ML20148N918
| ML20148N918 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/01/1997 |
| From: | Fenech R, Joos D, Nicholson R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20148N916 | List: |
| References | |
| CPC-2A, NUDOCS 9707010003 | |
| Download: ML20148N918 (141) | |
Text
...
. -.. - =
l i
ATTACHMENT 1 i
CONSUMERS ENERGY COMPANY f
BIG ROCK POINT PLANT DOCKET 50-155 l
PALISADES PLANT DOCKET 50-255 i
i 1
l I
1 Revision 17 of CPC-2A l
87 f
Pages k05hohf55' D
l Quality 3
i
... rograrn..s)escription 4
[OP i
Operational Nuclear ~?ower.:?1-mfo 1
J l
t l
(v.3(v-m j
p E 3 J
sia ROCK POIM; 3
I T
1 b
O,_ _
f n
l:: n
- -r:
l}d. 4;: iliiiii n
~
,i PfluSADES l
I 4
4 i
i I.
4
~
J N
1-l A CMS E4mv Car" wry i.
m uichaos c. uorrori
..o, t.,
yr 1
February 1,1997 i-5
)
i
SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMPANY QUALITY PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As President and Chief Executive Officer of Consumers Power Company, I have the ultimate management authority for the Cana"marm Powar f'ama.,w num11,v Prnaram ru.crin*ian fnr nnarational Nucinar Powar Planen. The Quality Program Description complies with the quality assurance requirements contained in Appendix B of 10 CFR 50, " Quality Assurance Criteria for Nuclear Power j
Plants and Fuel Reprocessing Plants" and responds to the additional guidance contained in ANSI N18.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of 3
applicability imposed by N18.7. The Quality Program Description for Operational Nuclear Power Plants l
outlines the actions that are implemented during the operational phase including fueling, testing, l
operation, refueling, procurement, maintenance, repair, and modification design and construction of the safety-related portions of the nuclear power plants.
I have delegated responsibility for establishing, maintaining and implementing the Quality Program Description through the Executive Vice President and Chief Operating Officer-Electric to the Vice President, Nuclear Operations. I have delegated selected portions of the Quality Program to the Vice President, Fossil and Hydro Operations; Vice President, Electric Transmission and Distribution; Vice l
j President, Information Technology and Operations Services Division; and through a Vice Chairman of i
Consumers Power Company to the Vice President and Secretary. This Quality Program Description describes the Consumers Power Company organizations responsible for irgiementation.
)
The Quality Program Description contains mandatory requirements which must be implemented and i
enforced by all responsible organizations and individuals.
1 l
I'
/
Y' II d
3
i l
I Page ii l
Rev 17 l
Date: Febmay 1,1997 l
QUALITY PROGRAM DESCRIPTION FOR l
OPERATIONAL NUCLEAR POWER PLANTS REVISION 17 APPROVED BY:
l l~50- 97 ExecDT!fe Vice{\\
resident nd Chief Operating Officer - Electric Date D. W. Joos
/ - ' -" A
/ -3/ - 9 7 Vice President, Nuclear Operations Date R. A. Fenech
/.$/* Y Y Vice President, Fossil arttf Hydro Operations Date R. J. Nicholson O//7/
)
l Vice President, Efectric Transmission and Distribution Date' l
C. L. English 1
(
//3I/17 Vi6e President. Inicrmation T'echnology/nd %ekations Services Date l
K. C. Ernery
/
(. h -
l-C]$- f I
Vice President and Secretary Date T. A. McNish l
I I
)
l l
Page iii l
i Rev 17 l
Date: February 1,1997 l-QUALITY PROGRAM DESCRIPTION FOR I
OPERATIONAL NUCLEAR POWER PLANTS CONTENTS Section Title Pace l
Statement of Responsibility and Authority I
Approval Page ii Contents lii 1.0 ORGANIZATION
,......................................... 1 2.0 QUALITY PROGRAM 12 3.0 D E SIG N CO NTRO L................................
16 4.0 PROCUREMENT DOCUMENT CONTROL........................ 19 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS................... 21 6.0 DOCUMENT CONTROL...
25 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES..... 26 8.0 IDENTIFICATION AND CONTROL OF ITEMS 29 l
9.0 CONTROL OF SPECIAL PROCESSES 30 10.0 INSPECTION............................................
31 11.0 TEST CONTROL 34 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT................. 36 13.0 HANDLING, STORAGE AND SHIPPING.......................... 38 14.0 INSPECTION, TEST AND OPERATING STATUS.................... ' 39 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS........... 40 j
16.0 C O R R ECTIV E ACTIO N..................................... 42
(
17.0 QU ALITY RECORDS..............
43 i
18.0 A U D IT S.....................................
45
?
l r,
i i
Page iv Rev 17 -
Date: February 1,1997 A PP E N D I X A........................,..................
47 APPENDIX B 73 l
. A PPEN DIX C..................
77 A P P E N D I X D........................................................
80 l
APPENDIX E
........................................................ 81 i
i
'I FIGURES 1 Consumers Power Company Corporate Organization
... 10 2 Nuclear Operations Organization...................................... 11 l
1 i
I j
i
Pago 1 R2v 17 Date: February 1,1997 1.0 ORGANIZATION 1.1 POLICY Consumers Power Company (CPCo) is responsible for establishing and implementing the Quality Program, as described herein, for the operational phase of its nuclear power plants. Although authority for development and execution of some parts of the program is delegated to others, such as contractors and consultants, CPCo retains overall responsibility.
This section of the Quality Program Description (QPD) identifies the CPCo organizations responsible for activities affecting the quality of safety-related nuclear power plant i
structures, systems and components and describes the authority and duties assigned to them it addresses responsibilities for attaining quality objectives; for establishing and maintaining the Quality Program; and for assessing the performance of activities affecting the quality of safety-related items. The control of this Quality Program Description is the responsibility of the Nuclear Performance Assessment Department.
Nuclear Performance Assessment Department (NFAD) functions (audits, surveillances, and independent safety reviews) are performed by personnel within formally designated organizational units that report to the Manager, Nuclear Performance Assessment or members of other organizations as selected by the Manager, Nuclear Performance i
Assessment. The reporting level of the Nuclear Performance Assessment organization affords sufficient authority and organizational freedom, including sufficient indepen-dence from the cost and schedule impacts of Nuclear Performance Assessment organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions, j
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 1,2.1 2a 1.2.2 2g I
1.2.2.c 2,2b,2c 1.2 IMPLEMENTATION 1.2.1 Source of Authoritv The President and Chief Executive Officer (see Figure 1 of Company Organization Charts) of CPCo is responsible for safe operation of CPCo nuclear power plants.
Authority and responsibility for establishing and implementing the Quality Program for plant operations, maintenance and modifications is delegated through the Executive Vice President and Chief Operating Officer - Electric to the Vice President - Nuclear Operations. This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer. Other quality-related functions are provided by other organizations as described herein.
CPC 2A.R17
]
i Pags 2 l
Rzv17
{
Date: February 1,1997
]
L i
1.2.2 Resoonsibility for Attainino Quality Obiectives in the Nuclear Ooerations Oraanization l
The Vice President - Nuclear Operations is responsible to the Executive Vice President and Chief Operating Officer - Electric for operation and maintenance of CPCo nuclear
{
power plants. Managers who report to the Vice President, NOD, are responsible for directing the performance of activities that affect safe plant operation and/or safety-A related functions of structures, systems and components of the operating nuclear power l
plants in accordance with Quality Program requirements.
l a
The Palisades Plant General Manager (see Figure 2) is responsible to the Vice a.
President, Nuclear Operations for operation and maintenance of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable J
regulations and the Quality Program. The Piant General Manager delegates to appropriate managers and staff personnel in his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed on the authority of the Plant General Manager include:
[
Qualification of plant operating, inspection and maintenance personnel, including certification of inspection personnel.
Preparation, review and approval of plant procedures and instructions.
Modifying components, including procurement, installation, inspection and testing activities when assigned by the Plant General Manager.
Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits.
Maintaining Echelon lil calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL M&TE).
Calibration / maintenance of installed plant instrumentation.
Maintaining a calibration recall system.
Maintaining a Master List for plant-owned PL-M&TE.
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.
Developing, maintaining and implementing site emergency plan.
Conducting a water chemistry program in accordance with technical specifications.
