technical Services in the Since the change is only a realignment of recent reorgantastion.

of responsibility, no reduction in commitment is involved.

_1.2.4 1.2.3b, Paragraph 6

f. The % nager - Malatenance and Admints- Providing electrical equipment and turbine-trative Services (see Figure 2) is This responalbility is transferred to Since the change is only a realtgrunent of gerarator experttae. Engineering and Field Operations in the resposatble through the Vice President- tesponsib!!!ty, no reduction in recent reorgantaatton.

Foaatt Operations to the Executive commitment is involved.

Vice President-Energy Supply for 1.2.4 electrical equipment and turbine-generator expertise, e. The Director, Management and Budget (see F'gure 2) is responsible through ht- revision adds further definittou Since this change only further defines I.2.4 to responsibility statement. an estating responathility, no reduction the Executive Vice Prealdent, Energy Supply for maintaining the Records in commitment is involved.

b. The Director-Management and Budget N nagement System, including required (see figure 2) la respunalble through retention, protection and retrievability, the Eaecutive Vice President-Energy operating the General Of fice (of fsite)

Supply for maintatalag the Records Document control Center and for m aagement System, operating the maintaining the t!niform File Indes.

Ceneral Of fice (of f atte) Docuneet Control Center and for maintaining the Datform File Indes.

1.2.4 1.2.3b, Paragraph 3

8. The Ceneral Manager Cobb and M ittag Providing Field Maintenance Services for Planta (see Figure 2) to responsible This responsibtitty is transfetsed to since the change is only a realignment major modifications and plant outages. Engineering and Field Operations in the of responsibility, no reduction in through the Vice President-F0asil Operations to the Esecuttee Vice the recent reorganisation. commitment is involved.

PrestJent-Energy Supply for Field Matatenance Services.

I.2.4 1.2.3b

j. h e Executive Engineer-System The Esecutive Manager, Engineering and he responsibt!!ty is transferred to Since the change is only a realtgruneht Dynamics and Plant Aux 111 artes (see Field Operations (EfD) la resp m ible .

Figure 2) is responsible through the EPO under the recent reorgantaation. of responsibility, ho reduction in fort Director-Power Resources and System Analytical studies to appraise the counttment is involved.

Planatng, and the Vice President- adequacy of electrical study to Q-List System Operettone, to the Executive related equipment in nuclear power plants Vice President-Energy Sgply for the from the prtactple power supply following quality-related function; facilities of the transmission networlt Analytical studies to appraise the and onette power supply.

QA0985-COO 2A-TJ01

m - _ _ - -

14 Q3A1.IW ASSURANCE PitOCRAN .ESCRIMION (CPC-2A)

REVlslOn 1 REvlSION 4 Reason For Change Basts For Conclusion adequacy of electrical supply to Q-List related equipment la smaclear power plaats from the ortactyls power supply f acilitte s et + e *ransmission network and castre power supply.

1.2.5 Re v onsibility for Operational helear 1.2.5 Responsibility for belear Assurance Assurance Functions Iuhctions The Eaecutive Director - belear Assurance The Executive Director, Nuclear Assurance Ihts change reflects that the Esecutive Since tt.e change is only a realignment of Department (see Figure 4), la responsible Department (see Plaure 4), is responsible Director, Nuclear Assurance Department of responathtltty, no reduction in to the Vice President - Nclear Operations to the Vice President, Eclear Operations now has a responsibility for the QA commitment is involved, for the deitaittom, direction and ef fective- for the deitaitton, direction and af fec- Program for all modifications, not just mese measurements of the Nuclear Operations tiveness measurement of the Nuclear Opera- those accomplished by the Nuclear Q4 Program, including those modtitcations tions Q4 Program, including modifications, This reflects the accomplished by the Nuclear Operations and for verifying that activities af fecting l Operations integrationDepartrent.

of the Environmental and kpartment, and for veritytag that activt- the quattry of safety-related items are Quality Assurance Department's QA responst-ties af fectlag the quality of safety-related performed to accordance with QA Program bilities and Projects. Engineering and items are performed in accordance with requirements. The Emacutive Director's Construction's responsibilities into QA Program requirements. The Executive authority includes the following major Energy Supply.

Director's authority inclades the follow- functions for wort ur. der his jurisdiction:

tag ma)er functions for tork under his

}urtsdiction:

Establishing the Nuclear Operations QA Establishing the QA Program for operating idith the integration of Projects, Program, nuclear plants.

Since the change is strictly editorial, Engineering and Constructica into no reduction in commitment is involved.

Energy Supply, it is appropriate to delete " Nuclear Operations" since the program is not just applicable to Nuclear Operations.

1.2.5, Paragraph 7 1.2.5, Paragraph 7 Reviewing and concurring with organizational Reviewing and concurrir.g with organizational See above. See above.

adatatstrative procedures and procedure *sinistrative procedures and procedure changes for comp!!ance with muelear opera- .angea for compliance witt. QA Program tiona QA Program requirements. requirements.

3.2.5, Paragraph a Establishing NAD staf fing levels based on None

_ CP Co's position is that this responsibil- This responsibility is a general one that workleed analysts and empertence of maa- try is inherent of all management positiona all management saast carry out in order to panser versus task history, of any organtaation and so need not te in- do the lobs assigned. Therefore, deletion cluded here for this one position alone. from CPC-2A is not a reduction in commitment.

1. 2.5, Paragraph 9 1.2.5, Paragraph 8 R.nat tne attendance and participat ton at Assuring routine attendance and participa- The Executive Director, NAD (s represented Since the change only clartiles a responsi-meetings of the Plant Review Cosmittee, tion by NAD staf f at meetings of the Plant by NAD Staff member at PRC meetings, tellity, no reduction in caemitment is Review C maittee, involved.

QA0485-OOO2A-TJO!

$Al.lTY ASSURANCE PROCRAM DESdtIPTION (OC-2A) 15 REVISION 3 RHISION 4 Reason For Giange Easts For Conclusion 1.2.5, Paragraph 9 mone

~ Aeauring that nonconforming items are This change adds a responsibility which, properly identitled, segregated and althmgh implied in l'olicies 13 and 15 Since the change in fact adds a commitment, dispositioned.

in prior revisions, was not previously no reduction in commitmenM involved.

addressed.

1. 2. 5 1.2.5

a. h Palisades Plant QA Director and the a. h Palisades Plant QA Director and the h words " operational phase" are added Big Rock Point Plant QA Superlatendent Big Rock Potat Plant QA Superintendent Since the change is only editorial, are required to possess the educational are required to possess the educational to provide a clartitcation of existing no reduction in commitment is involved and experience quantitcations specified responsibtlities since both plants possess Im Regulator Qaide 1.4. Each is re-and empertence qualifications specified operating licenses.

to Regulatory Guide 1.8 Each is re-sponathis to the Eaecutive Director - aponsible to the Executive Director -

muclear Assurance for the following Nuclear Assurance for the following activities for work under his operating phase activittee for work Jartsdiction: under his jurisdiction: l 3.2.54 Paragraph 4 1.2.5a, Paragraph 4 Vertiteation of onalte corrective action Vertiteetion of anatte corrective action This revision to clartfles that QA only implementation and the effectiveness of implementation and the ef fectiveness of Since this change is consistent with the corrective action for signtitcant has a responsiblitty for vertitcationa overall scope of the QA Program as defined problems.

corrective action for s!gntitcant safety- l associated with " safety-related" in Policy 2 and other locations, no related problema. I

• problems.

reduction in commitment la involved.

1.2.Sa, Paragraph 6 1.2.Sa, Paragraph 6 Onatte QA engineering associated with Onatte QA engineering associated with The change clarifles QA involvement in audificatim destga performed within NOD. Since the change only clarf fles an modtitcation design performed under plant l modification design since destgn estating requirement , no redection control. I may be performed by other than NUD but in commitment is involved,

1. 2.h Paragraph 10 but still be under " plant control".

1.2.Sa, Parmeraph 10 Review of and concurrence with test pro- Review of and concurrence with test The change reflects the integration of ceeares and tastructions for QA aspects procedures and instructions for QA Since the change is only a realfgnment tant app!! cable to major modification test aspects. Assuraace, thus the parenthetical of responsibility, no reduction in procedures and teatruction - see l QAD-Plant Modtitcations statement is no longer required.

into Nuclear commitment is involved.

Sectsom 1.2.6).

1.2.5 1.2.5

b. h Director - Qaality Assurance Support b. h Director Quality Assurance Support See aleve. See above.

is resposalble to the E.necutive Direc- is responsible to the Executive Direc-ter - huclear Asserance for the Nuclear tor, Nuclear Assurance for the huclear Operations QA Audit Program, QA Program Operations Q4 Audit Program, QA Program Development and Special Studies tacled- Development, QA Engineering for Major l 2ng the following: , Modifications Design and Procurement {

and Special Studies including the foltoutng:

QAo985-uo02A-TJ01

Qt:ALITY ASSURANCE PROGRAM DESOtIPTION (CPC-2A) 16 REVISION 3 REVISION 4 Reason For Qiange 1.2. %. Paragraph 4 Basis For Conclusion 1.2.5b Par. graph 4 Supplier surveys and evaluation including Supplier surveys and evaluation including review / approval of supplier QA programs. This change combines old 1.2.5b, Stace the change is strictly editorial, review / approval of supplier QA programa, Paragraph 9 for brevity, and antatenance cf the NOD approved no reductice in commitment is involved, Suppliers List.

1.2. % . Paratroph 6 Participation in the Coordinating Agency for Suppl:er Evaluation ICASE). _None CASE la a method of obtaining information 1.2.5b, 3rd para, still requires that relevant to supplier evaluation. Other evaluations of suppiters be performed methods are also used which are not listed and an Approved Suppliers List be main-herein, so that Itsting CASE to tained. Since CASE is only one part of inconsistent. the process, and the process continues to be required, there is no reduction in scanttment.

1. 2.%. Paragraph 7 1.2.Sb. Paragraph 6 Trend analysts and reporting. Corrective action program trend analysis and reporting.

This change clarifles that Quality This change only clarifies an esisting Assurance Support only has a trend responsibility and thus no reduction analysts responsibility associated in commitment is involved, with the corrective action program.

1.2.% Paremraph 9 Malatenance of the pKD Approved Suppliers See 1.2.5b, Paragraph 9, above.

List. See 1.2.5b, Paragraph 4, above. See 1.2.5b, Paragraph 4, above.

1.2.5 1.2.5

c. h Director - Nuclear Safety is re-sponsible to the Executive Director -

c. 2he Director, Nuclear Safety is respon- h phase " including NRC Information Since the change is only a clartitcation sible to the Executive Dirn tor, Nuclear information Notices" is added to clarif y huclear Assurance for performance of Assurance for safety analyses, safety that the Nuclear Safety Department's of an estating responsibility, no safety analyses, safety assessments, assessments, operating emperience re- no reduction of commitment is involved, operating espertence reviews, probabil- views including NRC Information Notices,include l operating expertence reviews seviews of Information slao Notices, ttles risk assessment, administrative probabt!!stic risk assessment, admints-and technical support for Nuclear Safety trative and technt'.al support for Board activttles and technical mapport Nuclear Safety Board activities and for onette review organtrations. technical support for onsite review organtaattons.

QAOS85-0002A-TJ01

QtaLITY ASST'RANCE PROGRAM DESCRIPTION (CPC-2Al 17 Riv!S10ss 1 REVISION 4 Reason For m ange Basis For Conclusion

1. 2. 5 Newie

~ d. The Corporate Health Ihysicist la re- This position was created in the recent spanalble to the Executive Director, reorganization. The addition of this position actually Nuclear Assurance for assessing the Increases our level of commitment.

ef fectiveness of the corporate Health Physics program. He maintains stan-dares for control of Radiological Materials and personnel esposure and recommends program improvements to redace on-stte and of f ette radiation exposure caused by plant operations.

1.2.6 Responsti.flf ry for ()sality Assurance 1.2.5, Paragraph 1 Functione for M di ficat ions Asalgrwd to Pro f ec t a , Frig I rarer Eng and Cuna t ruc t Ion Enviranaental and Quality Assurance is The Eaecutive Director, Nuclear Assurance responalble f or establishing quality The Environmental and Quality Assurance Sixe the change is only a realignment Department (see Figure 4), is responat- Department's QA responsibilities were assurance standarda for modificatices ble to the Vice President. Nuclear of responsibility, no reduction in accomp!!shed by PE&C comatstent with CP Co Operattens for the definition, direction tranaterred to the Nuclear Assurance commitment la involved, objectives and for assuring the establish- Departmes t 's QA organization in the meet and implementation of policies and and effectiveness measurement of the recent reorganization, proceaares to meet these standards, Nuclear Operations QA Program, including modifications, and for verifying that In performing their quality assurance func- activities af fecting the quality of tiens, Envirormental and Quality Aasurance safety-related treme rae performed in personnel are indepenJeat from cost and accordaoce with QA Program requirements, The Esecutive Director's authority includes schedule impact, have the authority and the following major functions for work organizattomal freedom to identify u , der !s jurisdiction:

assurance-related problems, taltlate, recoassend or provide corrective actica as=4 eerify implementattom of corrective attion and are 1adependena irom the ind1-vid'sals or groups performing the activt-ties betag taspected, tested or audited.

Respoestbility for carrying out quality assurance fumettens during oodtitcations performed by PEAC to assigned to Faviron-mental and Quality Assurance as follous:

a. The Quality Assurance Department -

Plant Pbdifications (QAD-PNI (see Figure 2) la responsible for: 1.7.5b, Paragraph 12 Ptwpering the Project Quality Assurance Preparing the Project Quality Assurance Plan The Environmental and Quality Pl.m and ase+ering the Plan's timely Since the change is only a reallgrusent and assuring the Plan's timely lasuance with Assurance Department's QA responsibilities of responstbility, no reduction in QAO985-OOO24-TJ01 4

a e

18 QUALITY ASStJRANCE PR(CRAM DESCRIPTION (CPC-2A)

REVISION 1 REVISION 4 Reason For (hange Rasis For Conclusion tasuance h th the mutual concurrence the mutual concurrence of the organtaations of the organisations favolved. lavolved. were transferred to the Nuclear commitment is involved.

Assurance Department's QA organtaatton Participating ta the estab!!shment of I.2.56. Paragraph Il in the recent reorgantaation.

the Project Plam by establishing the Qua11ty Assurance aspects of the Plan. Participating in the establistment of the See above.

Project Plan by establishing the Quality See above.

Participating, as specified by the Assurance aspects of the Plan, and partis:-

Project and Project QA Plans. pating, as spectited by the Project and Project QA ?lans. p Assuring the maintenance and reporting 1.2.5b. Paragraph 14 ef hardware destga and corrective tive actica statua. Assuring the maintenance and reporting See above. See above.

of hardware design and procurement quality and corrective action status.

Performing preeward supplier evalua- 1.2.5b. Paragraph 15 tiens for quality assurance factors.

Establishing suppiter quality assurance See above. See above.

requirements and performing selected pre-award supplier evaluations for quality assurance factors.

Preparing and laptementing plans and 1.2.5b Paragraph 16 proce&res for procured tree inspec- .

tions, sondestructive em a taattons Preparing and laptementing plans for pro- See above. See above, and testa (within the Departmeat's cured Stee inspections, nondestructive juttsdictica). ea m inations and tests.

Evaluating and, then necessary, approe- 1.2.5b Paragraph 17 tag supplier Quality Assurance-related documentatican. Evaluating and, edien necessary, approving See above. See above, supptter Quality Assurance-related docu-Determiatag the acceptability or ace- acetation and determining the acceptability acceptabil.ty. or monacceptability of hardware items.

1.2.6. 1.2.5b. Paragraph 14 Maintaining and reporting hardware procure- Assuring the maintenance and reporting of See above. See above, ment quality and carrective action status, hardware design and procurement quality and corrective action status.

Preparing and implementing plans and proce- 1.2.5a. Paragrage 18 dures for the inspections, aondestructive Preparing and leptementing plans for the See above. The term " procedures" is See above.

hree for the taapections, aondestructive inspections, nondestructive examinations deleted since QA uses only " plans",

es mtmattone and tests (other tham checkout and tests (other than checkout and preoper- "Prockred" is added since Palisades QA and preoperational tests and functional attonal tests and functional tests for the performs receipt inspections of procured tests for the establistment of laservice establishment of inservice baseline) for items for major modifications, baseline) for stored and tastalled items procured, stored and installed items and and determining the acceptability or determining the acceptability or nonaccept-

=<=acceptatt lity of the items, abt!!ty of the trees.

QA0985-taOQ2A-TJct

Qt1ALITY ASSURANCE MtorRAM DESCRIPTION (CPC-2A) 19 REVISION 1 REVISION 4 Reason For Onange Identifytag testallatten laspection and Baats For Conclusion 1.2.5a. Paragraph 19 saantaat;on problems and test problems (withta the Departamat's test jurtadic- Identtfying tastallation tasper' ton and Etan) and caualms their t!aely and examtmation problems and test problems See above, la addition, the parenthetical See above.

adequate correctica, and caustas their timely and adequata statement is deleted stace it ta no longer correction.

applicable under the new organization.

Participating ta the resoluttom of hard- 1.2.5a. Paragraph 20 were and systemattc anaconformances durtas teatellettom and obtatalag procesa Participating to the resolution of hardware correcstwo acttom. See abcve. See atuve.

and systematic noncomformances earing ta-stallation and obtatalas process correcti=a acttaa.

Aasertag that mancomforatag items are 1.2.5, Paragraph 9 properly identified, segregated and dispoatstomed. Assuring that conconforming items are See above. See above, properly identtiled, segretated and dispoettioned.

Matatatalag and reporttag atte hardware 1.2.Sa. Paragraph 22 qualtty and corroct1we actton atatua.

Maintaining and reporting site hardware See above. See above, quality and corrective actton atatus.

Reviewing the tadtvidual preoperattumal, 1.2.5a. Paragraph 23 tuacetemal tamerwice heaeltas and asjor modificattom test procedures to: Reviewing the individual preoperational. See above. See above.

functional saaervice baseline and major modification test procedures to:

1. Assure preparatica of proceeares la 1. Assure preparation of procedures in compliance with applicable regulatory compliance with applicable regulatory requirements, codes and standards. requirements, codes and standards.

2. Assure the estabitahment of quality- 2. Assure the estabitsiment of quality-related prerequisites for the perfor- related prerequistres for the perfor-mance et each test. mance of each test.

3. Assure the adequacy of the data col- 3. Assure the adequacy of the data collec-lection format and content for quality tion format and content for quattty assurance recorda. assurance records.

4 Identify Bold and Nottitcat tom potats. 4 Identify Hold and nuttitcasion potats.

, Priar to the performaace of preoperattomal, Prior to the performance of preoperational, i

f actieaal laservice basettaa and major functional inservice baseline and major l andtitcattom testa: modtitcation tests:

l l

1 QA0985-0002A-TJ01

l QUALITY ASSURANCE PROCRAM IESCRIPTION iCPC-2A) trylSina 3 arytsgOsl 4 Reason Por Otange Basis For Conclusion

1. Directly verifytag the accomplia%nent 1. Directly verifytag and signing of f to of quality-related canstruttom psere- indicate the accomplishment of the ptsites and sigatag of f om each aus.k foltoutng quality-related test prerequisite to sigatty: prerequisites,

s. That there has been a turnower a. h t there has been an acceptance acceptance of the constructies unit (s). of the constructica turnover unit (s),

b. That each moncomformance and b. h t each known noncomformance and def tctency has been identified. def tetency has been docmented.

c. T%st each such mancesformance and c. That each such nonconformance and Also see 15.2.3.

def tstency has been adequately def tetency has been either corrected dispositteerd, or dispositicard and evaluated for posalble tapact upon the item or the test program.

2. Castrthuttmg to the identtitcattom of 2. Centributtag to the identification of plant quality statas by transalttlag plant quality status by assuttag that IE2a to the Project Test Supervisor h O s are tacorporated teto the overall for their tacorporatten into the project and plant status accounting overall plant states accounting system. system.

3. Aaauttag the malatemance and reporttag 3. Assurtas the matarenance and reporting of test quality and corrective actica et test quality and corrective action states. status.

Issuing " Step both Orders" at any Itae that I.7.5 Paragraph 5 Qaality Amaurance Program commiteests are steleted, if ancesaary to preclude a safety Stepptag unsatisfactory work to control See above.

risk, further processtag, delivery or installattom See above.

of nonceaforming materials or items.

Perforetas quality medits, as requested. l.7.5b, Paragraph 2 QA Audit program tecludtag follow-up See above. See above, os corrective action for audit findings.

1.7.Se, Paragraph 71 maae Contrelltag measuring and test equipment

- This responsiblitty is added to clarify Since this is an added responsibility, used by contractors and his staf f during that for major modifications, the Palisades major modtitcations. Controlltr.g the QA Director controls PATE.

no reduction in commitment is involved.

calibration recall system and obtaining calibration services for such equipment.

f y te5-0002A-TJCI

21 QUAllTY ASSLRAFT PRIERAM DESCRIPTION (CPC-2A)

RETIS10m 3 REVISION 4 Reason For a anse masts For conclusion 1.2.6 1.7.5

b. The W .E and & t Systaan Section b. The Director, Quality Aaaurance taee Ptsure 7) to responsible for: Audit and Managenest Systems is entainated Stace the change is only a reallgrunent Support is respanalble to the Esecuttwo by the recent reorganization and these streeter, Nuclear Assurance for the of responsibilttles, no reduction in Perforetag medits of acttwittes which responsit.ilities reassigned to Qaality commitment is favolved.

9mactear Operations QA Adiatt Program, Assurance Support.

may impact the design and comtuction Development, QA Engineering for *tajor apnattty of modifiesticas asaigan d to Modifications Deatga and Procursment PEAC by evalmettag the adequacy of and Special Studies tactedtag the wlity policies and precedures and feiloistag.

the degree of snapliance to quattry docueents. W audit program tacludtag follow-up em correct 1we action for audit findings.

Stalatag corrective ac tion, as neces-eary, beoed en andts fladtags. R tew of Nuclear Operations Department Standarda (NODS) and review and concur-hewteestag and apprestag O Co <peality currence with effette adotatatrattwo proceeares for PE&C activittee with procedures for e mpliance with QA respect to camp!!ance with QA Pru gram. Program requirements.

Dartas the chechnunt, preoperettamat test and f%mettesat taaerstce besentae teor acttuttles far endtficattama asalgaed to PE4C, rewtentag the Project Teattag Program neannat with respect to compliance with the Qnality Assurance complettee of asch rewtow by a cemcur-reece stamature.

Providing Omality Assurance eescattaa, 1.7.1c, Paragraph I and 2

• tratatas and ladactrimetten.

The Esecuttwe Director, Planning, This respenaibtitty is reassigned to the See above.

Tratatng and Adatatstration is Planning, Trataing and Adataistration responalble ... for Department.

Estabitshing, implementing and documenting the training ... laclandtag QA Program todoctrination are trataing ... .

Preparing , releastag and centroII1ng mome See 2.2.5c.

PEnc tater- and tatrodepartmental See 2.2.Sc.

geality-related rellcies ame proce& ires.

Iseutna "Stop Wr16 Orders" et anw time 1.7.5, Paragrate 5 that the Plant hdtitcatten Qinality a-amce Program cammitmenta are vietated, si mecessary to preclude a Stoppt 3 enasantsf actory work to control This responsibility is resssigned to NAD Since the change is only a realignment safety risk.

further processing, dettvery or lasta!!ation in the recent reorganisation, of responsibility, no reductinn in of nuncomforming materials er items. commitment is inwotwed, i

GaJee5-Con 32A-TJ03 l

22 Q:At ITY assimANCE PlutEAM DES (1t!PTION (CPC-2A) kn t$1fEB 3 REVISION 4 Reason Por t3nante Saats For Conclusion 2.1. Paragraph 1 2.1. Paragraph 3 4altry Assurance Program status, scope. Quality Assurance Program statua, scope, Since the Plant Modificattom portion awy and cumplimace with 10CFRSO adequacy and cc.mpilance with IF.FRSO Since the change does not impact our Appendts S are regularly rewtemed by CP Co of the QA Program is lategrated into NAD, commitment to perform a blennial Appendia B are regularly reviewed by CP Ce only are blenniel assessment is now required, assessment, no redaction it. casmsitment stamageoemt chamash reports, meettags and femmageneat throueh reports, meettags and review of medit reemita. Stemmially, a review of medit resmits. Steantally, a is involved.

preptammed and earmented assessment of preplanned and docuented assessment of the nuclear Operettens QA Program is 'he thatlear Operettama QA Program la performed by a - ; team ta=epen- performed by a management team indepen-dont of the shalear assurance Department. dect of the thatlear Aasurance Department.

A stallar hiematal lamependent assessment et tme Plant st.41:1 cation porttom et rae l t

44 Program to atee pertarund.

1 1.% 2.2.5

a. thsclear Operattama Department St=ad- de a. huclear Operattuna Department Standarda Combines old 2.2.5a and 2.2.5b into one (BLE$1 spectly the standard methces of All necessary aministrative controls OKX25) and/or adelaistrative procedures l Stem fcr brevity and recognizes that are still required, and are attil accemgliaktag gerettamal phase activt- specify the standard methods of accom-ties. Recesse the Onality Assurance sometimes Administrative Proceoures cover reviewed by Nuclear Assurance Department plishtag operattomal phase activities, areas act covered by BKDS.

Pysgram is am 1stegral part of the Sacause the Quality Aaaurance Program staf f to asaure complete coverage.

Thus, no reduction in commitment aperettomat phase actistries, the la as lategral part of the operettomat is involved.

mettees for implementing Qnaltry phase acttwitles, the methods for Amaurance Program centrols are inte- implementing Quality Assurance Program grated late the grIIS. The Euclear castrels are integrated tato these Anmerance Deperiment rewtews the IKX3S doc u ents. The Nuclear Amaurance far compliance with QA Program require- Department reviews the tuiS and admis-meets and Corporate QA policy. 1strattwo procedures for compliance with QA Program requirements and Corpo-rate QA policy.

2.1.%

h. AAmtatstrattwo procedures for accom- M See above. See above.

pliahang p11ty-related activities spec 1f ted la the 8KIIS are also restewed der csepliance alth QA Program require-meses and Corporate Q4 policy by the hat near Asamrance Department.

1.1.%

c. Omat t e r aneurance Pros ram Procee res, moes Reorganization eliminates PE&C as a Omality Assurance Prestan Precedure

~

Sf nre all work is still done to CPC-2A segelements and quat try asserme-support departme 4 . Quality Assurance and to implementtrd NODS and admints-Program Procedures and Supplements will be trative procedures which will addeems related separtmestet precedures far phased out over the next sta months to audificatlash actietEles asalgard te modtiteation activities assigned to EFO, one year, no reduct1on in Commitment to proper M S-6002A-TJOR

QEIALITY ASSURAssT PROCRAM DESOt!Pf!ON (CPC-2Al 23 R31TSICs 1 REVIS!nse &

Reason For Change gasts For Conclusion Ptac are approved by the Directer ,

EAGA af ter restew by Adit and Manage- QA controla has occurred.

amme System for empliance with QA Program requirements and Carporate QA pa!!cy.

1.1.% 2.1.5

d. Ethme Castracters perfarm merk mader b. Men Contractors perfort work under There is now only one QA organization as their ene gnality assurance programs, their own quality a9aurance programs, Since this change is only a reallgreent of a result of the recent reorganisation - of responsibility, no reduction in these programa are rewtened fcr cam- these programs are reviewed for compt!- namely NAD.

pliance with the applicable taq=st e ance with the applicable requirements commitaant is involved.

meets of IOCM50 Appendia B and the of 10CFR50 Appendia B and the contract contract and are approved by the and are approved by Nclear Assurance applicable CP Ca QA arganisattom prior prier to the start of work.

to the start of work.

2.7.S 7.2.5

e. Applicable elements of the operattoms c. Applicable elements of the operations This change secognizes that the plana Since the change is in fact an increase O attty Assurance Program are applied Que11ty Assurance Program are applied also describe QA centrols applicable to in commitment, eatsting commitments to to emergency plans, secertty plans, to emergency plans, security plcss, activities associated with emergency plans, QA ccatrols are not reduced, rettattaa and fire protection plans redtation ame fire protectice plans security plants, etc as well as to ser CP Ce smeclear power plants. These for CP Ce nuclear power plaats. These associated equipment.

ge ms describe QA castrols applicable plans describe QA controls applicable ta associated equipment. to associated equipment and activities.

2.1.1 2.2.1 Activttles af fecting safety see accom- Activities af f ecting the quattty of safety- he revision is asJe to clarify the Since the change is only a clarification plished under centrolled condittema, related items are accomplished under com- the applicability of the statement of an existing commitment, no reduction Preparettens for such activities tactose t rolled ceedit toma. Preparattuns for such constraatten that prerequtattes have been and to be coaststent with the in carettaent is tavolved.

activities taciale comittmat tom that rematader of CPC-2A.

met, auch as: prerequisites have been met, such as:

1.1.10 1.2.10

h. Operartens CA Program Statua Meettags b. Seet- - I QA Program Status Meetings he program is only applicable, by Since Ge change is purely editorial, are held sent-assanally, inwelving the are held, levolving the Vice President, deftmitton, to operattag plants, no reduction in commitment is Wice President - Ihaclear Operatises, the IIuclear Operations, the Executive Direc- including modificattoms thereto, lavolved.

Eaecuttee Director - Insclear Asaurence tor, IIuclear Assurance and the Managers and the Managers of the organizat toma of the organitaticas responsible for respumathle far taplementing elemes:ts taplement sag elements of the QA Program of the operettama pertica of the QA for Operattenal Nuclear Power Plants.

Program for Operaticaal Actear Pcaser Plants.