Stopping unsatisfactory work to control further processing, delivery or installation of nonconforming materials or items.
CPC 2A.R17 l
g Piga 3 R:;v 17 Date: February 1,1997 Plant site inspection program, including inspection of maintenance, testing and fuel handling.
Assuring that nonconforming items are identified, segregated and dispositioned.
Procurement of nuclear fuel and associated services, including source verification at fuel supplier facilities, fuelinspection upon delivery and review of fuel supplier quality-related documentation Reactor engineering such as accident-transient and physics analysis of reloads, reactor core and nuclear fuel design and core thermal-hydraulic and nuclear support of plant modifications and operations.
Development and utilization of nuclear plant probabilistic safety assessment models to evaluate safety and plant reliability improvement Establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program Indoctrination and training.
Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules.
Performing reviews to advise the Plant General Manager on matters related to nuclear safety, as specified in Appendix B, Plant Review Committee, b.
The Big Rock Point Plant Manager (see Figure 2) is responsible to the Vice President, Nuclear Operations for operation and maintenance of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable regulations and the Quality Program. The Plant Manager delegates to appropriate managers and staff personnelin his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed on the authority of the Plant Manager include:
Qualification of plant operating, inspection and maintenance personnel, including 4
certification of inspection personnel.
Preparation, review and approval of plant procedures and instructions.
Functioning as the plant design and configuration control authority for compliance of plant modifications and design changes to existing plant design criteria.
Modifying components, including procurement, installation, inspection and testing activities when assigned by the Plant Manager.
Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits.
CPC-2A.R17
Paga 4 Rsv17 Date: February 1,1997 Maintaining Echelon ill calibration facilities for Portable and Laboratory Measuring l
and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TEl.
Calibration / maintenance of installed plant instrumentation.
Maintaining a calibration recall system.
Maintaining a Master List for plant-owned PL-M&TE.
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 a water chemistry program in accordance with technical specifications.
Stopping unsatisfactory work to control further processing, del'very er installation j
of nonconforming materials or items.
Plant site inspection program, including inspection of maintenance, testing and fuel handling.
j Preparation, review, and approval of Q-list updates.
Assuring that nonconforming items are identified, segregated and dispositioned.
l Reactor engineering such as accident-transient and physics analysis of reloads, reactor core and nuclear fuel design and core thermal-hydraulic and nuclear support of plant modifications and operations.
Establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program indoctrination and training.
l Development and utilization of nuclear plant probabilistic safety assessment models to evaluate safety and plant reliability improvement.
Procurement, including preparation, reviews and approval of purchase requests for spares, replacement items, consumables, and materials, items and services and submittal of purchase requests to Purchasing. Planning and execution of vendor source surveillance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.
Providing for storage and protection of purchased materials and items and items awaiting disposition implementation after removal from service, assuring preservation of identification.
Accomplishing plant licensing activities including maintaining licensing documents up to-date, interfacing with the NRC, accomplishing and/or tracking licensing CPC-2A.R17
l Page5 Roe 17 i
Date: February 1,1997 t
i j
commitments and coordinating internal action on NRC bulletins, generic letters, etc.
l Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability.
Operating experience reviews including NRC Information Notices.
t Performing the engineering, construction, inspection and testing associated with generating plant modification projects as assigned.
i.
Conducting the inservice inspection program in accordance with technical 1
specifications and State of Michigan rules.
l Developing, maintaining and implementing security, fire protection and emergency l
plans.
?
Performing reviews to advise the Plant Manager on matters related to nuclear j
safety, as specified in Appendix B, Plant Review Committee.
l The Manager, Nuclear Performance Assessment Department, (see Figure 2) is c.
responsible for:
Assessment of the effectiveness of the Nuclear Operations Quality Program.
Performance of the offsite safety review functions for the nuclear power plants as described in Appendix C, independent Safety Review.
Supplier surve. <s and evaluation including review / approval of supplier QA programs, and maintenance of the NOD Approved Suppliers List.
Preparation, review, approval and implementation of departmental procedures governing nuclear assessment activities.
Assessment of nuclear safety performance as described in the Technical I
Specifications.
Assuring that assessments are done by personnel not directly responsible for the work being performed.
-]
Recommending to the Plant General Manager / Managers or the Vice President, Nuclear Operations that a plant be shut down if such action appears necessary.
Assessment programs (plant sites and Corporate Office), including follow-up on corrective action for audit findings.
Review of performance trends associated with NOD activities including corrective actions.
CPC-2A.R17 -
Page 6 Rcv 17 Date: February 1,1997 Analysis of new and/or changed regulatory direction, codes and standards to determine their effect on the Quality Program.
j Maintenance of the Quality Program Description for Operational Nuclear Power Plants.
Reporting audit findings relative to follow-up on corrective actions and the effectiveness of the Quality Program to CPCo Management.
Maintenance / operation, processing and status reporting of the corrective action system (Palisades only).
l in order to implement these responsibilities, the Mancger, NPAD, is provided with "Stop Work" authority whereby he can suspend any quality related activity or process which may, in his opinion, adversely affect public safety or the safe operation of Consumers Power nuclear plants. A Stop Work order that would result in plant shutdown is given as a recommendation - NRC licensed operating staff are responsible for determining and carrying out the safest course of actions.
The Manager, Nuclear Performance Assessment has no other primary duties or responsibilities unrelated to Nuclear Performance Assessment that would prevent his attention to Nuclear Performance Assessment matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality considerations in his decisions and recommendations, and has direct access to high enough levels of Management to obtain resolution of quality problems, d.
The General Manager, Nuclear Services (see Figure 2) is responsible for designated activities in support of the Palisades Plant:
Preparing, reviewing, approving and implementing procedures for activities carried out by the department.
Accomplishing plant licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or tracking licensing commitments and coordinating internal action on NRC bulletins, generic letters, etc.
Providing determination of NRC reportability for corrective action documents.
Operating experience reviews including NRC Information Notices.
Functioning as the design and configuration control authority for compliance of plant modifications and design changes to existing plant design criteria. This includes preparing, reviewing and approving changes to plant engineering / design documents.
Performing the engineering, procurement, construction, inspection and testing associated with generating plant modification projects as assigned.
l CPC-2A.R17
Pagt 7 R;v 17 Date: February 1,1997 Providing, as requested, technical expertise and review capability to Nuclear Operations in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil structural engineering and application of codes and standards.
Preparation, review and approval of Q list updates.
Performing analytical studies to appraise the adequacy of electrical supply to safety-related equipment in nuclear power plants from the principal power supply facilities of the transmission network and onsite power supply.
Procurement, including preparation, reviews and approval of purchase requests for spares, replacement items, consumables, and materials, iterns and services and submittal of purchase requests to Purchasing. Planning and execution of vendor source surveillance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.
Providing for storage and protection of purchased materials and items and items awaiting dispositio1 implementation after removal from service, assuring preservation of identification.
Developing, maintaining and implementing security and fire protection plans.
Maintaining the Records Management System including required retention, protection and retrievabihty. This includes collecting, storing, maintaining, distributing and controlling plant engineering / design documents.
1.2.3 Resoonsibilitv for Attainina Quality Obiectives in Fossil and Hvdro Ooerations The Vice President, Fossil and Hydro Operations (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer - Elcctric. Directors and Managers reporting to him are responsib!e for directing the performance of activities in accordance with Quality Program requirements.
a.
The Manager, Equipment Services provides electrical, rotating and stationary l
equipment expertise, including developing and qualifying procedures for welding and heat treating, b.
The Director, Fuel Supply & Plant Operations maintains the Records Management l
System including required retention, protection and retrievability. This includes collecting, storing, maintaining, distributing and controlling plant engineering / design documents (Big Rock only). This excludes Big Rock Safeguards information documents, which are maintained at Big Rock. The accuracy, quality, and correctness of Big Rock documents in the Records Management System are the responsibility of Big Rock Point.
3 CPC 2A.R17
. ~ ~
~.-
Pags 8 1
l Rav17 j
Date: February 1,1997 1.2,4 Resoonsibilitv for Attainina Qualitv Obiectives Outside Nuclear Ooerations and Fossil and Hvdro Ooerations 4
Certain functions that constitute part of the Nuclear Operations Quality Program are performed by CPCo organizational units outside the Nuclear Operations Department or Fossil and Hydro Operations. Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization responsible for that activity (i.e., the design authority).