4M*eS-000 2A -TJO I

QUALITY ASSURANCE PROCRAM DESCRIPTION (CPC-2A)

RFVISIfb' 1 RFVISION 4 Reason For C.wge Basis Por Conclueton 2.7 10

c. Semi annual 4.4 Program st<tua meettags None. Reorganization eltstre es PE8iC as a are held taweavtag the Eneittee Vice $1nce this change is only a realignment President, the Director - Ewironmental support organtaatton. The topic of of responsiblitty and sentannual meetings

& qn.stity aseursace, the Cesarat Super- modifications is now addressed under the are still required, no reduction in meetings described to 2.2.10b.

wisor QAD Plant mdliteetions and the comettaent is favolved.

Managers of cther organizattav e re-openettle far impleenting tht. QA Program for madtiteettone accu'hlished by PEAC.

2.2.10 2.2.10

d. flanagment teams tadepesdent f rom the c. Management tea-: .otependent f rom the Stace the Plant Mods fication portion of gnaltry Assurswa organtaattom, but Osali:w *. eu-9-t ~1antaation, but Since the change does not impact our QA Program is integrated into Energy commitment to perform a biennial knowledgeable in audittas and quality k % 4edgeable in auditing and quality Supply, only one biennial assessment is assasamant, no reduction in commitment assurance, blema, tally revisw the assurance, bleantally review the ef fectivenese of the Quality Assurance ef f ectiveness of the Quality Assurance now required. to tavolved.

Program for gerattamat nuclear Pm Program for Operational fluclear Power Plants for both the operettor e pareton 'lanta. Concluatons and recommendettons of the program ame the portim caves tas t' ens are reported to the Executive modifications accouslished by *EAC. Time President, Energy Sigply.

Ccaclustoms and reccummendations are reported to the Emacettwe Vice president-Emergy Supply and the E.secutive fice President, respectively.

3.1 POLICY y POLICY l Ndtitcations to structures, systems am. Mod fications ti safety-related structures, This change clattfies the scope of Stree the change is os ly a clart f! cation j c e ts are accomplished in accordance syst me and caugonents are accouplished in the QA Program and makes the statement with approved designs, acco. Sance with approved designs, which does not impact ~p controls, l consistent with Policy 2 and other no reduction in commitent is involved, sections of CPC-2A, 3.2.1 1.2.1 Authority and responsibility for acdtitca- Authort y and resgenstbtitty for modifica- This change reflects the entaination of atom activities under the cogalzance of the Since the change is only a realignment tion act.wittes under the cognizance of the PEAC as a support department and the re- ment of responsiblitty, no reduction in Nuclear Operations Department and Prr.jects, Nuclear G., erat tene Department and Engineer- asatgrusent of responalbility for certain comettaent is tavalved Eastasering and Construction are described ing and Fa *14 Opesations (EFO) are described modi fications, in faction 1.0, ORCAm!ZATIces. This au: hor- 'n Section,1.0, Of CANIZATION. This author-it, and responsibility includes the preyr- 1*y and resg estb'Itty includes the prepar-attom, review, approval and vertitcation of atton, restem. ap.roval and vertitcation of the following design documents; a) Systep the foliowing Ses.gn documents: a) Systems descriptioma; b) Design taput and criteria, desc.-spetons; b1 Astgn input and criteria; c l Drautags and spectitcations; and d) En- c) Dru ings and spectitcations; and d) En-glarettog analyses and associated computer gineering analyses and associated cceputer programa. programs.

QA0945-voC2A-T301

QUALITY ASSUltANCT PROCPAM DESOtIPTION (CPC-2A) 25 REVISION 1 REvlS10N 4 Reason For Gianne Easts For Conclusion 1.7.6 1.3.6 Checks are performed and documented to Checks are performed and doceented to verif y the dimenstomat accuracy and verify the dimensional accuracy and Osange provides clarification only. Since the change is only a cl.rtit.ation completeness of design drawings and completenssa of design drawings and and does not impact any QA controls, no spec ific ations, specifications (ie, the products of a l reduction in commitment is involved.

design proceae). I 1.2.7 1.7.7 bdification design document packages are Modification design document packages are reviewed by Nuclear Assurance or QAD - reviewed by Shaclear Assurance Department to lModifications Change reflects the integretton Since the change is only a realigreent of QAD-Plant mdtfications, as applicable, to assure that the dociments that they contain Plant into Nuclear Assurance of responsibility, no reduction in assure that the documents that they contale have been prepared, verifled, reviewed and as a result of the recent reorganisation. commitment is involved, have been prepared, vert fled, reviewed and approved in accordance with Capany proce-approved is accordance with P7 ==y proce- dures med that they contain the necessary dures and that they contata the necessary quality assurance requirements. These re-quality assurance requirements. T1&se quirements include the taspection and test requirements include the inspection and requirements, quantitative and/or qualtta-tear requirements, quantitattwe and/or ttve acceptance criteria and the require-qualitative acceptance criterla and the ments for documenting inspectica and test requirements for documenting laspectico results.

and test results.

4.1 POLICY 4.1 POLICT Procurement doceents deitae the character- Procurement documents for safety-related This change clarifles the scope of the QA istics of item (s) to be procured, identify structures, systems, components and ser- Since the change is only a clarification applicable regulatery and industry Program and makes the statement consistent which does not impact QA controls, no codes / standards reqrtrements and specify vices define the characteristics of item (s) with Policy 2 and other sections of CPC-2A.

to be procured, identify .pplicable regu- reduction in commitment is involved.

supplier quality assurance program require- latory and industry codes / standards meats to the eatent necessary to assure requirements and specify supplier quality adequate quality, assurance program requirements to the estent necessary to assure adequate quality.

4.2.I. Paragraph 2 4.2.1. Paragraph 2 Procurement request packages are reviewed Procurement request packages are revleued This change reflects the new title of the and approved prior to outimittal to the and approved prior to sutimittal to the Since the changes only cover a title Purchaalag Department. Review includes Purchasing Department and the integration change and a realignment of responsi-verification by Nuclear Assurance or Purchasing and Materials Management Depart- l Of QAD-Plant Modifications into the bility, no reduction in commitment is ment. Review includes verification by Nuclear Assurance Department as a result involved.

Quality Assurance Department - Plant Nuclear Assurance Department that the Modtlications that the necessary quality necessary quali y requirements are l of the recent reorganisation.

requirements are spectiled, specified.

r w +e5-0002A-TJ01

- - ~ ~

r QRIALITY ASSURANCE PROCRAM DFSatIPTION (CPC-2A) 26 REVISION 3 REVISION 4 Reason For Osange 4.2.3 Basis For Conclusion 4.2.1

e. A requirement for a documented QA Pro- e. A requirement for a documented QA Pro-gram, subject to Nuclear Assurance or See above. See above, gram, subject to Nuclear Assurance QAD - Plant Mudifications review and Department review and written concur-written concurrence prior to the start rence prior to the start c f work, of work.

4.2.4 4.2.4 Nuclear Assurance or QAD - Plant Modifica- Nuclear Assurance Department terforms and See above.

tions, as applicable, performs and doctasents documents reviews of procurement request See above.

reviews of procurement request packages to packages to assure thats assure that:

5.2 5.2 The procedures used by CP Co to control its the procedures used by CP Co to control its activities include the followings This change corrects the impitcation Since the change tc only a clarification to activities include the followings thet NAD Procedures are pg Administrative Control Procedures, preclude misinterpretation and QA controle are unchanged, no reduction in commitment

1. Administrative Control Procedures and 1. is involved.

Administrative Procedures, including Nuclear Assurance Department Procedures. Nuclear Assurance Department Procedures.

6.1 POLICY 6.1 POLICT Documents controlling activities w; thin the Documents controlling safety-related actt-scope defined in Section 2.0, QUALITY This change clarifles the scope of the St. ace the chahse is only a Clarification vities within the scope defined in Sec- Policy and makes the statement consistent ASSURANCE PROGRAM are issued and changed tion 2.0, QUALITY ASSURANCE PROGRAM are with Policy 2 and other sections of CPC-2A. which does not impect QA controls, no according to estab!!shed procedores. Docu- issued and changed according to established reduction in commitment is involved, ments such as instructions, procedures and procedures. Documents such as instructions, drawings, including changes thereto, are procedures and dr neings, including changes reviewed for adequacy, approved for release thereto, are reviewed for adequacy, approved by authorised personnel and 0re distributed for release by authorised personnel and are and used at the location where a prescribed distributed and used at the location where activity is performed. a prescribed activity is performed.

6.2.2 6.2.2

b. As-built drawings and related b. As-built drawings (record drawings) documents, The term *(record drawings)* is added for Since the change is only a clarification and related documents. clarification, since for plant modifica-tions, the term *as-built drawings" is not e lch does not impact QA controls, no recognited. reduction in commitment is involved.

QA0985-DOO24-TJ01

27 QtlALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A)

REVISION 3 REVISION 6 Reason For Change ~ Basis Por Conclusion 6d. 9 6.2.3 The review, approval, issue and change of he review, approval, issue and change of documents are controlled by: his revision clarifies that ther statement Since the change is only clarification of the above documents are controlled by: l 1s applicable to the documents listed in a requirement and does not tapact entsting 6.2.2 noj documents in general. QA controls, no reduction in commitment was involved.

6.2.3 6.2.3

c. Perfomance and documentation of a re- c. Performance and documentation of a his change, in conjunction with the change view for concurrence with Quality As- review for concurrence with Quality Since the first change only provides a surance related aspects by the Nuclear Assurance related aspects of made above clarifies which documents Nuclear clarification of CPC 's commitment Assurance or Environmental & @ ality Assurance reviews and reflects past and regarding OA reviews (which is consistent itema 6.2.2 a, b, c, d (except for current practice. It also reflects the with the Standard Review Plan) and the Assurance Departments, as applicable, operating procedures), e and g by the integration of E4QA and NAD.

Puclear Assurance Department. secer* s ange is only a realignment of respnsil.111ty, no reduction in commit-ment is Unvolved.

6. 2. 6 6.2.6 Accurate as-built drawings and related Accurateas-builtdrawings(recorddrawings)lSee6.2.2above. See 6.2.1 above, uocumentation are prepared in a timely and related documentation are prepared in a manner. timely manner.

7.1 POLICY 7.1 POLICY Activities that implement approved procure- Activities that taplement approved procure- This change clarifies the scope of the ment requests for material, equipment and Since the change is only a clarification ment requests for safety-related material, l Policy and makes the statement consistent which dues not impact esisting QA services are controlled to assure confor- equipment and services are controlled to with Policy 2 and other sections of CPC-2A.

mance with procurement document require- controls, no reduction in commitment assure conformance with procurement docu- was inw.elved, ments. Controls include a system of ment requirements. Controls include a supplier evaluation and selection, source system ad supplier evaluation and selec-inspection, esamination and acceptance tion, source inspection, examination and of items and documents upon delivery, and acceptance of items and documents upon periodic assessment of supplier performance, delivery, and periodic assessment of Objective evidence of quality that demon- supplier performance. Objective evidence strates conformance with specified procure- of quality that demonstrates conformance ment document requirements is available to with specified procurement doctament require-the nuclear power plant site prior to use ments is available to the nuclear power of equipment, material or services. plant site prior to use of equipment, material or services.

7.2.6 7.2.6 Suppliers are required to furnish the Suppliers are required to furnish the The change reflects the integration of QAD-following records: following records:

Since the change is only a realignment Plant Modifications into Nuclear Assurance. of reJponsibility, no reduction in cose1Mant is involved.

Q40985-0002A-TJ01

28 QtlALITY ASSURANCE PROCRAM DESOtIPTION (CPC-2A)

REVISION 3 REVISION 4 Reason For Onanze gasis For Conclusion Nuclear Assurance or QAD - Plant Modifica- Nuclear Assurance Department evaluates the l tions evaluates the acceptability of these acceptability of these documents during documents during source and/or receipt source and/or receipt inspection.

Inspection.

8.1 POLICY 8.1 POLICY Materials, parts and components (items) Safety-related materials, parts and l ne change clarifles the scope of the are identified and controlled to prevent Since the change is only a clarification components (items) are identified and Policy and makes the statement consistent which does not impact estating QA their inadvertent use, ... and controlled to prevent their with folicy 2 and other sections of CPC-2A. controls, no reduction in commitment inadvertent use. . .

is involved.

9.1 POLICY 9.1 POLICY Special processes are controlled and are Special processes af fecting safety-related See above. See above, accomplished by qualiften p esonnel using structures, systems and components are qualified procedures and equipment in controlled and are accomplished by qualified accordance with applicable codes, standards, personnel using qualifted procedures and specifications, criteria and other special equipment in accordance with applicable requirements, codes, standards, specifications, criteria and other special requirements.

9.S.7 9.2.7 The appropriate QA organisations audit The Nuclear Assurance Department audits l 'The change reflects the integration of Since the change is only a reallgrunent special process qualification activities special process qualification activities QAD-Plant Modifications into Nuclear of responsibility, no reduction in and perform inspection and surveillance and performs inspection and surveillance Assurance. commitment is involved.

of special processes to assure they are of special processes to assure they are satisfactorily performed when specified satisfactorily performed when specified by applicable inspection planning and/or by applicable inspection planning and/or site procedures. Such inspection and site procedures. Such inspection and surveillance includes verification that surveillance includes verification that process data are recorded as required, process data are recorded as required, are within specified limits and are are within specified limits and are per-performed in accordance with applicable formed in accordance with applicable requirements. requirements.

10.2.2 10.2.2 Inspections are applied to procurement, Inspections are applied to procurement, The change provides eaamples of typical Since the first change is only editorial maintenance, modification, testing, fuel maintenance, modification, testing, fuel work-authorising documents and reflects and the second is only a realignment of handling, operation and inservice inspec- handling, operation and inservice inspec- the integration of QAD-Plant Modifications responsibilities, no reduction in tion to verify that items and activities tion to verify that items and activities into Nuclear Assurance. commitment is involved, conform to specified requirements. Work conform to specified requirements. Work authorizing documents are reviewed by authorising documents (egg procedures, Nuclear Assurance or QAD Plant Modifica- instructions, maintenance 'erk orders) tions in accordance with established are reviewed by the Nuclear Assurance l criteria to du the following as necessary: Department in accordance wath established i criteria to do the following as necessary:

QA0985-0002A-TJ01

QUA1.lTY ASSURANCE PROCRAM DESCRIPTION (CPC-2A) 29 REVISION 3 REVISION 4 Reason For Gange Basis Por Conclusion 10.2.3 10.2.3 _

Training and qualification programs for Training and qualification programs for personnel who perform inspections, includ- mange reflects the integration of Since the chanse is only a realignment personnel who perform inspections, includ- QAD-Plant Modifications into Nuclear ing nondestructive examination, are ing nondestructive examination, are of responsibility, no reduction in estab!!shed. Implemerted and documented in Assurance. commitment is involved, established, taplemented and documented in accordance with Sectit 2.0, QUALITY accordance with Section 2.0, QUALITY ASSURANCE PRUCRAM. hse programa meet ASSURANCE PROGRAM. These programs meet the requirements of applicable codes and the requirements of applicable codes and standards. Nuclear Assurance or QAD - standards, h Nuclear Assurance Depart- tl Plant hdifications review and concur ment reviews and concurs with any such with any such programs that are not under programs that are not under its direct their direct responsibility. Qualifica- responsibility. Qualifications and tions and certifications of inspection and certifications of inspection and htE NDE personnel are maintained. personnel are maintained.