The Manager, Electric System Operations (see Figure 1) is responsible through the a.
Vice President, Electric Transmission and Disbribution to the Executivo Vice President and Chief Operating Officer - Electric for determining settings for electrical protective systems and relay control schemes, and for design, review and i
recommending changes to electrical protective schemes and associated settings.
l l
b.
The Director, Electric Employee Development (see Figure 1) is responsible to the Executive Vice President and Chief Cperating Officer - Electric for operating the Skill Centers including the training, and qualifying of personnel and equipment for welding operations.
I c.
The Corporate Records Administrator (see Figure 1) is responsible through the Vice
)
President and Secretary for microfilming of specified quality records and plant i
engineering / design documents, i
d.
The Manager, Environmental and Technical Services (E&TS) is responsible, through i
the Vice President, Information Technology and Operations Services to the President and Chief Executive Officer for:
e Maintaining the Company's Echelon ll calibration facility for calibrating reference and secondary standards and general usage portable and laboratory measuring and test equipment.
4 Controlling the calibration recall system for Portable and Laboratory M&TE owned 2
by E&TS, and other departments, as requested, i
Maintaining a Master PL-M&TE List for E&TS PL-M&TE and for other departments, as requested.
i l
Providing a PL-M&TE Inventory List for Nuclear Operations.
ij l
Providing chemistry support to Nuclear Operations, as requested.
Preparing, reviewing, approving and obtaining additional reviews and approvals if j
required, of purchase requests for services, equipment and consumables, and i
submitting such requests to purchasing for procurement action.
Conducting performance tests on materials, equipment and systems when requested.
CPC 2A.R17 4
a k
g Page 9 Rev 17 Date: February 1,1997 Performing nondestructivc examination, and controtting/ maintaining NDE equipment.
j Providing qualified NOE 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.
The Manager, Electric Services is responsible, through the Vice President, Electric Transmission and Distribution to the Executive Vice President and Chief Operating e.
Officer - Electric for testing and maintaining electncal protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associated settings.
i CPC-2A.R17
Energy and Chairman - ]
CPCo
'1 l
- n-an www xw l
I
~
Vice Chairman - CMS President & CEO -
Energy and Vice CPCO Chairman CPCo I
I Executive Vice Vice President Pressdent & COO Information Technology Electric
& Operations Services Vice President &
Secretary I
i l
i Vice President Ebetric Vice Proeident Director Electric Manager T.
Fossil & Hydro Employee Environmental &
D6stribunon Operemons Development Technical Services i
1 Corporate Records Admirwetrator Manager Director.
Electnc System Fuel Supply &
Operemons Plant Operemons 222 iii < E EG&
Electnc Services Manager Egtepment 5[
Manager Services g
2
?
a m
(,0 N
Figure 1 - Quality Program Organizational Chart for Operational Nuclear Power Plants
l Page 11 Rev 17 l'
Date: February 1,1997 l
l i
l 1
i Vice President Nuclear Operations
- -ammmmmmmem l
l l
I I
i Nuclear Nuclear Mont Nuclear Ment Nuclew Services Perfwmence Meneger General Meneger 0"
N A'**
- Big Rock Point Polisadee Meneger Figure 2 - Nuclear Operations Department Organization f
Pags 12 Rav17 Date: February 1,1997 i
l 2.0 QUALITY PROGRAM 2.1 POLICY Policies that define and establish the Consumers Power Company (CPCo) Quality Program for Operational Nuclear Power Plants are stated in the individual sections of this document. The program is implemented through procedures and instructions responsive to provisions of the Quality Program Description and will be carried out for the life of each plant.
Quality controls apply to activities affecting the quality of safety-related structures, systems and components, to an extent based on the importance of those structures, systems, or components to safety. Such activities are performed under suitably controlled conditions, including the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that all applicable prerequisites have been met.
Quality Program status, scope, adequacy and compliance with 10 CFR 50, Appendix B are regularly reviewed by CPCo Management through reports, meetings and review of audit results. A preplanned and documented assessment of the nuclear safety performance is conducted as described in Appendix C.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
l Paraaraoh Exceotions/Interoretations 2.2.3 20a, 20.b I
2.2.5 19a l
2.2.6 1,18a,20a,20b 2.2.9 2J, 4a, Sa, Sb, 6a, 7b,10a, lla,12a,12b,12c,12d,13a,17e 2.2.10 2e, 2f 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 provisions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10 CFR 50, I
Appendix B. The statement makes this Quality Program Description and the associated implementing procedures and instructions mandatory and requires compliance by all responsible organizations and individuals. It identifies the Management positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness.
2.2.2 The Quality Program at CPCo consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION).
t 2.2.3 The effectivity and applicability of this Quality Program Description are as follows:
CPC 2A.R17 y
r
Paga 13 R::V 17 Date: February 1,1997 For Big Rock Point and Palisades, the Quality Program Description became a.
effective on April 1,1982, with fullimplementation on January 1,1983.
1 b.
The Quality Program described in this Quality Program Description is intended to I
apply for the life of CPCo's nuclear power plants, The Quality Program applies to activities affecting the quality of safety-related c.
structures, systems, components and related consumables during plant operation, maintenance, testing and all modifications. Those activities having a direct impact on saf6ty related items shall be controlled. Safety-related structures, systems, components and related consumables are identified in Q-Lists, which are developed and maintained for each plant in accordance with the criteria of Regulatory Guide 1.29 as clarified by items No. 20a and No. 20b in Part 2 of Appendix A to this Quality Program Description.
2.2.4 This Quality Program Description, organized to present the CPCo Quality Program for Operational Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states CPCo policy for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this Quality Program Description that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually. Any changes made to this Quality Program Description that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation. The submittal of the changes described above shall be made in accordance with the requirements of 10 CFR 50.54.
The program described in this Quality Program Description will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B.
2.2.5 Documents used for implementing the provisions of the Quality Program Description include the following:
a.
Administrative procedures specify the standard methods of accomplishing operational phase activities. Because the Quality Program is an integral part of the operational phase activities, the methods for implementing Quality Program controls are integrated into these documents.
l b.
When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50, Appendix B and the contract, and are approved by CPCo prior to the start of work.
c.
Applicable elements of the operations Quality Program are applied to emergency plans, security plans, radiation and fire protection plans for CPCo nuclear power plants. These plans describe quality controls applicable to associated equipment and activities.
2.2.6 Provisions of the Quality Program for Operational Nuclear Power Plants apply to activities affecting the quality of safety related structures, systems, components and related consumables.
l CPC-2A.R17 l
l
I Pagn 14 Ray 17 l
Date: February 1,1997 l
Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which CPCo commits. Appendix A also describes necessary exceptions and i
clarifications to the requirements of those documents. The scope of the program and
~
i the extent to which its controls are applied are established as follows:
CPCo uses the criteria specified in Regulatory Guides 1.26 and 1.29 in engineering a.
evaluation of an item's function in relation to safe operation and shutdown to identify structures, systems and components to which the Quality Program applies (See Appendix A).
b.
This identification by engineering personnel results in the classification of equipment as either safety related or non-safety related, and the inclusion of this classification in an equipment data base. This data base is available for, inquiry by individuals involved in plant operation. The classification of structures, systems and consumables is also identified, documented, and controlled, c.
The extent to which controls specified in the Quality Program are applied to items is determined for each item considering its relative importance to safety. Such l
determinations are based on data in such documents as the plant safety analysis, plant Technical Specifications and the FSAR/FHSR (See Appendix A).
2.2.7 Activities affecting the quality of safety-related items are accomplished 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.
Specified equipment and/or tools, if any, are on hand to be used.
d.
Materials and items are in an acceptable status.
e.
Systems or structures on which work is to be performed are in the proper condition for the task.
f.
Authorized current instructions / procedures for the work are available for use.
g.
Items and facilities that could be damaged by the work have been protected, as
- required, h.
Provisions have been made for special controls, processes, tests and verification methods.
2.2.8 Development, control and use of computer programs affecting nuclear power plant design and operation at CPCo are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).
CPC 2A.R17
a Pega 15 Rsv 17 Date: February 1,1997 l
2.2.9 Responsibility and authority for planning and implementing indoctrination and training are specifically designated in the CPCo organization (see Section 1.0, ORGANIZATION).
The training and indoctrination program provides for ongoing training and periodic a.
refamiliarization with the Quality Program for Operational Nuclear Power Plants.
b.
Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.58, SNT TC-1 A, or the ASME l
Code, or Section 10.2.3 of this Quality Program Description, as applicable, Personnel who lead audits are qualified in accordance with Regulatory Guide c.
1.146. Others are either qualified to ANSI N45.2.23 or have detailed expertise in the area being audited.
l d.
Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with applicable codes, standards and regulatory guides, The training / qualification program for personnel leading audits includes provisions e.
for retraining, reevaluation and recertification to ensure that proficiency is maintained, i
f.
Training and qualification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the personnelinvolved are performing activities to which the training / qualification is l
relevant.
g.
Personnel responsible for performing activities that affect quality are instructed as to the requirements identified in applicable quality related manuals, instructions and procedures.
2.2.10 Status and adequacy of the quality program are regularly assessed by CPCo Manage-ment. The following activities constitute formal elements of that assessment:
a.
Audit reports, including follow-up on corrective action accomplishment and i
effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).
b.
Management teams assess the nuclear safety performance as described in Appendix C. Conclusions and recommendations are reported to the Executive Vice l
President and Chief Operating Officer - Electric.
Corrective actions in response to recommendations are tracked in the regular l
corrective action tracking system (see Section 16.0, CORRECTIVE ACTION).
i i
l CPC-2A.R17 1
l
t!'
Paga 16 Rev 17 l
Date: February 1,1997 l
l l
3.0 DESIGN CONTROL l
3.1 POLICY Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled.
Depending on the type of modification, these activities include design and field i
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 preparation and review of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 3.1 9a,13b 3.2.9 15a 3.2.10 13d 3.2 IMPLEMENTATION l
3.2.1 Authority and responsibility for modification activities is under the cognizance of the Nuclear Operations Department as described in Section 1.0, ORGANIZATION. This authority and responsibility includes the preparation, review, approval and verification of the following design documents: a) System descriptions; b) Design input and criteria; c)
Drawings and specifications; and d) Engineering analyses and associated computer programs.
l 3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect structures, systems and components are documented. Action is taken to assure that the errors and deficiencies are corrected.
3.2.3 Materials, parts and processes that are essential to safety-related functions are selected and specified, based on the require /nents of applicable codes and standards or on known, successful use under similar conditions. This includes standard commercial materials, parts and processes. A;ternatively, 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 j
verifications or approvals.
I 3.2.4 Exceptions and waivers to or deviations from the engineering (quality) standards (i.e.,
the required dimensions, material properties, features and other characteristics specified for modifications) are required by procedure and by contract, when appUcable, to be documented and controlled. (See, also, Section 15 concerning the approval of " repair" or "use as is" dispositions of nonconformances.)
CPC 2A.R17 l
i l
l Pags 17 l
Rsv 17 Date: February 1,1997 l
3.2.5 When modifications involve design interfaces between internal or external design organizations or across technical disciplines, these interfaces are controlled. Procedures are used for the review, approval, release, distribution and revision of documents involving design interfaces to ensure that structures, systems and components are compatible geometrically, functionally and with processes and environment. Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses.
Decisions and problem resolutions involving design interfaces are made by the CPCo organization having responsibility for engineering direction of the design effort.
3.2.6 Checks are performed and documented to verify the dimensional accuracy and completeness of design drawings and specifications (i.e., the products of a design process).
3.2.7 Modification design document packages are reviewed by either Plant Engineering personnel or by Nuclear Engineering and Construction personnel to assure that the documents that they contain have been prepared, verified, reviewed and approved in accordance with Company procedures and that they contain the necessary quality requirements. These requirements include the inspection and test requirements, quantitative and/or qualitative acceptance criteria and the 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 importance of the item to safety, design complexity, degree of standardization, the state-of-the-art and similarity with previously proven designs. Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews. These methods may be used singly or in combination, depending on the needs for the design under consideration.
When design verification is done by evaluating standardized or previously proven designs, the applicability of such designs is confirmed. Any differences from the proven design are documented and evaluated for the intended application.
Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated. This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function.
Qualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented. Results are evaluated to assure that test requirements have been satisfied. Modifications shown to be necessary through testing are made, and any necessary retesting or other verification is performed. Scaling laws are established and verified, when applicable. Test configurations are clearly documented.
Design reviews are performed by multi-organizational or interdisciplinary groups or by single individuals. Criteria are established to determine when a formal group review is required and when review by an individualis sufficient.
CPC 2A.R17
i Pags 18 RLv 17 Date: February 1,1997 1
Unless otherwise stated, the verification of design addresses allinformation 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.
4 3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience but are not directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that:
(1) He is the only technically qualified individual available, and 1
(2) He has not specified a singular design approach, ruled out certain design considerations or established the design inputs for the particular design aspect being verified, and (3) His review is either:
Approved in advance by the supervisor's management, with documentation a.
of the approvalincluded in the desit,n package, or b.
Controlled by a procedure which provides specific limitations regarding the l
types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification.
Independent audits by Nuclear Performance Assessment cover the frequency, effec-tiveness, and technical adequacy of the use of supervisors as design verifiers to guard against abuse.
3.2.10 When designs must be released for use before they have been fully completed or before they have been verified, the incomplete or unverified parts of the design and the hold point to which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety related function.
Justification for such early release is documented.
3.2.11 Computer codes used in design are approprit,tely 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, organizations that approved the original design.
Information on approved changes is transmitted to all affected organizations.
CPC-2A.R17
Pags 19 3
Rav 17
)
Date: February 1,1997 j
4 4.0 PROCUREMENT DOCUMENT CONTROL i
J
' 4.1 POLICY Procurement documents for safety-related structures, systems, components and services define the characteristics of item (s) to be procured, identify applicable regulatory and industry codes / standards requirements and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.
The following exceptions / interpretations in Appendix A, Pa t 2, are relevant to j
implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations i
4.2.1 17c,17d l
4.2.3 21,17a,17b l
4.2.5 17d e
4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement p!anning and for preparation, review and approval of procurement documents are delineated in Section 1.0, ORGANIZATION.
j Procurement request packages are reviewed and approved prior to submittal to the Purchasing and Materials Department. Review includes verification that the necessary quality requirements are specified.
The responsible project engineer performs bid evaluations.
4 j
4.2.2 Supplier selection is described in Section 7.0, CONTROL OF PURCHASED MATERIALS, EQUIPMENT AND SERVICES.
4.2.3 The contents of procurement documents vary according to the item (s) being purchased and its function (s) in the plant. Provisions of this Quality Program Description are considered for application to suppliers. As applicable, procurement documents include:
a.
Scope of work to be performed.
b.
Technical requirements, with applicable drawings, specifications, codes and standards identified by title, document number and revision and date, with any required procedures such as special process instructions identified in such a way as to indicate source and need.
c.
Regulatory, administrative and reporting requirements.
d.
Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections, e.
A requirement for a documented Quality Program, subject to CPCo review and written concurrence prior to the start of work.
CPC-2A.R17
. - ~ -
~
Pags 20
~
Rav 17 5
Date: February 1,1997 J
f.
A requirement for the supplier to invoke applicable quality requirements on subtier suppliers.
g.
Provisions for access to supplier and subtier suppliers' facilities and records for inspections, surveillances and audits.
j h.
Identification of documentation to be provided by the supplier, identification of documents to be compatible with the records system, the schedule of submittals and identification of documents requiring CPCo approval.
4.2.4 Trained, qualified personnel perform and document reviews of procurement request packages to assure that; j
a.
Quality requirements (see 4.2.3 of this Section) are correctly stated, inspectable, and controllable.
b.
Adequate acceptance and rejection criteria are included.
i c.
The procurement documents have been prepared, reviewed, and approved per the
)
Quality Program requirements.
4 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.
4 Those that could affect fit, form, function or the necessary assurance of quality are reviewed and approved by the same, or equivalent, organizations that approved the i
original procurement request packages, d
4 t
J 4
CPC-2A.R17
Pegs 21 l
Rav17 i
Date: February 1,1997 l
l l
5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 POLICY l
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 i
satisfactorily completed.