10.2.4 10.2.4 Inspection requirements are specified in Inspection requirements are specified in See above.

procedures, instructions, drawings or procedures, instructions, drawings or See above, checklists and are either provided or checklists and are either provided or concurred with by Nuclear Assurance or concurred with by the Nuclear Assurance QAD - Plant hdifications, as applicable. l Department, hy (procedures, etc) l hy provide for the following as provide for the following as appropriates appropriate:

10.2.5 10.2.5 Inspection points are designated by Nuclear Inspection points are designated by the Assurance or QAD Plant Modifications as See above.

mandatory hold points when confirmation is Nuclear Assurance Department as mandatory l See above.

hold points when confirmation is needed needed that the work accomplished up to that that the work accomplished up to that point point la acceptable before the work can be is acceptable before the work can be allowed to proceed further. Hold point allowed to proceed further. Hold point inspections are performed, and work is inspections are performed, and work is released for further processing or use, released for further processing or use, by by designated inspection personnel. Hold designated inspection personnel. Hold points may be waived only by designated points may be waived only be designated Nuclear Assurance or QAD - Plant hdifica- Nuclear Assurance Department personnel, tions personnel.

10.2.7 10.2.7

b. The qualification criteria for the b. The quellfication criteria for the inspection personnel have been reviewed This change is editorial, adding Since the change is strictly editorial, inspection personnel have been reviewed " Department" in last line, and found acceptable by Nuclear and found acceptable by the Nuc lear no reduction in commitment is involved.

Assurance. Assurance Department.

QAOHl5-DOO1A-TJOI 4

30 Qt!ALITY ASSURANCE PROGRAM DESCRIPTION (CPC-1A)

REVISION 3 REVISION 4 Reason For Qianae Basis For Conclusion 11.1 MM. ICY 11.1 foi. ICY Testing is performad in accor.tance with Testing is performed in accordance with he change clarifies the scope of the Since the change is only a clarification established programs to esmonstrate that established programs to demonstrate that l Policy and makes the state'eent consistent nich does not impact esisting QA controls, structures, systems and components will safety-related structures, systema and l with Policy 2 and other sections of CPC-2A. no reduction in cemitment is involved.

perform satisfactorily in service. The components will perform satisfactorily in testing ta performed in accordance with service. he testing is performed in written procedures that incorporate spe- accordance with written procedures that citted re wireseats and acceptance criteria, incorporate specified requirements and The test program includes qualification (as acceptance criteria. h e test program applicable), acceptance, pre-operational, includes qualification (as applicable),

start up, surveillance and maintenance acceptance, pre-operational, start up, tests. Test parameters, including any surveillance and maintenance tests. Test prerequisites, instrumentation require- parameters, including any prerequisites, ments and environmental conditions are instrimmentation requirements and environ-specified and met. Test results are mental conditions are specified and met.

documented and evaluated. Test results are documented and evaluated, 11.2.3 11.2.3

d. Any mandstory taald points, d. Mandatory inspection hold points for This change clarifies tree purpose of the Since the ca.ange only provides a witness by the appropriate authority. hold points, clarification which does not impact any esisting (f. controls, no rediac tit ; in cousmitment is invilved, 3 Provision for verifying that test 3 Assuring that test prerequisites have h e changes in g and h are editorial Since the chan; e is strictly editorial, prerequisites have been met, been met. to provide correct syntax with the lead- no reduction in commitment is involved.

In phase of 11.2.3.

h. Provision for QA verification of com- h. QA verification of completion of pletion of asadification activities, modification activities.

Test procedures and instructions are re- Test procedures and instructions are re- his change reflects the integration of Since the change is only a realignment viewed by the engineering organizations viewed by the engineering organtaations QAD-Plant Modifications 'nto Nuclear of responsibility, no reduction in for technical content and by Nuclear for technical content and by the Nuclear Assurance, commitment is involved.

Assurance or QAD - Plant Modifications Assurance Department for QA aspects.

for QA aspects.

11.2.4 11.2.6 Nuclear Assurance ar E6QA, where applic- he Nuclear Assurance Department verifles, his change reflects the transfer of See above, able, verifles, throu;th audits, inspection through audits, inspection and survell- E6QA QA responsibilities to the Nuclear and surveillances, th.c test results are lances, that test results are documented, Assurance Department.

documented, evaluated and their accepta- evaluated and their acceptability is bility is determined by responsible determined by responsible personnel, personne1.

QA0985-0002A-TJ01

31 QUAI.lTY ASSURANCE PROGRAN DESCRIPTION (CPC-2A)

REVISION 3 RFVISION 4 Reason For Chante Basis For Conclusfon 12.2.1 12.2.1 The authority and responsibility of person- The authority and responsiktlity of person- The change allows for more than one net estabitshing, implementing and assuring net establishing, implementir.g and assuring Since the estating QA controls are not effectiveness of the calibration program is calibration program to be consistent with impacted, no reduction in commitment effectiveness of calibration programs is the revisions made in Policy 1, Paragraph is involved, described in Section 1.0, ORCANIZATION. descaibed in Section 1.0, ORGANIZATION. 1.2.2a, 1.2.3a, and 1.2.5a.

11.1 PCLICY 13.1 POLICY Activities with the potential for causing Activities with the potential for causing This change clarifies the scope of the contamination or deterioration that could contamination or deterioration that could Since the change is only a clarification Policy and makes the statement consistent which does not impact estating QA controls, adversely affect the ability of an ites to adversely affect the ability of a safety- with Policy 2 and other sections of CPC-2A, perform its safety-related functions and related ites to perform its intended no reduction in commithent is involved.

activities necessary to prevent undetect- safety functions, and activities necessary ed or uncorrectable damage are identified to prevent undetected or uncorrectable and controlled. These activities are damag* are identified and controlled. These cleaning, packaging, preserving, handling, activities include cleaning, packaging, pre-shipping and storing. Controls are ef- serving, handling, shipping and storing, fected through the use of appropriats Controls are effected through the use of procedures and instructions implemented appropriate procedures and instructions by suitably trained personnel. Implemented by suitably trained personnel.

14.1 POLICY 14.1 POLICY Operating status of structures, systems Operating status of safety-related l See above.

and components is indicated by tagging See above.

structures, systems and components is of valves and switches, or by other is indicated by tagging of valves and specified means, in such a manner as to switches, or by other specified means, prevent Inadvertent operation. The in such a manner as to prevent inadvertent status of insepctions and tests performed operation. The status of inspections and on individual itema is clearly indicated testa performed on individual f rems is by markings and/or logging under strict clearly indicated by markings and/or procedural controls to prevent inadvertent logging under strict procedur.at controls bypassing of such inspections and tests. to prevent inadvertent bypassing of such inspections and tests.

14.2.5 Nuclear Assurance or QAD - Plant !bdifica- Not in Policy 14 Requirements for NAD review of items ilsted Deletion from Policy 14 is not a tions reviews and concurs with procurement already exist in Section 4.2.4 and in packages, contracts, and procedures for Section 6.2.3c, rehtien since the requirements inspections, tests and other operations stated are already covered elsewhere important to safety, in CPC-2A and these sections are not altered.

QA0985-0002A-TJ01

32 Qt!ALITY ASSURANCE PROCRAM DESO IPTION (CPC-2A)

REVISION 3 REVISION 4 Reason For O ange Basis For Conclusion 15.1 POLICY 15.1 ICE. ICY Materials, parts or weponents that do not Safety-related materials, parts or compo- l This change clartf tet the scope of the conform to requirements are controlled in nents that do not conform to requirements Since the change is only a clarification order to prevent their inadvertent use. Policy and makes the stateacnt ccasistent which does not impact esisting QA controls, are controlled in order to prevent their with Policy 2 and other sections of CPC-2A.

Nanconforming items are identified, docu- inadvertent use. Nonconforming items are no reduction in commitment is involved.

mented, segregated when practical and identified, docusented, segregated when dispositioned. Affected organisations practical and dispositioned. Affected or-are notified of nonconformances, gantaations are notified of nonconformances.

15.2.1 15.2.1

b. Nuclear Assurance or QAD - Plant Mod!- b. The Nuclear Assurance Department reviews l The change reflects the integration of fications, as appropriate, reviews the the disposition of nonconformances, and Since the change is only a realignment of disnosition of nonconformances, and QAD-Plant Modifications into Nuclear a responsibility, no reduction in documents concurrence with the accep- Assurance. commitment is involved.

documents concurrence with the accep- tance, conditional release or repair tance, conditional release or repair of a nonconforming ites, of a nonconforming item.

c. Itema that have been repaired or c. Items that have been repaired or See above. See above, reworked are inspected and tested in reworked are inspected and tested in accordance with the original inspec- accordance with the original inspec-tion and test requirements or alterna- tion and test requirements or alterna-tives that have been doctamented as tives that have been doctasented as acceptable and concurred with by acceptable and concurred with by Nuclear Assurance or QAD - Plant the Nuclear Assurance Department. l Modi fications.

15.2.3 15.2.3 Prior to the initiation of preoperational Prior to the initiation of preoperational The change requires that nonconformance The change actually increases the testing on an ites, all nonconformances are testing on an item, all nonconformances are be dispositioned prior to tes:ing to be level of coimsitment, corrected or evaluated for possible impact corrected or dispositioned and evaluated l consistent with actual practice.

upon the ites or any facet of the testing for impact upon the item or the testing program, program.

IS.?.g 15.2.4 Nuclear Assurance (or QAD - Plant Ibdif t- The Nuclear Assurance Department analyzes l De change reflects the integration of Since the change is only a realignment cations for major modifications) analyzes nonconformance reports to identify quality QAD-Plant Modificatter.s into Nuclear of a responsibility, no reduction in swnconformance reports to identify quality trends. Trend reports, which highlight Aasurance. is involved, trends. Trend reports, which highlight significant results, are issued periodical-significant resulta, are tsaued period- ly to upper management for review and ically to upper management for review and assessment, assessment.

QA0985-0002A-TJ01

m - - -- -

33 QtIALITY ASSURANCE PROCRAM DESG IPTION (CPC-2A)

REVISION 3 REVISION 4 Reason For (hanne Basis For Conclusion 16.1 Pot. icy 16.1 pot. ICY Conditions adverse to quality, such as Conditions adverse to quality of safety- he change clarifies the scope of the failures, malfunctions, defielencies, related structures, systems, components or Policy and makes the statement consistent Since the change is only a clarification deviations, defective material and equip- activities, such as failures, malfunctions, with Policy 2 and other sections of uhtch does not impact esisting QA ment and nonconforances are identified controls, no reduction in commitment deficiencies, deviations, defective mate- CPC-2A. is involved, promptly and corrected as soon as rial and equipment and nonconformances are practical. Ider.tified promptly and corrected as soon as practical.

16.2.3 16.2.3 The identi fied conditf ona, their causes he identified conditions, their causes and The change reflects the integration of and corrective actions taken are reported corrective actions taken are reported to Since the change is only a realignment to appropriate levels of management for QAD-Plant Modifications into Nuclear of a responsibility, no reduction in appropriate levels of management for review Assurance. commitment is involved, review and assessment. Nuclear Assurance and assessment, ne Nuclear Assurance De- I or QAD - Plant Modifications reviews and partment reviews and dc.cuments concurrence [

documents concurrence with actions taken with actions taken to prevent recurrence, to prevent recurrence, perform follow-up perform follow-up to verify proper imple-to verify power implementation and deter- mentation and det6rmine if additional mine if additional action (such as audit action (such as audit or surveillarce) is or survelliance) is necessary to verify necessary to verify the effectiveness of the ef fectiveness of action taken, action taken.

17.2.5 No previous requirement. Temporary storage of completed ductasents he addition clarifies CPCo's choice This change clarifles CPCo's commitment during processing to become records is in regarding ANS! N45.2.9 vs NFPA 232, special fire-resistant stia cabinets. to ANSI N45.2.9 and since it makes the as allowed by RG 1.88. Previously, commitment more specific, it is the choice was not documented as a clear considered aa increase in the level of 17.2.7 commitment. commitment.

17.2.8 Except for records that can be stored as Records are stored in remote, dual f acili- his revision clarifies CPCo's commitment This change only claris tes CPCo's cunmit-originals, such as radiographs and some ties to prevent damage, deterioration or to use remote, dual facilities except strip cha.ts, records are stored in remote, losa due to natural or unnatural causes, ment and since it does not impact esisting when the record can only be stored in its QA controls, no reduction in commitment dual facilities to prevent damage, deterio- Records that can only be stored as origi- original form. is involved.

ration or losa due to natural or unnatural nals, such as radiographs and some strip c au ses. Laien only the single original can charts are retained in a four-hour fire-be retained, special fire-rated facilities rated facility, are used.

18.2.2 18.2.2

c. Controls over plant modifications performed by the Nuclear Operations

c. Controls over plant modifications. ndith the eliminarie of 'TM in tia Since the change is only a realignment serossantaation, the statement is of regmsibility and the comunitment Department and Project Engineering simpli fied. la unchangeo,na ree.ction in and Construction, commitment is involved.

QA0985-000/A-TJ01

34 4tJALITY ASS!!RANCE PROGRAM DESCRIPTION (CPC-2A)

REv!SinN 1 REVISION 4 Reason For Change gasts For Conclusion 18.2.9 18.2.9 Audit data are analyzed by Nuclear Assur- Audit data are analyzed by the Nuclear l The change reflects the integration of ance or by E4Q4 The resulting report Assurance Department. De resulting audit l E6QA QA functions into Nuclear Assurance Since the change, in the first case, identifies any quality deficiencies and reports identify any quality def?ciencies only reflects the reallgreent of and clarifles that the assessment M responsibility and in the second case assesses the ef fectiveneas of the QA Pro- and assess the effectiveness of the QA program ef fectiveness only covers the gram. 1" e reports are distributed to the a clarification, no reduction in responsible management of both the audited Program in the area audited. The reports l areas audited, commitment la involved.

are distributed to the responalble manage-and auditing organizations. ment of both the audited and auditing organizations.

18.2.10 18.2.10 Management of the audited organtaation Management of the audited organization his change reflects the integration of identifies and takes appropriate corrective identifies and takes appropriate corrective Since the change is only a realignment of F60A QA functions into Nuclear Aa*1rance, a responsibility, no reduction in action to correct observed deficiencies and action to correct observed deficiencies and to prevent recurrence of ary significant to prevent recurrence of any significant commitment is involved.

conditions adverse to quality. Follow-up conditions adverse to quality. Follow-up l 1e performed by Nuclear Assurance or E&QA la performed Iy the Nuclear Assurance De-to ensure that the appropriate corrective l partment to ensure that the appropriate action is taken and is ef fective. Such corrective action is taken and la ef fective, follow-up includes reaudits when necessary. Such follow-up includes reaudits when necessary.

Page 6, Appendia A Not previously a commitment. 21. 10 CFR 50, Appendix R. Fire Protection Commitment added to 10CFR50, Appendix R, this change adds a commitment to Program for Nuclear Power Factittles Section III C, Ill J, and III. Appendix R a Tso is not considered operating Prior to January 1, 1979, a reduction in commitment.