I I
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraaraoh Exceotions/Interoretations 5.1 9a,13b j
5.2.8 2r, 2s, 8a 5.2.14 6b 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 i
instructions, procedures and drawings necessary to accomplish the activity a e 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)
I and/or qualitative (such as workmanship standards) acceptance criteria sufficient to I
determine that the activity has been satisfactorily accomplished.
i l
i Temporary procedures may be issued to provide management instructions which have short-term applicability. Temporary procedures include a designation of the time period during which they may be used.
I i
The procedures used by CPCo to control its activities include the following:
1 1.
Administrative Procedures.
2.
System procedures that describe the operation of the plant, j
3.
Start-up procedures that provide for starting the reactor from hot or cold condition and recovering from reactor trips.
I 4.
Shutdown procedures tnat provide for controlled reactor shutdown or shutdown l
following reactor trips.
5.
Power operation and load changing procedures that provide for steady state power operation and load changing, including response to unanticipated load changes.
CPC-2A.R17 I
_ _. _.~. _ - _......... _ _ _
Patge 22 Rav17 Date: February 1,1997 l
l 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 activities such as:
t.
a.
b.
Refueling l
l c.
Fuel accountability l
d.
Receipt and shipment of fuel t
e.
Nuclear safety measures
[
8.
Maintenance procedures that provide for:
a.
Preparation for maintenance b.
Performance of maintenance c.
Post-maintenance and operability checks and tests l
d.
Use of supporting maintenance documents 9.
Radiation control procedures that provide for:
a.
Implementation of the radiation control program including the acquisition of radiation data l
b.
Identification of equipment for performing radiation surveys c.
Measurement, evaluation and assessment of radiation hazards
- 10. Calibration and test procedures that provide for:
a.
Periodic calibration and testing of safety-related instrumentation and control systems l
b.
Calibration of portable measuring and test equipment used in activities affecting safety i
- 11. Chemical-radiochemical control procedures that provide for activities including:
1 a.
Sampling and analyses b.
Maintenance of coolant quality l
c.
Control of deleterious agents i
CPC-2A.R17 l
~
pig 3 23 Rav17 Date: February 1,1997 I
i d.
Control, treatment and management of radioactive wastes l
e.
' The control of radioactive calibration sources
- 12. Emergency procedures that provide guidance for:
l Operations during potential emergencies so that a trained operator will know a.
in advance the expected course of events that willidentify 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 l
- 13. Emergency Plan Implementing Procedures
- 14. Inspection, test and examination procedures that identify:
a.
Objectives b.
Acceptance criteria c.
Prerequisite and special conditions d.
Limiting conditions e.
Test or inspection instructions f.
Any required special equipment or calibration g.
Hold and Witness points, as appropriate
- 15. Modification procedures that provide for:
a.
Administrative control and technical support during plant modifications b.
The basis for a consistent method of performing recurring engineering, construction and quality activities c.
Control of the interfaces between CPCo and its suppliers d.
Offsite management control e.
Control of onsite quality-related modification activities that assure the Quality Program is implemented and its effectiveness is assessed and reported l
[
CPC-2A.R17 l
Pigs 24 Rsv 17 Date: February 1,1997 6.0 DOCUMENT CONTROL 6.1 POLICY Documents controlling safety-related activities within the scopo defined in Section 2.0, QUALITY PROGRAM are issued and changed according to established procedures.
Documents such as instructions, procedures and drawings, including changes thereto, l
are reviewed for adequacy, approved for release prior to implementation by authorized personnel
- and are distributed and used at the location where a prescribed activity is performed.
Changes to controlled documents are reviewed and approved by the same organizations that performed the original review and approval or by other qualified, responsible organizations specifically designated in accordance with the procedures governing these documents.
1 Personnel authorized to approve procedures specified by plant Technical Specifications are limited to:
1.
For Palisades, an appropriate senior department manager, based on the l
activities addressed in the specific procedure, predesignated in writing by the Plant General Manager; or 2.
For Big Rock Point, the Plant Manager.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraaraoh Exceotions/Interoretations 6.1 2h,2n 6.2.3 2h,2n,2s,12b 6.2 IMPLEMENTATION 6.2.1 The authority and responsibility for the control of documents are described in Section 1.0, ORGANIZATION.
6.2.2 Controls are established for approval, issue and change of documents in the following categories:
a.
Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes b.
As-built drawings (record drawings) and related documents c.
CPC-2 A.R17
Paga 25 Rev 17 Date: February 1,1997 4
d.
Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test and plant maintenance and operation which implement the Quality Program, Final Safety Analysis Report / Final Hazards Safcty Report e.
f.
Reports of nonconformances l'
g.
Plant Technical Specifications i
6.2.3 The review, approval, issue and change of the above documents are controlled by:
a.
Establishment of criteria to ensure that adequate technical and quality requirements are incorporated, b.
Identification of the organizations responsible for review, approval, issue and revision.
I c.
Review of changes to documents by the organizations designated in accordance with the procedure governing the review and approval of specific types of documents, including quality aspects.
]
I 6.2.4 Controlled documents are issued and distributed so that; a.
The documents are available at the work location prior to commencing work b.
Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner 6.2.5 Master lists or equivalent controls are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents. When master lists are used they are updated and distributed to designated personnel who are J
responsible for maintaining current copie0 of the lists.
6.2.6 Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.
CPC-2A.R17
Pigs 26 Rsv 17 Date: February 1,1997 l
7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for safety-related material, equipment and services are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement Cocument requirements is available to the nuclear power plant site prior te reliance on equipment, material or services for nuclear safety.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 7.1 2i 7.2.3 7b,17e 7.2.5 2m, 7e,17f 7.2.6 2m, 9b,13c,13d,17f 1
7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in Section 1.0, ORGANIZATION.
7.2.2 CPCo qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. To remain qualified, suppliers involved in active procurements are reevaluated annually and are audited triennially, if an audit is acquired from an external source, the audit is evaluated prior to its use.
Supplier evaluation and triennial audits are not necessary when the items or services suppaed are all of the following:
a.
Relatively simple and standard in design, manufacture and test, and b.
Adaptable to standard or automated ir.spections or tests of the end product to verify quality characteristics after delivery, and c.
Such that receiving inspectio' 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.
l These procedures provide the method of verifying (such as audit, surveillance or CPC-2A.R17
1 Pags 27 R3v 17 Date: February 1,1997 1
. inspection) and documenting that the characteristics or processes meet the requirements of the procurement document. For commercial "off-the shelf" items where the requirements for a specific quality assurance program appropriate for nuclear applications cannot be imposed in a practical manner, source verification is used to provide adequate assurance of acceptability unless the quality of the item can be adequately verified upon receipt.
7.2.4 Spare and replacement parts are procured in such a manner that their performance and quality are at least equivalent to those of the parts that will be replaced.
Specifications and codes referenced in procurement documents for spare or a.
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 enD neering evaluation performed by i
qualified individuals. The evaluation assures there is no adverse affect on interfaces, interchangeability, safety, fit, form, function, or compliance with applicable regulatory or code requirements. Evaluation results are documented.
d.
Any additional or modified design criteria, imposed after previous procurement of the item (s), are identified and incorporated.
7.2.5' Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with safety-related procurement requirements not previously verified by source surveillance or inspection and that required supplier furnished documentation is available. Items inspected are identified as to their acceptance status prior to their storage or release for installation.
7.2.6 Suppliers are required to furnish the following records:
a.
Applicable drawings and related engineering docurnentation that identify the purchased item and the specific procurement requirements (e.g., codes, standards, and specifications) met by the item.
b.
Documentation identifying any procurement requirements that have not been met.
c.
A description of those nonconformances from the procurement requirements dispositioned " accept as is" or " repair."
d.
Quality records as specified in the procurement requiremerts.
The acceptability of these documents is evaluated during source and/or receipt inspection, CPC-2A.R17 j
m
~
Pags 28 Rsv 17 l
Date: February 1,1997 l
l l
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, s
l l
CPC-2A.R17
Prga 29 REv17 Date: February 1,1997 1
8.0 IDENTIFILATION AND CONTROL OF ITEMS i, -
i
\\
l 8.1 POLICY 4
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, j
their storage areas or containers, or on records traceable to the items.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to
~
implementation of the requirements of this section of the QPD:
1 Paraaraoh Excentions/Interoretations I
8.2.2 7d,7g-8.2.3 7a 4
8.2 IMPLEMENTATION '
8.2.1 Controls are established that provide for the identification and control of materials 1
(including consumables), parts and components, (including partially fabricated i
assemblies). Responsibility for the identification and control of items is described in I
Section 1.0, ORGANIZATION.