Section III C.,111 J. and III 0 Page 80. Exception 12a Page % Exception 12a RC 1.58. Sec C.1 RC 1.58. Sec C.1 Requi rement Requirement "However, for qualification of personnel "However, for qualification of personnel The exception /interpretatlan is revised Since the change only clartiles that (1) who approve preoperational, start up (1) who approve preoperational, start up to delete reference to specific of fsite the exception / interpretation is generic and operational test procedures and test and operational test procedures and test results and (2) who direct or supervise results and (2) who direct or supervise support organizations, since it is to of f atte support organizat tuna, no intended to be generic to such reduction in commitment is involved.

the conduct of individual preoperational, the conduct of individual preoperational, organisations.

start-up arid operational tests, the guide- start-up and operational tests, the guide-lines contained in Regulatory Guide 1.8, lines contained in Regulatory Guide 1.8, Personnel Selection and Training, should Personnel Selection and Training, should be followed in lieu of the Cuidelines of be followed in lieu of the Culdelines of ANS I N45.2.6 - 19 78." ANSI N45.2.6 - 1978."

Q40985-DOO2A-TJ01

QilALITY ASSURANCE PROGRAN DESCRIPTION (CPC 2A)

REVISION 3 REVISION 4 Reason For (hante Santa For Conclusion Exc eption /I nt e rpre t ation Exception / Interpretation This requirement is interpretated to not 2his requirement is interpretated to not apply to System Protection and I.aboratory apply to of fsite support organizations.

Services and Plant Modifications 6 Miscel- These departments have developed their laneous Projects (of fsite support organlaa- qualtaication programs based on tions), hese departmenta have developed ANSI M45.2.6 and provide services thr 2gh-the*r qualification programa based on out the operations phase of CP Co Felear ANSI M45.2.6 and provide services through- Plants. These programa include the out the construction and operation phases certification of the First Line Supervisors of CP Co Nuclear Plants. These programs to ANSI M45.2.6 and additional specific include the certification of the First requirements determined by the work Line Supervisors to ANSI M45.2.6 and activity involved.

additional specific requirements deter-mined by the work activity involved.

Page 82. Enception 11a Page 78. Exception lla N45.2.8, Sec 2.9e N45.2.8, Sec 2.9e Requirement Requirement Section 2.9e of N45.2.8 lista documents Section 2.9e of N45.2.8 lista documents his change clarifies that documents are relating to the specific stage of instal- relating to the specific stage of instal- to be avattable to the plant site rather Since the change only provides a lation activity which are to be available lation activity which are to be available clartiteetion of CPCo's commitment, at the construction site, than the construction site. no reduction in commitment la at the construction site. involved.

Eaception/ Interpretation Exception / Interpretation All of the documents listed are not All of the documents listed are not necessarily required at - the construction necessarily required at the plant site site for installation and testing. CP Co for installation and E sting. CP Co assures that they are available to the assures that they are available to the site as necessary. ~

site as necessary.

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Pase 79. Exception lac RC 1.88. C2 Requirement No previous exception in this area. "Two methods of protection of quality Addition clarifies CPCo choice regarding This change clarifies CPCo commitment assurance records from the hazards of fire ANSI M45.2.9 vs NFPA 232, as allowed by to ANSI N45.2.9 and NFPA 212, as are described in Subdivision 5.6 of RC 1.88. Previous to this addition, the allowed by RC 1.88 ANSI N45.2.9-1974 NFPA No 232-1975 Since it makes the choice was not documented as a clear commitment more specific, it is also contains provisions for records pro- ca.am i tment .

tection equipment and records handling considered an increase in level of techniques that provide protection from consitment .

the hazards of fire. This standard, within its scope of coverage, is considered by QA0985-0002A-TJ01

36 QUALITY ASOtJRANCE PROGRAN DESCRifTION (CPC-2A)

REVISION 3 REVISION 4 Reaenn For Change Basis For Conclusion the NRC staf f to provide an acceptalte siternative to the fire protection pro-visions listed la Subdivision 5.6 .

When NFPA 232-1975 to used, quality assurance records should be classified as NFPA Class 1 records...

Exception /Inte rpret a t ion CP Co adheres to ANSI M45.2.9-1974, Subdt-vision 5.6 for the fact!!ty for permanent storage of non-duplicated records. Tempo-rary storage of documents af ter completion and during processing as records is in file cabinets selected in accordance with provi-stons of NFPA 232-1975 for Class 1 records (usually NFPA Class C, I hour or UL-Class 350).

Page 86. Esception 19a Page 83. Exception 19a Branch Technical Position ASB9.5.1, General Br anch Technt eal Position ASB9.5.1 and ToCFR50 Appendix R. Sect ione III G. ,

@ and TII 0., General Except ion / Int erpret a tion yyt t on / Int e rpret ation E

The CPCo Fire Protection Plan aut,ettted to F1 e protection measures, equipment and Cosmitment to BTP AS89.5.1 is expanded This change adds a commitment to and approved by NRC supereedes the BTP in the individual plant Fire Protection Plans to include new commitment to 10CFR50, Appendia R eMo is not considered any areas of conflict, are in compliance v1.h the NRC Safety Appendix R, Section Ill C, til J and 111 0, a reduction in commitment.

Evaluation Reports and the required sec-tions of IOCFR50 Appendia R except for the spect fic exemptions approved by the NRC.

QA0985-OOO2A-TJ01

CORSurn8tS pow 8r ,o ,,m,

{l Chairman of the Board lll and Pressdent I

General offices: 212 West MicNgen Avenue, Jackson, Mk.higan $9201 * (517) 788-1600

SUBJECT:

STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMPANY QUALITY ASSURANCE PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As Chief Executive Officer of Consumers Power Company, I have the ultimate management authority for the establishment of Corporate Quality Assurance Policy. This Policy is provided in the Consumers Power Company Quality Assurance Program Description for Nuclear Power Plants. The Quality Assurance Program Description complies with the quality assurance requirements contained 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 N18.7, the ANSI N45.2 Series of Standards and corresponding Regulatory Guides. The Quality Assurance Program Description for Operational Nuclear Power Plants outlines the actions that are implemented during the operational D phase including fueling, testing, operation, refueling, procurement, main-tenance, repair, and modification design and construction of the safety-related portions of the nuclear power plants.

I have delegated the authority for the establishment and maintenance of the Quality Assurance Program Description to the Executive Vice President, Energy Supply for operational phase activities and plant modifications, and in turn to the Executive Directer, Nuclear Assurance. The Executive Director, Nuclear Assurance is also authorized to verify the offective implementation of the Quality Assurance Program Description.

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

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CPC-2A 11 I

OUALITY ASSUPANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS REVISION 4 APPROVED BY:

I Executivd Vice President, Energy Supply Date J W Reynolds T-(3-E F ExecutivgVicePresident, Energy Distribution Date l Stephen H Howell (JP A&ar Vi'et!H're sident , Nuclear Operations 763/rr Date

> R B DeWitt CYAM Vice President, Energy Supply C R Bilby vices

+ s rc

' Date l

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Vice President, Distribution Operations Date R C Lincoln diciGfre sident , Fuel Supply /

/[D(te R J Odlevak 83 d fVe Predident, General Services / /Date l K A Wells I

Pcgi iii Rev 4 Date 09/16/85 I

QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS CONTENTS Section Title Page Statement of Responsibility and Authority. .. . . .. i Approval Page. . . . . . . . . . . . . . . . . . . . . 11 Contents . . . . . . . . . . . . . . . . . . . . . . . iii 1.0 Organization . . . . . . . . . . . . . . . . . . . . . 1 2.0 Quality Assurance Program. . . . . . . . . . . . . .. 19 3.0 Design Control . . . . . . . . . . . . . . . . . . . . 25 4.0 Procurement Document Control . . . . . . . . . . . . . 29 5.0 Instructions, Procedures and Drawings. . . . . . . . . 31 h 6.0 Document Control . . . . . . . . . . . . . . . . . . . 35 7.0 Control of Purchased Material, Equipment and Services . . . . . . . . . . . . . . . . . . . . . 37 4,0 Identification and Control of Items. . . . . . . . . . 41 9.0 Cantrol of Special Processes . . . . . . . . . . . . . 43 10.0 Inspection . . .. . . . . . . . . . . . . . . . . . . 49 11.0 Test Control . . . . . . . . . . . . . . . . . . . . . 47 12.0 Control of Measuring and Test Equipment. . . . . . . . 49 13.0 Handling Storage and Shipping . . . . . . . . . . . . 51 14.0 Inspection, Test and Operating Status. . . . . . . . . 53 15.0 Nonconforming Materials, Parts or Components . . . . . 55 16.0 Corrective Action .. . . . . . . . . . . . . . . . . 57 17.0 Quality Assurance Records. . . . . . . . . . . . . . . 59 18.0 Audits . . . .. .. . . . . . . . . . . . .. . . .. 61 PD1081-0535A-QA04-QA06

Pegs iv Rev 4 Date 09/16/85 I

Section Title Page Appendix A Regulatory Guide and ANSI Standard Commitments . . . . . . . . .. . . . . . . 63 (2pp)

Part 2 CP Co Exceptions to Operating Phase Standards and Regulatory Guides. . . . . . . . . . . .. . . . .. 65 (19 pp)

FIGURES 1 Consumers Power Company Corporate Organization . . . . . . . . . . . . . . . .. . . . 13 2 Energy Supply Organization . . . . . . . . . . . .. 14 3 Nuclear Operations Department Organization . . . . . 15 4 Nuclear Assurance Organization . . . . . . . . . . . 16 5 Energy Distribution and General Services Organizations . . . .. . . . . . . . . . . 17 6 Energy Supply Services . . . . . . . . . . . . . .. 18 PD1081-0535A-QA04-QA06

Pgga 1 Rev 4 Date 09/16/85 I

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

This section of the Quality Assurance Program Description (QAPD) identifies the CP Co organizations responsible for activities affect- l ing the quality of safety-related nuclear power plant structures, systems and components and describes the authority and duties assigned to them. It addresses responsibilities for both attaining quality objectives and for the assurance functions of establishing and main-taining the Quality Assurance Program and verifying that activities affecting the quality of safety-related items are performed in accor-dance with QA program requirements.

Quality assurance functions (as defined above) are performed by personnel within formally designated Quality Assurance (QA) organiza-tional units. Specific areas of responsibility and authority are delegated to these units by the individual assigned overall responsi-bility and authority for the QA Program. The reporting level of the D Nuclear Assurance organization affords sufficient authority and organizational freedem, including sufficient independence from the l

cost and schedule impacts of QA organization actions, to enable people in that organization to identify quality problems; to initiate, l recommend, or provide solutions; and to verify implementation of solutions. QA/QC functions at the nuclear plants are performed by onsite quality assurance organizations that report to the Executive Director, Nuclear Assurance.

1.2 IMFLEMENTATION 1.2.1 Source of Authority

, The President and Chief Executive Officer (see Figure 1 of Company Organization Charts) of CP Co is responsible for safe operation of CP Co nuclear power plants. Authority and responsibility for estab-lishing and implementing the QA Program for plant operations, mainte-nance and modifications is delegated through the Executive Vice President, Energy Supply to the Vice President, Nuclear Operations (see Figure 2). This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Execu-tive Officer. Other quality-related functions are provided by other organizations as described herein.

I PD1081-0535A-QA06

Pags 2 Rev 4 Date 09/16/85 1.2.2 Responsibility for Attaining Quality Objectives in the Nuclear Operations Organization The Vice President, Nuclear Operations is responsible to the Executive Vice President, Energy Supply for operation and maintenance of CP Co 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 QA Program requirements.

a. The Plant General Manager / Plant Superintendent (see Figure 3) are responsible to the Vice President, Nuclear Operations for opera-tion and maintenance of the nuclear power plants in such a manner as to achieve compliance with Plant licenses, applicable regula-tions and the QA Program. Each Plant General Manager or Plant Superintendent delegates to appropriate managers and staff person- l nel in his organization responsibility for carrying out applicable controls required by the Quality Assurance Program. QA Program activities performed on the authority of the Plant General Manager or Superintendent include:

Qualification of plant operating and maintenance personnel. l Control of preparation, review and approval of Q-List updates.

Control of preparation, review and approval of plant procedures and instructions.

Procurement planning for the plant including preparation of and obtaining the required reviews and approval of purchase requests for spares, replacement items and consumables; and materials, items and services for minor modifications; and submittal of purchase request packages to Pu chasing for procurement actions.

Project responsibility for micor modifications including design, procurement, construction and testing activities, whether per-formed by CP Co or by outside contractors.

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.

Controlling a calibration recall system for PL-M&TE owned by the plant.

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Pags 3 Rev 4 Date 09/16/85 I

Maintaining a Master List for plant-owned PL-M&TE. l Operating onsite Document Control Certers.

Onsite evaluation of corrective action documents, including l initial determination of reportability to the NRC.

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

Implementing security, fire protection, health physics and emer-gency 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.

Performing reactor engineering functions, such as fuel calcula-tions and specification, fuel movement calculations, reactor thermal profile studies, etc.

I

b. The Nuclear Safety Board, chaired by the Executive Director.

Nuclear Assurance Department (see Figure 3), the Director, Nuclear Safety, or a duly appointed alternate, is responsible for perfor-mance of the offsite refety review functions for the nuclear power plants as described in plant technical specifications.

c. The Director, Nuclear Licensing (see Figure 3) is responsible for:

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

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

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PD1081-0535A-QA06

Pegy 4 Rev 4 Date 09/16/85 I

d. Other positions reporting to the Vice President, Nuclear Opera-tions (not shown on Figure 3) are responsible for:

Administrative control of Nuclear Operations Department Standards and the biennial assessment of QA Program effectiveness.

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

Coordinating Corporate Emergency Planning.

1.2.3 Responsibility for Attaining Quality Objectives in the Energy Supply Services Organization The Vice President, Energy Supply Services (see Pigure 6) is responsi-ble to the Executive Vice President, Energy Supply for standards for calibration of M&TE, operating the personnel dosimetry laboratory, training and major modifications to CP Co nuclear power plants.

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

a. The Executive Manager, Operating and Technical Services, (0&TS) is responsible, through Managers and Directors 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.

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 Labora-tory M&TE owned by O&TS, and other departments, as requested.

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

Maintaining a Company PL-M&TE Inventory List.

Providing chemistry support to Nuclear Operations, as requested.

Documenting justification for, and authorizing use of, reference calibration standards having an accuracy less than four times that of secondary standards being calibrated.

Preparing and obtaining the required reviews and approvals of purchase requests for services, equipment and consumables, and g submitting such requests to Purchasing for procurement action.

PD1081-0535A-QA06 i

i P:ge 5 Rev 4 Date 09/16/85

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Operating the dosimetry laboratory (including preparation and maintenance of occupational radiation and exposure records).

Conducting performance tests on materials, equipment and systems.

Performing nondestructive examination, and controlling / maintaining NDE equipment.

Providing qualified NDE procedures and equipment and NDE personnel. '

Providing chemical and metallurgical analytical services.

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

b. The Executive Manager, Engineering and Field Operations (EFO) is responsible, through Managers and Directors reporting to him for:

Performing the engineering, construction, preoperational testing and overall project management of generating plant major modifica-tion projects. This includes functioning, as appropriate, as either the lead design organization when such projects are engi-neered in-house or as the Company's design reviewer when those projects are done by outside engineering organizations.

Providing Field Maintenance Services for major modifications and plant outages.

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

Prcviding, as requested, technical support to Nuclear Operations in the areas of metallurgy, electrical, mechanical and civil-structural engineering.

Providing electrical equipment and turbine-generator expertise.

Analytical studies to appraise the adequacy of electrical supply to safety-related equipment in nuclear power plants from the principle power supply facilities of the transmission network and onsite power supply.

c. The Executive Director, Planning, Training and Administration, is responsible, through the Managers and Directors reporting to him, for:

P Establishing, implementing and documenting the training of opera-tions and technical support personnel, including QA Program indoctrination and training, and operating the Skill Centers.

I PD1081-0535A-QA06

Pago~ 6 Rev 4 Date 09/16/85 I

Preparing and obtaining required reviews and approval of contracts and providing approved procurement packages to Purchasing for action, as assigned.

Developing and qualifying special process procedures and qualify-ing personnel and equipment for welding and heat treating.

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

1.2.4 Responsibility for Attaining Quality Objectives Outside Nuclear l

Operations and Energy Supply Services Certain functions that constitute part of the Nuclear Operations QA Program are performed by CP Co organizational units outside the Nuclear Operations Department or Energy Supply Services, as follows: I

a. The Director, Property Protection Services (see Figure 5) is responsible through the Vice President General Services to the Executive Vice President, Energy Distribution for developing and maintaining the Fire Protection and Plant Security Plans for the nuclear power plants and for contract administration for the security force.

b. The Manager, Information and Operations Management, (see Figure 5)

D is responsible through the Vice President, General Services to the Executive Vice President, Energy Distribution for microfilming of specified QA records and plant engineering / design documents.

c. The Manager, Purchasing and Materials Management (see Figure 5) is responsible through the Vice President, General Services to the Executive Vice President, Energy Distribution for initiating procurement action based on approved purchase requests received from organizations performing or supporting plant operation, maintenance or modification.

d. The Director, Nuclear Fuel Supply (see Figure 2) is responsible through the Vice President, Fuel Supply to the Executive Vice President, Energy Supply for the procurement of nuclear fuel and associated services.

e. The Director, Management and Budget (see Figure 2) is responsible through the Executive Vice President, Energy Supply for maintain-ing the Records Management System including required retention, protection and retrievability, operating the General Office (offsite) Document Control Center and for maintaining the Uniform File Index. This includes collecting, storing, maintaining, distributing and controlling plant engineering / design documents through the Engineering Records Center.

I PD1081-0535A-QA06

Paga' 7 Rev 4 Date 09/16/85 9 The Manager, Distribution Engineering and Construction Department f.

(see Figure 5) is responsible through the Vice President, Distri-bution Operations to the Executive Vice President, Energy Distri-bution for determining settings for electrical protective systems and relay control systems, and for design, review and recommending changes to electrical protective schemes and associated settings.

1.2.5 Responsibility for Nuclear Assurance Functions l

The Executive Director, Nuclear Assurance Department (see Figure 4),

is responsible to the Vice President, Nuclear Operations for the definition, direction and effectiveness measurement of the Nuclear Operations QA Program, including modifications, and for verifying that l activities affecting the quality of safety-related items are performed in accordance with QA Program requirements. The Executive Director's authority includes the following major functions for work under his jurisdiction:

Establishing the QA Program for operating nuclear plants.

Continuing evaluation of QA Program status and adequacy, reporting his conclusions to CP Co Management.

l Assuring that verification activities are accomplished by personnel not directly responsible for the work being performed.

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

Recommending that a plant be shut down if such action appears neces-sary (the order is issued by the Vice President, Nuclear Operations or the Plant General Manager / Superintendent).

Reviewing and concurring with organizational administrative procedures l and procedure changes for compliance with QA Program requirements.

Assuring routine attendance and participation by NAD staff at meetings l of the Plant Review Committee.

Assuring that nonconforming items are properly identified, segregated and dispositioned.

The Executive Director's job description includes the following prerequisites: Previous management experience; knowledge of quality assurance regulations, policies, practices and standards; and experi-ence working in quality assurance or related activities in reactor design, construction or operaticns, or in a similar high technology industry. The quality management office, consisting of the E::vcutive l

PD1081-0535A-QA06

Pcga 8 Rev 4 Date 09/16/85 D Director and his immediate staff, meet or exceed the qualifications established in Paragraph 4.4.5 of ANSI /ANS 3.1, 12/79 Draft as en-dorsed by Regulatory Guide 1.8.

The Executive Director, Nuclear Assurance has no other duties or responsibilities unrelated to QA that would prevent his full attention to QA matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality considerations in his decisions and recommendations, and has direct access to high enough levels of Management to obtain resolution of quality problems. As Executive Director, he delegates authority and holds his organization responsi-ble for accomplishing QA functions for operational nucleer power plants, as follows:

a. The Palisades Plant QA Director and the Big Rock Point Plant QA Superintendent are required to possess the educational and experi-ence qualifications specified in Regulatory Guide 1.8. Each is responsible to the Executive Director - Nuclear Assurance for the following operating phase activities for work under his jurisdiction:  !

Site surveillance program.

Review of and concurrence with plant administrative procedures for compliance with Nuclear Operations QA Program requirements.

Verification of onsite corrective action implementation and the effectiveness of corrective action for significant safety-related g problems. I Review of and concurrence with quality requirements of procurement request packages for site-originated procurements.

Onsite QA engineering associated with modification design per-formed under plant control.

Vendor surveys for local procurements and source surveillance /

inspection at supplier facilities.

Onsite inspection program, including receiving inspection and inspection and acceptance activities associated with operations, maintenance, modifications, testing and fuel handling.

Participation in daily work schedule and status meetings to remain abreast of day-to-day work assignments throughout the plant and to assure adequate QA coverage relative to procedural and inspection controls, acceptance criteria and staffing and qualification of site QA personnel to carry out their assignments.

Review of and concurrence with test procedures and instructions for QA aspects.

I PD1081-0535A-QA06

Pcgr 9 Rev 4 Date 09/16/85 D Review and approval of inspection procedures and onsite inspection planning.

Review of work authorizing documents.

Review and concurrence with administrative procedures that control methods for indicating inspection, test and operating status and attachment / removal of inspection status indicators.

Review and concurrence with Q-Lists and Q-List changes to assure compliance with QA Program commitments and to assure that the extent QA controls are to be applied to specific structures, systems and components is appropriate.

In addition, the Palisades QA Director is responsible for the following major modification (construction and testing) activities for work at both Palisades and Big Rock Points Establishing supplier quality assurance requirements and performing selected preaward supplier evaluations for quality assurance factors.

Evaluating and, when necessary, approving Supplier Quality Assurance-related documentation and determining the accept-ability or non-acceptability of hardware items.

Preparing and implementing plans fsc the inspections, nonde-structive examinations and tests (other than checkout and preoperational tests and functioaal tests for the establish-ment of inservice baseline) for procured, rtored and installed items and determining the acceptability or nonacceptability of the items.

Identifying installation inspection and examination problems and test' problems and causing their timely and adequate correction.

Participating in the resolution of hardware and systematic nonconformances during installation and obtaining process corrective action.

Controlling measuring and test equipment used by contractors and his staff during major modifications. Controlling the calibration recall system and obtaining calibration services for such equipment.

Maintaining and reporting site hardware quality and corrective action status.

PD1081-0535A-QA06 L

Pega 10 Rev 4 Date 09/16/85 Reviewing the individual preoperational, functional, inservice baseline and major modification test procedures to:

1. Assure preparation of procedures in compliance with applicable regulatory requirements, codes and standards.

2. Assure the establishment of quality-related prerequisites for the performance of each test.

3. Assure the adequacy of the data collection format and content for quality assurance records.

4. Identify Hold and Notification points.

Prior to the performance of preoperational, functional, inserv-ice baseline and major modification tests:

1. Directly verifying and signing off to indicate the accom-plishment of the following quality-related test prerequisites.

a. That there has been an acceptance of the construction turnover unit (s).

b. That each known nonconformance and deficiency has been documented.

c. That each such nonconformance and deficiency has been either corrected or dispositioned and evaluated for possible impact upon the item or the test program.

2. Contributing to the identification of plant quality status by assuring that NCRs are incorporated into the overall project and plant status accounting system.

3. Assuring the maintenance and reporting of test quality and corrective action status.

Evaluating compliance with test procedures on an inspection and surveillance basis.

b. The Director. Quality Assurance Support is responsible to the Executive Director. Nuclear Assurance for the Nuclear Operations QA Audit Program, QA Program Development. QA Engineering for Major l Modifications Design and Procurement and Special Studies including l the following:

QA audit program including follow-up on corrective action for audit findings.

Verification of the implementation and effectiveness of offsite corrective action for significant problems.

PD1081-0535A-QA06

Pcg2 11 Rev 4 Date 09/16/35 D Supplier surveys and evaluation including review / approval of supplier QA programs, and maintenance of the NOD Approved Suppli-ers List.

Review of and concurrence with quality requirements of procurement request packages generated offsite.

Corrective action program trend analysis and reperting.

I Maintenance / operation of corrective action system.

I Maintenance of the QA Prograu Description for Operational Nuclear Power Plants.

Review of Nuclear Operations Department Standards (NODS) and .

review and concurrence with offsite administrative procedures for compliance with QA Program requirements.

Development and maintenance of Nuclear Assurance Department Procedures and Quality Control Procedures.

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

For modifications:

Preparing the Project Quality Assurance Plan and assuring the Plan's timely issuance with the mutual concurrence of the organizations involved.

Participating in the establishment of the Project Plan by establishing the Quality Assurance aspects of the Plan, and participating, as specified by the Project and Project QA Plans.

Assuring the maintenance and reporting of hardware design and procurement quality and corrective action status.

Establishing supplier quality assurance requirements and performing selected preaward supplier evaluations for quality assurance factors.

Preparing and implementing plans for procured item inspec-tions, nondestructive examinations and tests.

Evaluating and, when necessary, approving supplier Quality Assurance-related dccumentation and determining the accept-ability or nonacceptability of hardware items.

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Page 12 Rev 4 Date 09/16/85 I

c. The Director, Nuclear Safety is responsible to the Executive Director, Nuclear Assurance for safety analyses, safety assess-ments, operating experience reviews including NRC Information Notices, probabilistic risk assessment, administrative and techni-cal support for Nuclear Safety Board activities and technical support for onsite review organizations,

d. The Corporate Health Physicist is responsible to the Executive Director, Nuclear Assurance for assessing the effectiveness of the corporate Health Physics program. He maintains standards for control of Radiological Materials and personnel exposure and recommends program improvements to reduce on-site and offsite radiation exposure caused by plant operations.

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PRES DEhT AND GIEF EXECLTIVE OFFICER

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EXEC VICE PRESEENT EXEC VICE PRESEEhT

> ENERGY DISTRIBLTION ENERGY SUPPLY Figure 1 - Consumers Power Company Corporate Organization I

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VICE PRESIDENT ENERGY SUPPLY SERVICES EXECUTIVE MANAGER EXECUTIVE MANAGER EXECUTIVE DIRECTOR OPERATING AND ENGINEERING AND PLANNING, IRAINING TECHNICAL SFRVICES FIELD OPERATIONS AND ADMINISTRATION Figure 6 - Energy Supply Services Organization I

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2.0 QUALITY ASSURANCE PROGRAM 2.1 POLICY Policies that define and establish the Consumers Power Company (CP Co)

Quality Assurance 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 provi-sions of the QAPD and will be carried out for the life of each plant.

Quality assurance 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 Assurance Program status, scope, adequacy and compliance with 10CFR50 Appendix B are regularly reviewed by CP Co Management through reports, meetings and review of audit results. Biennially, a pre-planned and documented assessment of the Nuclear Operations QA Program is performed by a management team independent of the Nuclear Assurance Department.

2.2 IMPLEMENTATION 2.2.1 The President 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 10CFR50 Appendix B.

The statement makes this QAPD and the associated implementing proce-dures and instructions mandatory and requires compliance by all responsible organizations and individuals. It identifies the Manage-ment positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness.

2.2.2 The Quality Assurance Program at CP Co 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 QAPD are as follows:

a. For Big Rock Point and Palisades, the QAPD became effective on April 1, 1982, with full implementation on January 1, 1983.

b. The QA Program described in this QAPD is intended to apply for the life of CP Co's nuclear power plants.

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c. The QA Program applies to activities affecting the quality of safety-related structures, systems, components and related consumables during plant operation, maintenance, testing and all modifications. These activities having a direct impact on Q-listed items shall be procedurally controlled. Safety-related structures, system, components and related consumables are identi-fled in Q-Lists, which are developed and maintained for each plant in accordance with the criteria of Regulatory Guide 1.29 as clarified by Item No. 20a in Part 2 of Appendix A to this QAPD.

2.2.4 This QAPD, organized to present the CP Co Quality Assurance Program for Operational Nuclear Power Plants in the order of the 18 criteria of 10CFR50 Appendix B, states CP Co policy for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this QAPD that do not reduce the commitments previous-ly accepted by the NRC must be submitted to the NRC at least annually.

Any changes made to this QAPD that do reduce the commitments previous-ly accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation. The submittal of the changes described above shall be made in accordance with the requirements of 10CFR50.54.

The program described in this QAPD 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 QAPD include the following

a. Nuclear Operations Department Standards (NODS) and/or administra- l tive procedures specify the standard methods of accomplishing operational phase activities. Because the Quality Assurance Program is an integral part of the operational phase activities, the methods for implementing Quality Assurance Program controls are integrated into these documents. The Nuclear Assurance Department reviews the NODS and administrative procedures for compliance with QA Program requirements and Corporate QA policy,

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 Nuclear Assurance prior to the start of work. l

c. Applicable elements of the operations Quality Assurance Program l are applied to emergency plans, security plans, radiation and fire protection plans for CP Co nuclear power plants. These plans describe QA controls applicable to associated equipment and activities.

2.2.6 Provisions of the Quality Assurance Program for Operational Nuclear Power Plants apply to activities affecting the quality of safety-related structures, systems, components and related consumables.

Appendix A to this QAPD lists the ANSI Standards and Regulatory Guides PD1081-0535A-QA06 O

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to which CP Co commits. Appendix A also describes necessary excep-tions 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. CP Co uses the criteria specified in Regulatory Guides 1.26 and 1.29 for identifying structures, systems and components to which the Quality Assurance Program applies (See Appendix A).

b. This identification process results in a Q-list for each nuclear power plant. The Q-list is a controlled document, issued to designated personnel. Q-list items are determined by engineering analysis of the function (s) of plant structures, systems, compo-nents and consumables in relation to safe operation and shutdown.

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

2.2.7 Activities affecting the quality of safety-related items are accom- l plished under controlled conditions. Preparations for such activities 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 engineering and/or technical specifications.

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

d. Materials and items are in an acceptable status.