8.2.2 Items are identified by physically marking the item, its storage area or its container or by l
maintaining records traceable to the item. The method of identification is such that the i
quality of the itern 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.
CPC-2A.R17
Page 30 Rsv 17 Date: February 1,1997 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 requirements.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD
)
Paraoraoh Exceotions/Interoretations 9.2.1 6c,13e 9.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at CPCo are those for which fuli 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 speci'ications.
9.2.6 Qualification records are maintained in accordance with Quality Program Description Section 17.
9.2.7 The Nuclear Assessment Department audits / assesses special process activities, including qualification activities to assure they are satisfactorily performed.
CPC-2A.R17
Pag's 31 Rav 17 Date: February 1,1997 10.0 INSPECTION 10.1 POLICY Activities affecting the quality of safety-related structures, systems, and components are inspected to verify their conformance with requirements. Inspections are accomplished by independent verification or process monitoring as necessary.
Verification points are used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraarsch Exceotions/Interoretations 10.2.2 2p,2q 10.2.3 2j, 6a 10.2.7 2j, 6a 10.2.10 2j 10.2 IMPLEMENTATION 10.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.
10,2.2 Inspections are applied to procurement, maintenance, modification, testing, fuel handling, and inservice inspection to verify that items and activities conform to specified requirements. Work authorizing documents (e.g.; procedures, instructions, maintenance work orders) are reviewed in accordance with established criteria to do the following as necessary:
a.
Determine the need for inspection (s),
b.
Identify the inspection organization or personnel.
c.
Identify independent verification points, d.
Determine how and when the inspections are to be performed, e.
Specify measuring and test equipment of the necessary accuracy for performing inspection.
f.
Provide for documentation of inspection results to provide adequate objective evidence of acceptability.
Independent verification is performed at each operation where it is necessary to verify conformance with requirements.
Process monitoring is used in whole or in part where direct inspection alone is impractical or inadequate.
CPC-2A.R17
Pags 32 R3v 17 Date: February 1,1997 10.2.3 Training and qualification programs for personnel who perform inspections, including nondestructive examination, are established, implemented, and documented in accordance with Section 2.0, QUALITY PROGRAM, and plant or offsite procedures.
These programs meet the requirements of applicable codes and standards. The Plant General Manager / Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility. For activities i
performed at Palisades that are under the cognizance of Nuclear Services, the Manager, j
Nuclear Projects and Construction is responsible for review and concurrence of such programs.
Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are documented in E&TS procedures.
Training and qualification programs for System Maintenance and Construction Services (SM&CS) personnel who perform inspections are documented in SM&CS procedures.
Qualifications and certifications of inspection and NDE personnel are maintained.
10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists and are either provided or concurred with by the organization that performs the inspection planning. They (procedures, etc) provide for the following as appropriate:
a.
Identification of applicable revisions of required instructions, drawings and specifications.
b.
Identification of characteristics and activities to be inspected, c.
Inspection methods (independent verification or process monitoring).
d.
Specification of measuring and test equipment having the necessary accuracy.
e.
Identification of ptersonnel responsible for performing the inspection.
f.
Acceptance and rejection criteria.
g.
Recording of the inspection results and the identification of the inspector.
10.2.5 Independent verification points are designated when confirmation is needed that critical characteristics are acceptable before the work can be allowed to proceed further.
Independent verifications are performed, and work is released for further processing or use, by assigned verification personnel, independent verification points may be waived only by the organization that performs the inspection planning.
10.2.6 Independent verifications are performed and documented in accordance with the written instructions provided. The results are evaluated by designated personnelin order to ensure that the results substantiate the acceptability of the item or work. Evaluation and review results are documented.
CPC-2A.R17
Pags 33 Rrv 17 Date: February 1,1997 i
a 1
Independent verification should be designated when the activity / task being verified is necessary to ensure critical characteristics are in conformance with requirements and/or the verification is result of codes, standards, regulations, or commitments.
3 j
10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:
1 a.
Qualifications of the independent verifier are equal to or better than the minimum i
qualifications for persons who can be authorized to perform the task; and i
4 b.
The work is within the skills of CPCo personnel and/or is addressed by CPCo procedures.
If work involves breaching a pressure retaining item, the quality of the work can be c.
demonstrated through a functional test.
When a, b, and c are not met, inspections will be carried out by individuals certified in accordance with ANSI N45.2.6.
]
The verification is performed by individuals other than the person (s) performing or i
directly supervising the work.
10.2.8 For independent verification, when acceptance criteria are not met, corrected areas are to be reverified. Results of independent verification are documented and retained for J
the purposes of performance trending and analysis.
10.2.9 The independent verifier has the authority to stop work if inspection criteria are not met. Resolution of disagreements between the verifier and worker is resolved by plant management.
I 10.2.10 Contractors may be used as independent verifiers in accordance with Section 10.2.7 provided:
a.
The work is performed using the CPCo Quality Program and procedures.
b.
Individuals are trained and qualified in accordance with Section 10.2.3.
Otherwise, contractors must be certified to ANSI N45.2.6 to perform inspections.
CPC-2A.R17
. - _ _ ~ _..
~...-
Pags 34 Rav17 Date: February 1,1997 11.0 TEST CONTROL 11.1 POLICY Testing is performed in accordance with established programs to demonstrate that
]
safety-related structures, systems, and components will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes 4
qualification (as applicable), acceptance, pre-operational, start-up, surveillance, and maintenance tests. Test parameters, including any crerequisites, instrumentation requirements and environmental conditions are specified and met. Test results ara docurnented and evaluated.
l J
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 11.2.2 2k,17g 11.2 IMPLEMENTATION 11.2.1 Organizational responsibilities for testing are described in Section 1.0, ORGANIZATION.
11.2.2 Tests are performed in accordance with programs, procedures, and criteria that designate when tests are required and how they are to be performed. Such testing includes the following:
a.
Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0, DESIGN CONTROL.
b.
Acceptance tests of equipment and components to assure their proper operation prior to delivery or to pre-operational tests.
c.
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.
CPC-2A.R17
... -.. -.. ~.. - -. -. - _. -. -.. - ~ -
. -. -.. ~ _... -.... - - ~...
- ~. - _
Paga 35 Rsv 17 -
Date: February 1,1997
(
i b.
Test prerequisites such as calibrated instrumentation, adequate test equipment, i
i I
and instrumentation including accuracy requirements, completeness of the item to be tested, suitable and controlled environmental conditions, and provisions for data collection'and storage.
j
}
c.
Instructions for performing the test.
i d.
Mandatory inspection hold points for witness by the appropriato authority, ei Acceptance and rejection criteria, f.
Methods of documenting or recording test data and results, g.
Assuring that test prerequisites have been met.
I h.
Verification of completion of modification activities.
Test procedures and instructions are reviewed for technical content and quality aspects, by the plant engineering organization, or the offsite technical organization, as applicable J
When acceptance criteria are not met, corrected areas are to be retested, i
r 4
s i
ii CPC-2A.R17
. _.-. ~ _ _.... _ -. _ -.-.~. -.. -. _.. -. - -. - -. ~. ~ - -
Paga 36 Rsv 17 Date: February 1,1997 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 POLICY Measuring and testing equipment used in activities affecting the quality of safety-relcted systems, components and structures are properly identified, controlled, calibrated, and j
adjusted at specified intervais to maintain accuracy within necessary limits.
l The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 12.2.3 2o, 9c 12.2.4 2o, 9c 12.2.5 10e l
12.2.8 10b t
12.2 IMPLEMENTATION i
12.2.1 The authority and responsibility of personnel establishing, implementing and assuring effectiveness of calibration programs is described in Section 1.0, ORGANIZATION.
12.2.2 Procedures are established for measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components.
These procedures describe calibration technique and frequency and maintenance and control of the equipment.
12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration sous Ce.
12.2.4 CPCo uses a system of labels to be attached to measuring and test equipment to display the next calibration due date, Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.
12.2.5 Measuring and test equipment (M&TE) and installed plant instrumentation is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.
Calibration of M&TE is against standards that have an accuracy of at least four times i
the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures t!ie equipment being calibrated will be within required tolerance and the basis of acceptance is documented and authorized by responsible management.
Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The t
basis for this acceptance is documented and is approved by responsible management, t
CPC-2A.R17 i
l i
I Paga 37 Rav 17 Date: February 1,1997 12.2.6 Calibrating standards have greater accuracy than standards being calibrated. Calibrating j
'i standards with the esme accuracy may be used if it can be shown to be adequate for the rcquirements and the basis of acceptance is documented and authorized by
)
i responsible management.
i 12.2.7 Reference and transfer standards are traceable to nationally recognized standards-where national standards do not exist, provisions are established to document the basis for calibration.
12.2.8 When measuring cnd testing equipment used for inspection and test is found to be outside of required accuracy limits at the time of calibration, evaluations are conducted
~
to determine the validity of the results obtained since the most recent calibration. The results of evaluations are documented. Retests or reinspections are performed on suspect items.
F CPC-2A.R17
Pigs 38 Rav 17 Date: February 1,1997 13.0 HANDLING, STORAGE AND SHIPPING 13.1 POLICY Activities with the potential for causing contamination or deterioration 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 controlled. These activities include cleaning, packaging, preserving, handling, shipping, and storing. Controls are effected through the use of appropriate procedur'es and instructions implemented by suitably trained personnel.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 4
13.2.2 7a, 7c, 7d, 7f, 7, 7h 9
13.2 IMPLEMENTATION 13.2.1 The authority and responsibility of personnelimplementing and assuring the j
effectiveness of material cleaning, handling, storing, pack-aging, preserving, and shipping activities is described in Section 1.0, ORGANIZATION.
13.2.2 Procedures are used to control the cleaning, handling, storing, pack-aging, preserving, j
and shipping of materials, components and systems in accordance with design and procurement requirements. These procedures include, but are not limited to, the 1
following functions:
a.
Cleaning, to assure that required cleanliness levels are achieved and maintained, b.
Packaging and preservation, to provide adequate protection against damage or deterioration. When necessary, these procedures provide for special environments such as inert gas atmospheres, specific moisture content levels, and temperature levels.
c.
Handling, to preclude damage or safety hazards.
d.
Storing, to minimize the possibility of loss, damage to or deterioration of items in storage, including consumables such as chemicals, reagents, and lubricants.
Storage procedures also provide methods to assure that specified shelf lives are not exceeded.
e CPC-2A.R17
_. - -. ~. - - - - - _ _. _. ~..
Pega 39 Rsv 17 Date: February 1,1997 14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 POLICY Operating status of safety-related structures, systems, and components is indicated by tagging of valves and switches, or by other specified means,in such a manner as to prevent inadvertent operation. The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Exceotions/Interoretations 14.1 2r 14.2.5 2i 14.2 IMPLEMENTATION 14.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.
14.2.2 For modification activities, including item f abrication, installation and test, procurement documents, service contracts, and procedures specify the degree of control required for the indication of inspection and test status of structures, systems, and components.
14.2.3 Application and removal of inspection and welding stamps and of such status indicators as tags, markings, labels, et :, are controlled by procedures.
14.2.4 The sequence of inspectio'is, tests and other operations important to safety are controlled by procedures Changes in the approved sequence are subject to the same review and approval as the original, or as specified in administrative procedures if the original organization no longer exists.
14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems, and components is clearly identified and documented to prevent inadvertent use.
CPC-2A.R17
m._
i 4
Psga 40 Rav 17 Date: February 1,1997 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS i
15.1 POLICY Safety-related materials, parts, or components that do not conform to requirements are controlled in order to prevent their inadvertent use. Nonconforming items are identified, documented, segregated when practical, and dispositioned. Affected organizations are notified of nonconformances s
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
1
+
]
Paraaraoh Excentions/Interoretations l
15.1 2i l
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 j-authorized to disposition, conditionally release, and close out nonconformances are i
designated. The authority and responsibility for the implementation of activities related to the processing and control of nonconforming materials, parts, or components are.
described in Section 1.0, ORGANIZATION, Nonconforming items are identified by marking, tagging, or segregating or by s.
documented administrative controls. Documentation describes the nonconformance, the disposition nf the nonconformance and the inspection requirements. It also includes signature approval of the disposition.
b.
The originalinspection planning authority reviews the disposition of nonconformances, and documents concurrence with the acceptance, conditional release or repair of a nonconforming item, c.
Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the original inspection planning authority, d.
Items that have the disposition of " repair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as built condition.
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.
CPC 2A.R17
Pigs 41 Rsv 17 Date: February 1,1997 15.2.4 Nonconformance reports are analyzed to identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management for review and assessment.
I l
l l
4 CPC-2A.R17
i l
Pags 42 Rsv 17 Date: February 1,1997 i
l 16.0 CORRECTIVE ACTION 16.1 POLICY l
Conditions adverse to quality of safety-related structures, systems, components, or activities, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconformances are identified promptly and corrected as soon as i
i practical.
.)
I' l
For significant conditions adverse to quality, the cause of the condition is determined l
and corrective action is taken to preclude repetition. In these cases, the condition, cause and corrective action taken is documented and reported to appropriate levels of management for review and assessment.
t 16.2 IMPLEMENTATION 16.2.1 The responsibility and authority for the control of corrective action are described in Section 1.0, ORGANIZATION.
l 16.5.2 Controls are established to assure that conditions adverse to quality are identified and documented and that appropriate remedial action is taken.
16.2.3 For significant conditions adverse to quality, necessary corrective action is promptly L
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.
CPC-2A.R17
~ _..
A a
Pags 43 Rav 17 Date: February 1,1997 17.0 QUALITY RECORDS 4
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.
1, The following exceptions / interpretations in Appendix A, Part 2, are relevant to
{
implementation of the requirements of this section of the OPD:
Paraoraoh Excentions/Interoretations 1,
i 17.1 14b 17.2.5 14c 17.2.8 14a,14c 3
i 17.2 IMPLEMENTATION 17.2.1 Responsibilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION, 17.2.2 Documents that furnish evidence of activities affecting quality are generated and controlled in accordance with the procedures that govern those activities. Upen completion, these documents are considered records. These records include:
a.
Results of reviews, inspections, surveillances, tests, audits, and mc';.tl 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 i.
Other documentation such as drawings, specifications, procurement documents, calibration procedures, and reports 17.2.3 Inspection and test records contain the following where applicable:
e.
A description of the type of observation CPC 2A.R17 s
._.m Paga 44 Rev 17 Date: February 1,1997 b.
The date and results of the hspection or test Information related to conditions adverse to quality c.
d.
Inspector or data recorder identification e.
Evidence as to the acceptability of the results f.
Action taken to resolve any discrepancies noted 17.2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times.
Permanent records are maintained for the life of the item. Appendix E identifies retention periods for certain specific records.
17.2.5 Temporary storage of completed documents during processing to become records is in
.special fire-resistant file cabinets.
17.2.6 Only authorized personnel may issue corrections or supplements to records.
17.2.7 Traceability between the record and the item or activity to which it applies is provided.
.2.8 Records are stored in remote, dual f acilities 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.
CPC-2A.R17
Pags 45 Rav17 4
Date: February 1,1997 18.0 AUDITS 18.1 POLICY A comprehensive system of audits is carried out to provide independent assessment of performance and effectiveness of the Quality Program to achieve nuclear safety, including those elements of the program implemented by suppliers and contractors.
Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are
]'
documented and are reviewed by management. Follow up action is taken where indicated.
2 I
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
l Paraaraoh Exceotions/Interoretations 18.2.2 3a,3b,16a,16b 18.2.3 16c 18.2.9 2e 18.2 IMPLEMENTATION 18.2.1 Responsibility and authority for the audit program is described in Section 1.0, ORGANIZATION.
18.2.2 Internal audits are performed in accordance with established schedules that reflect the status and importance to safety of the activities being performed. Audits are conducted in accordance with frequencies stated in Appendix D, Audit Frequencies.
-18.2.3 Audits of suppliers and contractors are scheduled based on the status and safety importance of the activities being performed as well as performance of the suppliers and contractors and are initiated early enough to assure effective quality during design, procurement, manuf acturing, construction, installation, inspection, and testing.
18.2.4 Principal contractors are required to audit their suppliers based on performance and on a schedule based on the status and safety importance of the activities being performed.