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

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

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

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

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

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2.2.9 Responsibility and authority for planning and implementing indoctrina-tion and training are specifically designated in the CP Co organization (see Section 1.0, ORGANIZATION).

a. The training and indoctrination program provides for ongoing training and periodic refamiliarization with the Quality Assurance 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-1A, or the ASME Code, as applicable.

c. Personnel who participate in quality assurance audits are quali-fied in accordance with Regulatory Guide 1.146.

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 performing QA functions includes provisions for retraining, reexamination and recertification to ensure that proficiency is maintained.

f. Certificates of qualification for personnel performing QA func-tions designate specific functions that the named personnel are qualified to perform and indicate the performance criteria on D which the qualification was based.

g. 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.

h. 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 assurance program are regularly assessed by CP Co Management. The following activities constitute formal elements of that assessments

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. Semi-annual QA Program Status Meetings are held, involving the Vice President, Nuclear Operations, the Executive Director, Nuclear Assurance and the Managers of the organizations responsi-ble for implementing elements of the QA Program for Operational Nuclear Power Plants.

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c. Management teams independent from the Quality Assurance organiza-tion, but knowledgeable in auditing and quality assurance, bienni-ally review the effectiveness of the Quality Assurance Program for Operational Nuclear Power Plants. Conclusions and recommendations are reported to the Executive Vice President, Energy Supply.

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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Pcgt 25 Rev 4 Date 09/16/85 D 3.0 DESIGN CONTROL 3.1 POLICY Modifications to safety-related structures, systems and components are l accomplished in accordance with approved designs. Activities to develop such designs are controlled. Depending on the type of modifi-cation, these activities include design and field engineering: the performance of physics, seismic, stress, thermal, hydraulic, radiation and Safety Analysis Report (SAR) accident analyses; the development 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 prepa-ration and review of design documents, including the correct transla-tion 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 under the cognizance of the Nuclear Operations Department and Engineering and Field Operations (EFO) are described in Section 1.0. ORGANIZATIOh.

This authority and responsibility includes the preparation, review, approval and verification of the following design documents: a)

System deacriptions; b) Design input and criteria; c) Drawings and specifications; and d) Engineering analyses and associated computer D 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 coces 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 valvers to or deviations from the engineering (quality) standards (ie, the required dimensions, material properties, features and other characteristics spe:ified for modifications) are required by procedure and by contract, when applicable, to be documented and controlled. (See, also, Section 15 concerning the approval of "re-pair" or "use as is" dispositions of nonconformances.)

3.2.5 When modificatione involve design interfaces between internal or external design organizations or acrons technical disciplines, these interfaces are controlled. Procedures are used for the review, PD1081-0535A-QA06

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, Pcga 26 I Rev 4 I Date 09/16/85 D approval, release, distribution and revision of documents involving design interfaces to ensure that structures, systems and components are compatible geometrically, functionally and with processes and environment. Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses. Decisions and problem resolutions involving design interfaces are made by the CP Co organization having responsibility for engineering direction of the design effort.

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

3.2.7 Modification design document packages are reviewed by the Nuclear Assurance Department 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 assur-ance requirements. These requirements include the inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements 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 impor-tance of the item to safety, design complexity, degree of standardiza-tion, the state-of-the-art and similarity with previously proven D 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 p 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 pperating 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 ratesting or other verification is performed.

Scaling laws are established and verified, when applicable. Test f configurations are clearly documented.

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Pcg2 27 Rev 4 Date 09/16/85 D Design reviews are performed by multi-organizational or inter-disciplinary 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, and (2) He has not specified a singular design approach, ruled out design considerations or established the design inputs.

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

QA audits cover the frequency and effectiveness of the use of supervi-D 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 unveri-fled parts of the design and the hold point to which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function. Justification for such early release is documented.

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

3.2.12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original design. Such changes are evaluated for impact. Those that affect fit, form or function are reviewed and approved by the same, or equivalent, organisations that approved the original design. Informa-tion on approved changes is transnitted to all affected organizations.

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Pcgo 29 Rev 4 Date 09/16/85 D 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 POLICY Procurement documents for safety-rslated structures, systens, 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 necessary 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-ested in Section 1.0, ORGANIZATION.

Procurement request packages are reviewed and approved prior to submittal to the Purchasing and Haterials Management Department.

Review includes verification by Nuclear Assurance Department 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 QAPD are considered for application to suppliers. As applicable, procurement documents includet

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 QA Program, subject to Nuclear Ansurance Department review and written concurrence prior to the l start of work.

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

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Pcgo 30 Rev 4 Date 09/16/85 D 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 be compatible with the Engineering Records Center Syst m. the schedule of submittals and identifica-tion of documents requiring CP Co approval.

4.2.4 Nuclear Assurance Department performs and documents reviews of pro- l curement request packages to assure thats

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 QA 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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Pcg] 31 Rev 4 Date 09/16/85 D 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGC 5.1 POLICY Activities affecting the quality of safety-related structures, systems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances which include acceptance 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 qualitative (such as workman-ship 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 ray be used.

The procedures used by CP Co to control its activities include the following:

1. Administrative Procedures, including Nuclear Assurance Department l 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. Shi'edown procedures that provide for controlled teactor shutdown or utdown following reactor trips.

S. Power operation and load changing procedures that provide for steady state power operation and load changing, including response to unanticipated load changes.

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P g2 32 Rev 4 Date 09/16/85 D 6. Process monitoring procedures that provide for monitoring plant system performance and which, as appropriate, identify limits for significant process parameters.

7. Fuel-handling procedures that provide for activitics such as

a. Core alterations

b. Refueling

c. Fuel accountability

d. Receipt and shipment of fusi

e. Nuclear Safety measures

8. Maintenance procedures that provide fort

a. Preparation for maintenance

b. Performance of maintenance

c. Post-maintenance and operability checks and teste

d. Use of supporting maintenance documents

9. Radiation control procedures that provide fort

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 fort

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 activi-ties including:

a. Sampling and analyses

b. Maintenance of coolant quality

c. Control of deleterious agents PD1081-05358-QA06

r-Pcgo 33 Rev 4 Date 09/16/A5 9 d. Control, treatment and management of radioactive wastes

e. The control of radioactive calibration sources

12. Emergency procedures that provide guidance fort

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 identifyt

a. Objectives

b. Acceptance criteria

c. Prerequisite and special conditions

d. Limiting conditions

a. Test or inspection instructions

f. Any required special equipment or calibration

g. Ilold and Witness points, as appropriate

15. Modification procedures that provide fort

a. Administrative control and technical support during plant modifications

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

c. Control of the interfaces between CP Co and its suppliers

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e. Control of onsite quality-related modification activities that assure the QA Program is implemented and its effectiveness is assessed and reported D

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Paga 35 Rev 4 Date 09/16/85 D 6.0 DOCUMENT CONTROL 6.1 POLICY Documents controlling safety-related activities within the scope l defined in Section 2.0. QUALITY ASSURAhCE PROGRAM are issued and changed according to established procedures. Documents such as instructions, procedures and drawings, including changes therato, are reviewed for adequacy, approved for release 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 organisations specifically designated in accordance with the procedures governing these documents.

6.2 IMPLEMENTATION 6.2.1 The authority and responsibility for :he 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, D e'alyses) 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

e. Procedures that implement the Quality Assurance Program

f. Final Safety Analysis Report

g. Reports of nonconformances

h. Plant Technical Specifications

6.2.3 The review, approval, issue and change of the above documents are l controlled bys

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

b. Identification of the organisations responsible for review.

) approval, issue and revision PD1081-05338-QA06

Pcgo 36 Rev 4 Date 09/16/85 D c. Performance and documentation of a review for concurrence with Quality Assurance related aspects of items 6.2.2 a. c, d (except for operating procedures), e and g by the Nuclear Assurance Department

d. Review of changes to documents by the organization that performed the initial review and approval or by the organization designated in accordance with the procedure governing the review and approval of specific types of documents 6.2.4 Controlled documents are issued and distributed so thats

a. The documents are available at the work location prior to commenc-ing 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 controin are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents. Wen master lists are used they are updated and distributed to designated personnel who are responsible for maintaining current copfes of the lists.

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

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r P ga 37 Rev 4 Date 09/16/85 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, examinatioa 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 use of equipment, material or services.

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 CP Co qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. To remain qualified, suppliers involved in active procure-ments are reevaluated annually and are audited triennially. If a Licensee Contractor / Vendor Inspection Program letter of confirmation or the Coordinating Agency for Supplier Evaluation Register is used to b

F establish the qualifications of the Supplier, the documentation identifies the letter or the audit used. Evaluation of suppliers holding applicable ASME Certificates of Authorization is done by reference to the current ASME listing of certificate holders.

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

a. Relativnly simple and standard in design, manufacture and test, and

b. Adaptable to standard or automated inspections or tests of the and 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 PD1081-05358-QA06

Pcg> 38 Rev 4 Date 09/16/85 nuclear applications cannot be imposed in a practical manner, source verification is used to provide adequate assurance of acceptability unless the quality of the item can be adequately verified upon receipt.

7.2.4 Spara 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 apare 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 engineer-ing evaluation performed by qualified individuals. The evaluation assures there is no adverse effect on interfaces, interchangeabil-ity, safety, fit, form, function or compliance with applicable regulatory or code requirements. Evaluation results are documented.

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

7.2.5 Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with 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 in" or " repair."

d. Quality records as specified in the procurement requirements.

Nuclear Assurance Department evaluates the acceptability of these documents di. ring source and/or receipt inspection.

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Pcg3 39 Rev 4 Date 09/16/85 D 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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I P;gt 41 Rev 4 Date 09/16/85 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 containers 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-43 Rev 4 Date 09/16/85 9 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 applicable codes, standards, specifications, criteria and other special require-ments.

9.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at CP Co are those for which full verification or characterization by direct inspection is impossible or impractical. Such processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement and nondestructive examination.

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

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

9.2.4 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations. Certification is based on examination results. Personnel qualification is kept current by performance of the special process (es) and/or reexamination at time intervals specified by applicable codes, specifications and standards.

Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals requires recertification.

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

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

9.2.7 The Nuclear Assurance Department audits special process qualification activities and performs inspection and surveillance of special pro-cesses to assure they are satisfactorily performed when specified by applicable inspection planning and/or site procedures. Such inspection and surveillance includes verification that process data are recorded as required, are within specified limits and are performed in accor-dance with applicable requirements.

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Page 45 Rev 4 Date 09/16/85 D 10.0 INSPECTION 10.1 POLICY Activities affecting the quality of safety-related structures, systems and components are inspected to verify their conformance with require-ments. These inspections are performed by people other than those who perform the activity being inspected. Direct inspection, process monitoring, or both, are used as necessary. Hold 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, operation and inservice inspection to verify that items and activities conform to specified requirements. Work authorizing documents (eg; procedures, instructions, maintenance work orders) are reviewed by the Nuclear Assurance Department in accordance with established criteria to do the following as necessary:

a. Determine the need for inspection (s).

b. Identify the inspection organization.

c. Identify Hold and Notification 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.

Inspection is performed at each operation where it is necessary to verify quality.

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

10.2.3 Training and qualification programs for personnel who perform inspec-tions, including nondestructive examination, are established, imple-mented and documented in accordance with Section 2.0, QUALITY ASSURANCE PROGRAM. These programs meet the requirements of applicable codes and standards. The Nuclear Assurance Department reviews and l concurs with any such programs that are not under its direct responsi-bility. Qualifications and certifications of inspection and NDE

) personnel are maintained.

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Page 46 Rev 4 Date 09/16/85 10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists and are either provided or concurred with by the Nuclear Assurance Department. They (procedures, etc) provide for l 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,

d. Specification of measuring and test equipment having the necessary accuracy.

e. Identification of personnel responsible for performing the inspec-tion,

f. Acceptance and rejection criteria,

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

10.2.5 Inspection points are designated by the Nuclear Assurance Department as mandatory hold points when confirmation is needed that the work accomplished up to that point is acceptable before the work can be D allowed to proceed further. Hold point inspections are performed, and work is released for further processing or use, by designated inspec-tion personnel. Hold points may be waived only by designated Nuclear Assurance Department personnel.

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

10.2.7 Inspection of work associated only with normal operation of the plant, such as surveillance. tests and verifications of routine maintenance may be performed by individuals in the same group as that which performed the work, but not by personnel who directly performed or supervised the work. Peer inspection is acceptable provided:

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

b. The qualification criteria for the inspection personnel have been reviewed and found acceptable by the Nuclear Assurance Department.

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/ 11.0 TEST CONTROL 11.1 POLICY Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems and components l will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified require-ments and acceptance criteria. The test program includes qualifica-tion (as applicable), acceptance, pre-operational, start-up, surveillance and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental condi-tions are specified and met. Test results are documented and evaluated.

11.2 IMPLDINTATION 11.2.1 Organizational responsibilities for testing are described in Section 1.0, ORGANIZATION.

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

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

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

c. 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 and 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 following, as applicable:

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

b. Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including accuracy require-ments, completeness of *.he item to be tested, suitable and con-I PD1081-0535B-QA06

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trolled 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. QA verification of completion of modification activities.

Test procedures and instructions are reviewed by the engineering organizations for technical content and by the Nuclear Assurance Department for QA aspects.

11.2.4 The Nuclear Assurance Department verifies, through audits, inspection l and surveillances, that test results are documented, evaluated and their acceptability is determined by responsible personnel.

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12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 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 de- l scribed 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 componente. 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 CP Co uses a system of labels to be attached to measuring and test equipment to display the next c'alibration due date. Where labels cannot be attached, a control system is used that identifies to D potential users any equipment beyond the calibration due date.

12.2.5 Measuring and test equipment is calibrated at specified intervals.

These intervals are based on the amount of use, stability characteris-tics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards are traceable to nationally recognized standards where they exist.

Where national standards do not exist, provisions are established to document the basis for calibration.

Reference standards that have at least four times the required accura-cy of the item being calibrated are used to calibrate secondary standards. When this accuracy is not possible, these standards shall have an accuracy that assures that the equipment being calibrated will be within required tolerance. In such cases the basis of acceptance is documented, and is authorized by identified management.

Secondary standards shall normally have greater accuracy than equip-ment or installed plant instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.

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Page.50 Rev 4 Date 09/16/85 D 12.2.6 When measuring and testing equipment used for inspection and test is found to be outside of required 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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P:ge 51 Rev 4 Date 09/16/85 D 13.0 HANDLING, STORAGE AND SHIPPING 13.1 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 suitably 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, packag-ing, preserving and shipping activities is described in Section 1.0, ORGANIZATION.

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

a. Cleaning, to assure that required cleanliness levels are adhieved D and maintained.

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

c. Handling, to preclude damage or safety hazards.

d. Storing, to minimize the possibility of loss, damage to or deteri-oration of items in storage, including consumables such as chemi-cals, reagents and lubricants. Storage procedures also provide methods to assure that specified shelf lives are not exceeded.

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14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 POLICY Operating status of safety-related structures, systems and components l is indicated by tagging of valves and switches, or by other specified means, in such a manner as to prevent inadvertent operation. The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.

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 plant 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.

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

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15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 15.1 POLICY

^

Safety-related materials, parts or components that do not conform to l requirements are controlled in order to prevent their inadvertent use.

Nonconforming items arc 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 documented and dispositioned, and notification is made to affected organizations. Personnel authorized to disposition, conditionally release and close out nonconformances are designated. The authority and responsibility for the 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 nonconfor-D mance and the inspection requirements. It also includes signature approval of the disposition.

b. The Nuclear Assurance Department reviews the disposition of l nonconformances, and documents concurrence with the acceptance, conditional release or repair of a nonconforming item.

c. Items that have been repaired or reworked are inspected and tested in accordance' with the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the Nuclear Assurance Department. l

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 56 Rev 4 Date 09/16/85 D 15.2.4 The Nuclear Assurance Department analyzes nonconformance reports to l identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management for review and assessment.

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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 nonconformances 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.

16.2 IMPLFJfENTATION 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. For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded. Corrective action includes determining the cause and extent of the condition, and taking appropriate action to preclude similar problems in the future.

The controls also assure that corrective action is implemented in a timely manner.

16.2.3 The identified conditions, their causes and corrective actions taken are reported to appropriate levels of management for review and assessment. The Nuclear Assurance Department reviews and documents l concurrence with actions taken to prevent recurrence, perform follow-up to verify proper implementation and determine if additional action (such as audit or surveillance) is necessary to verify the effectiveness of action taken.

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P:gs 59 Rev 4 Date 09/16/85 9 17.0 QUALITY ASSURANCE 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 QA records are described in Section 1.0, ORGANIZATION.

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

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

b. Qualification of personnel, procedures and equipment

c. Operating logs

d. 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

1. 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. Inspector or data recorder identification

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i Pcgs 60 l Rev 4 Date 09/16/85 9 f. Action taken to resolve any discrepancies noted 17.2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times. Permanent records are maintained for the life of the item.

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 I records.

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

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

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Pcg2 61 Rev 4 Date 09/16/85 18.0 AUDITS 18.1 POLICY A comprehensive system of audits is carried out to provide independent evaluation of compliance with and the effectiveness of the Quality Assurance Program, including those elements of the program implemented by suppliers and contractors. Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are docu-mented 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 schedules that reflect the status and importance to safety of tim activities being petformed. All areas where the requirements of 10 CFR 50 Appendix B apply art audited within a period of two years. The following are audited at least once every 12 months:

a. Conformance of facility operations with applicable conditions of the technical specifications and license

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

c. Controls over plant modifications 18.2.3 Audits of suppliers and contractors are scheduled based on the status and safety importance of the activities being performed and are initiated early enough to assure effactive quality assurance during design, procurement, manufacturing, construction, installation, inspection and testing.

18.2.4 Principal contractors are required to audit their suppliers systemat-ically in accordance with the foregoing scheduling criteria.

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

18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities and items and review of documents and records to confirm that the QA 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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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 Assurance Department. The resulting audit reports identify any quality deficiencies and assess the effectiveness of the QA 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 is performed by the Nuclear Assurance Department to ensure that the l appropriate corrective action is taken and is effective. Such follow-up includes reaudits when necessary.

18.2.11 Audits of operational nuclear safety-related facility activities shall be performed under the cognizance of Nuclear Safety Board (NSB).

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QAPD MANUAL APPENDIX A, PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Power Company Quality Assurance 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 Re-quirements (Operation) - Endorses ANSI N18.7 - 1976.

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

9. Regulatory Guide 1.38 - (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 N45.2.11 - 1974.

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

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Paga 64 Rev 4 Date 09/16/85 D 14. Regulatory Guide 1.88 - (10/76, Rev 2) - Collection, Storage, and Mainte-nance of Nuclear Power Plant Quality Assurance Records - Endorses N45.2.9

- 1974.

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

Endorses ANSI N45.2.5 - 1974.

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

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

18. Regulatory Guide 1.144 - (9/80, Rev 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 ASB9.5.1'(Rev 1) Guidelines for Fire Protection

} for Nuclear Power Plants.

21, 10CFR50, Appendix R Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, Sections III G., III J. and III 0.

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QAPD MANUAL APPENDIX A, PART 2 CP CO 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 endcrses.

Certain ANSI Standards invoke or imply additional standards.

Exception / Interpretation The CP Co 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.

2. N18.7 General Exception / Interpretation Consumers Power Company has established both an organizational unit and a standing committee for independent review activities. Together they form the independent review body.

The standard numeric and qualification requirement may not be met by each group individually. Procedures will be established to specify how each group will be. involved in review activities.

2a. N18.7, Sec 3.4.2 Requirement "The Plant Manager shall have overal'1 responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."

Exception / Interpretation Since CP Co has more than one nuclear unit and more than one organiza-tion providing services to these units, overall responsibility cannot be centralized in a single on-site position. Instead, responsibilities are as designated within the QA Program Description.

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2b. Sec 4.3.1 Requirement

" Personnel assigned responsibility for independent reviews shall be apecified 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 Nuclear Safety - Nuclear Assurance Department 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 Safety Board (NSB) will be specified by number and discipline.

The NSB will not specifically include a member qualified in Nondestruc-tive Testing but will use qualified technical consultants to perform this function as determined necessary by the NSB Chairman.

2c. Sec 4.3.2.1 Requirement "When a standing committee is responsible for the independent review D program, it shall be composed of no less than five persons of whom no more than a minority are members of the onsite operating organization.

Competent alternatives are permitted if designated in advance. The use of alternates shall be restricted to legitimate absences of principals."

{,xcep tion /Interpre tation See Item 2. General 2d. Sec 4.3.3.1 Requirement

". . . recommendations. .. shall be disseminated promptly to appropriate members of management having responsibility in the area reviewed."

Exception / Interpretation Recommendations made as a result of reviews will generally be conveyed to the onsite or offsite standing committee. Procedures will be maintained specifying how recommendations are to be considertd.

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2e. 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.

2f. 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.

Exception / Interpretation The Nuclear Safety Board (NSB) will not review Technical Specification Changes efter NRC approval prior to implementation. The basis for this position is that NSB reviews all Technical Specification changes prior D

to submittal to the NRC.

2g. Sec 4.4 Requirement "The onsite operating organization shall provide, as part of the normal duties of plant supervisory personnel, ..."

Exception / Interpretation Some of the responsibilities of the onsite operating organization described in Section 4.4 may be carried out by Nuclear Safety - NAD as described in plant technical specifications.

2h. Sec 4.5 Requirement

" Written reports of audits specified in ANSI N18.7 shal1 be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited."

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Exception / Interpretation The independent review body reviews or arranges for reviews of those audits over which it has cognizance, in accordance with the individual plant Technical Specifications.

Some of the QA audits required during the operational phase are in areas other than those requiring independent review in accordance with ANSI N18.7, Section 4.3.4.

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

Exception / Interpretation On-site personnel not directly associated with operating activities, as defined in ANSI N18.7, Section 2.2, are not considered to be operating personnel.

2j . 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 CP Co considers that this requirement applies only to procedures identified in plant technical specifications. Temporary changes to these procedures shall be approved as described in plant technical specifications.

2k. 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 shew 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 functiont."

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Exception / Interpretation CP Co initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which ir required to verify equipment acceptability. This action includes a technical evaluation of the equipment's operability status.

21. Sec 5.1.8 Requirement "A surveillance testing and inspection program...shall include the establishment of a master surveillar e schedule reflecting the status of all planned inplant surveillane- aats and inspections."

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

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

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

2n. Sec 5.2.13.2 Requirement ANSI N18.7 and N45.2.13 specify that where required by code, regulation or contract, documentary evidence that items conform to procurement requirements shall ba available at the nuclear power plant site prior to installation or use of such items.

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

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

Exception / Interpretation See Item 9b.

2p. 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 ara 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, See 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 The corrective action system trend reports are reviewed by the indepen-dent review body twice annually. In addition, the corrective action system is audited at least once every two years with additional audits and investigations performed as indicated necessary by the trend report reviews.

4a. ANS 3.1, General Exception / Interpretation The CP Co commitment in this QA Program Description to ANS 3.1 is limited to those requirements which apply to the training and qualifi-cation of personnel performing QA/QC functions.

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Pcgs 71 Rev 4 Date 09/16/85 D Sa. RG 1.8, C.3.1, General Exception / Interpretation The CP Co comyftment in this QA Program Description is limited to those requirements which apply to the training and qualification of personnel performing QA/QC functions.

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

Exception / Interpretation CP Co understands that this requirement applies both to CP Co employees from another site and to contract personnel who are temporarily as-signed to a nuclear power plant either as replacements for regular employees or to augment the staff during cutages. CP Co employees so D 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 train-ing. All temporarily assigned personnel receive the site general crientation as embodied in General Employee Training.

6a. N45.2.1, Sec 3.1 Requirement N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items be so classified.

Excep tion /Interp re ta tion Instead of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activities is addressed on a case-by-case basis.

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

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6b. Sec 5 Requirement

" Fitted and tack-welded joints (which will not be immediately sealed by velding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the velds can be completed."

Exception / Interpretation CP Co 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 D

l item's complexity, use and sensitivity to damage. Prior to installa-tion or use, the items are inspected and serviced as necessary to assure that no damage or daterioration exists which could affect their function.

7b. Sec 3.9 and Appendix A 3.9 Requirement "The item and the outside of containers shall be marked."

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

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

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7c. Sec 5.2.2 Requirement "The inspections shall be performed in an area equivalent to the level of storage."

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

7d. Sec 6.2.4 -

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

Exception / Interpretation Packaged food for emergency or extended overtime use may be stored in material stock rooms. The packaging assures that materials ara not g contaninated. Food will not be "used" in these areas.

7e. Sec 6.3.4 Requirement "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."

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

7f. Sec 6.4.1 Requirement "Inspectiono and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and ics container...is being maintained."

Exception / Interpretation The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule. Instead, the g inspections and examinations are performed and documented in accordance PD1081-0535C-QA06

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with material storage procedures which identify the characteristics to be inspected and include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.

8a. N45.2.3, Sec 2.1 Requirement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.

Exception / Interpretation Instead of the five-level zone designation system referenced in ANSI N45.2.3, CP Co bases its controls over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modifications work, are 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.

D 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.

9b. 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."

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

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

10a. 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 CP Co uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The N18.7 requirements are more applicable to an operating plant.

D 10b. 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."

Exception / Interpretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 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."

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Page 76 Rev 4 Date 09/16/85 Exception / Interpretation Qualification of plant personnel who perform testing is provided in specific plant specifications. Personnel participating in testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 but need only be trained to the extent necessary to perform the assigned function.

12a. RG 1.58. Sec C.1 Requirement "However, for qualification of personnel (1) who approve preoperation-al, 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 This requirement is interpretated to not apply to offsite support organizations. These departments have developed their qualification programs based on ANSI N45.2.6 and provide services throughout the h

F operations phase of Ce Co Nuciear rianes. These prestams inctuae the certification of the First Line Supervisors to ANSI N45.2.6 and eddi-tional specific requirements determined by the work activity involvad.

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, examina-tion and test objectives."

Exception / Interpretation While a Level III individual abould be capable of reviewing and approv-ing inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examina-tion and test objectives, this is not construed by CP Co as requiring personnel who review, approve or evaluate such procedures to be certi-fied as Level III personnel.

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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."

Excep tion /Interpre tation The education and experience recommendations given in ANSI N45 2.6, Section 3.5 will be treated as such, since our qualification and certification program is based upon these recommendations, and more.

significantly, upon satisfactory completion of capability testing prior to certification. It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.

12.d 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 educa-D tion 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 experi-ence. However, this may take the form of documentation other than

" procedures and records of written test" such as documentation of oral tests and on-the-job performance demonstrations.

12e. General Imposition of these Regulatory Guides on CP Co suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured.

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Pcgs 78 Rev 4 Date 09/16/85 9 13a. 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 g the plant l site for installation and testing. CP Co assures that they are avail-able to the site as necessary.

13b. Sec 2.9e Requirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installa:1on.

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

13c. Sec 4.5.1 Requirement

" Installed systens and components shall be cleaned, flushed and condi-tiened according to the requirements of ANSI N45.2.1. Special consid-eration 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 I

containers. Steel cabinets are preferred.

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P:g2 79 Rev 4 Date 09/16/85 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) may be used to organize the records for storage.

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, quality assurance records should be classified as NFPA Class 1 records . . ."

Exception / Interpretation CP Co 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, I hour or UL-Class 350).

15a. RG 1.64, C2 Requirement i

"Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design...."

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Pcgo 80 Rev 4 Date 09/16/85 D Exception / Interpretation CP Co follows Section 3E4(a) of the Standard Review Plan, which states:

"In exceptional circumstances, the designer's immediate supervisor can perform the verification, provided:

1. The supervisor is the only technically qualified individual.

2. The need is individually documented and approved in advance by the supervisors management.

3. QA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse."

16a. RG 1.144, Sec C3a(1)

Requirement This section requires that for operational phase activities, RG 1.33

" Quality Assurance Program Requirements (Operations)" are to be fol-loved. One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and occur in fatility 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 audited periodically.

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Pcg3 81 Rev 4 Date 09/16/85 D 16c. Sec C3b(1)

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

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

17a. N45.2.13. Sec J.2.2 Requirement N45.2.13 requires that technical requirements be specified in procure-ment documents by reference to technical requirement documents.

Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.11.

Exception / Interpretation For replacement parts and materials", CP Co follows ANSI N18.7 Section D 5.2.13, Subitem 1, which states: "Where the original item or part is found to be commercially 'off the shelf' or without specifically identified QA requirements, spare and replacement pa*ts may be similar-ly procured, but care shall be exercised to ensure at least equivalent pe rfo rmance ."

17b. Sec 3.2.3 Requirement

" Procurement documents shall require that the supplier have a document-ed 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 2m.

17c. Sec 3.3(a)

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

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Pcg2 82 Rev 4 Date 09/16/85 Exception / Interpretation Documents may be released for bid or contract award before cempleting the necessary reviews. however, these reviews are completed before the item or service is put into service or before work has progressed beyond the point where it would be impractical to reverse the action taken.

17d. 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 N18.7, Section 5.2.13.1 Subitems 1 through 5.) The timing of reviews will be the same as for review of the ori,inal t procurement document.

17e. Sec 10.1 Requirement "Where required by code, regulation or contract requirement, documen-tary evidence cl.at 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 2n.

17f. Sec 10.3.4 (as modified by RG 1.123, C6e)

Requirement

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

Exception / Interpretation In exercising its ultimate responsibility for its QA program, CP Co establishes post-installation test requirements, giving due considera-tion to supplier recommendations.

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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.

Exception / Interpretation

1. RC 1.26 was not used as a basis for establishing the lists of safety-related items for the Palisades and Big Rock Point Plants.

For Big Rock Point, items are classified as safety related or non-safety related in accordance with Regulatory Guide 1.29,

2. Items falling into Groups A, B and C are considered to be safety related. Group D items are not.

19a. Branch Technical Position ASB9.5.1 and 10CFR50 Appendix R.

Sections III G., III J. and III 0., General Exception / Interpretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10CFR50 Appendix R except for the

> specific exemptions approved by the NRC.

20a. RG 1.29. General Requirement Apply pertinent Quality Assurance requirements of 10CFR50, Appendix B.

Excep tion / Int e rpre ta tion The pertinent QA requirements for these systems, structures and compo-nents 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 10CFR50 applies.

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