Such audits shall be initiated early enough to assure an effective Quality Program on the part of their suppliers.
18.2.5 Regularly scheduled au ots are supplemented by special audits when significant changes are made in the Quality Program, when it is suspected that quality is in jeopardy or when an independent assessment of program effectiveness is considered necessary.
18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities and items, and review of documents and records to confirm that the Quality Program is effective and properly implemented.
18.2.7 Audit procedures and the scope, plans, checklists, and results of individual audits are documented.
CPC 2A.R17
Paga 46 Rav17 3
Date: February 1,1997 18.2.8 Personnel selected for auditing assignments have experience or are given training commensurate with the needs of the audit and have no direct responsibilities in the areas audited.
18.2.9 Audit data are analyzed by the Nuclear Performance Assessment Department. The resulting audit reports identify any quality deficiencies and assess the effectiveness of the Quality Program in the area audited. The reports are distributed to the responsible management of both the audited and auditing organizations.
18.2.10 Management of the audited organization identifies and takes appropriate corrective action to correct observed deficiencies and to prevent recurrence of any significant conditions adverse to quality. Follow-up for internal audits is performed by the Nuclear Performance Assessment Department to ensure that appropriate corrective action is-taken and is effective. Such follow-up includes re-audits when necessary. For Vendor Audits, such follow-up shall be performed by the organization performing the audit.
CPC-2A.R17 I
i I
Paga 47 Rev 17 Date: February 1,1997 l
QPD MANUAL APPENDIX A. PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Power Company Quality Program complies with the regulatory position of the
. Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2.
1.
Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
2.
10 CFR, Part 50.55a - Codes and Standards.
3.
Regulatory Guide 1.8 - (9/80 Draf t) - Personnel Qualification and Training - Endorses ANSI /ANS 3.1 - (12/79 Draf t).
4.-
Regulatory Guide 1.26 - (2/76, Rev 3) - Quality Group Classification, and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants.
5.
Regulatory Guide 1.29 - (9/78, Rev. 3) - Seismic Design Classification.
6.
Regulatory Guide 1.30 (Safety Guide 30) - (8/11/72) - Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment -
Endorses ANSI N45.2.4 - 1972.
7.
Regulatory Guide 1.33 - (2/78, Rev 2) - Quality Assurance Program Requirements (Operation) - Endorses ANSI N18.7 - 1976.
l 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
)
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 forWater-Cuoted Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.
11.
Regulatory Guide 1.58-(9/80, Rev i) - Qualification of Nuclear Power Plant inspection, Examination, and Testing Personnel-Endorses N45.2.61978.
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.
CPC-2A.R17
Pigs 48 Riv 17 Date: February 1,1997 14.
Regulatory Guide 1.88 - (10/76, Rev 2) - Coilection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - Endorses N45.2.9 - 1974.
15.
Regulatory Guide 1.94 - (4/76, Rev 1) - Quality Assurance Requirements for Installation, inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -Endorses ANSI N45.2.5 - 1974.
16.
Regulatory Guide 1.116 -(5/77)- Quality Assurance Requirements for Installation, inspection, and Testing of Mechanical Equipment and Systems - Endorses ANSI N45.2.8 -
1975Property "ANSI code" (as page type) with input value "ANSI N45.2.8 -</br></br>1975" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
17.
Regulatory Guide 1.123 - (7/77, Rev 1) - Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants - Endorses N45.2.13 - 1976.
18.
Regulatory Guide 1.144 -(9/80, Rev I) - Auditing of Quality Assurance Programs for Nuclear Power Plants Endorses N45.2.12 - 1977, 19.
Regulatory Guide 1.146 - (8/80) - Qualification of Quality Assurance program Audit Personnel for Nuclear Power Plants - Endorses N45.2.23 -1978.
20.
Branch Technical Position ASB9.5.1 (Rev 1) Guidelines for Fire Protection for Nuclear Power Plants.
21.
10 CFR 50, Appendix R Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979, Sections ill G., lil J. and lli O.
22.
ANSI /ANS 3.1-1987, Selection, Qualification, and Training of Personnel for Nuclear Power Plants application limited as described in Apt,endix C of this document).
CPC-2A.R17
Paga 49 Rsv 17 Date: February 1,1997 QPD MANUAL APPENDIX A. PART 2 CPCO EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES 1
1.
General Reauirement i
Certain Regulatory Guides invoke or imply Regulatory Guides and standards in addition to the standard each primarily endorses.
Certain ANSI Standards invoke or imply additional standards.
Exceotion/Interoretation The CPCo commitment refers to the Regulatory Guides and ANSI Standards specifically identified in Appendix A, Part 1. Additional Regulatory Guides, ANSI Standards, and similar documents implied or referenced in those specifically identified are not part of this commitment.
i imposition of these Regulatory Guides on CPCo suppliers and subtier suppliers will be on a case by-case basis depending upon the item or service to be procured.
2.
N18.7 General Exceotion/interoretation Consumers Power Company has established an organizational unit, Nuclear Performance Assessment Department, for independent review activities.
The standard numeric and qualification requirements may not be met by the Nuclear Performance Assessment Department staff. Procedures will be established to specify how NPAD will acquire necessary expertise to carry out its review responsibilities in accordance with Appendix C, independent Safety Review.
2a.
HILZ, Sec 3.4.2 Reauirement "The Plant Manager shall have overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."
CPC 2A.R17
P gs 50 Rtv 17 Date: February 1,1997 Exceotion/Interoretation Since CPCo has more than one nuclear unit and more than one organization providing services to these units, overall responsibility cannot be centralized in a single on site position. Instead, responsibilities are as designated within the Quality Program Description.
2b.
N18.7, Sec 4.3.1 Reouirement
" Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines and shall collectively have the experience and competence required to review problems in the following areas:..."
Exceotion/interoretation The Nuclear Performance Assessment 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 Performance Assessment Department win function as described in Appendix C, Independent Safety Review, and will acquire the services of personnel having such experience and competence as necessary.
2c.
N18.7. Sec 4.3.4 Reauirement "The following subjects shall be reviewed by the independent review body:"
Exceotion/Interoretation Subjects requiring review will be as specified in Appendix C, independent Safety Review.
2d.
N18.7. Sec 4.3.4(3)
Recuirement 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.
Exceotion/interoretation The Nuclear Performance Assessment Department will not review Technical Specification Changes after NRC approval prior to implementation. The basis for this position is that all Technical Specification changes are reviewed prior to submittal to the NRC.
CPC-2A.R17
.-.__m
..m_..._
Paga 51 Rev 17 Date: February 1,1997 t
2e.
N18.7, Sec 4.5 i
Reauirement Written reports of audits specified in ANSI N18.7 shall be reviewed by the.:ndependent l
review body and by appropriate members of Management including those having responsibility in the area audited.
Excention/Interoretation l
The Nuclear Performance Assessment Department'shall review or arrange for reviews of those audits over which it has cognizance, in accordance with Appendix C, Independent Safety Review.
l l
Some of the 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.
2f.
N18.7, Sec 4.5 l
Reauirement l
Periodic review of the audit program shall be performed by the independent review body or i
by a management representative at least semiannually to assure that audits are being accomplished in accordance with requirements of technical specifications and of this standard.
l Excention/Interoretation Audits of operational nuclear safety related facility activities are performed under the cognizance of the Nuclear Performance Assessment Department as described in Appendix C, Independent Safety Review.
2g.
N18.7. Sec 5.2.1 1
i Reauirement "The responsibilities and authorities of the plant operating personnel shall be delineated."
i Exceotion/Interoretation 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, t
(
l CPC 2A.R17
1 m
m_.
Paga 52 Rav17 4
Date: February 1,1997 i
2h.
bl18.7. Sec 5.2.2 Reauiremq11
" 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 knowled eable in the 0
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."
4 Excention/interoretation CPCo considers that this requirement applies only to procedures identified in Plant Technical -
l Specifications and to Security and Emergency Plans implementing procedures. Temporary j
changes to these procedures may be made provided:
l a.
The intent of the original procedure is not altered; 1
b.
The change is approved by two members (or designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator License; and 4
The change is documented, subsequently reviewed by the PRC within 30 days of c.
issuance and approved by:
4 1.
Appropriate
- senior Palisades department manager predesignated by the Plant General Manager; or 2
2.
The Big Rack Point Plant Manager.
Determinstion of the appropriate senior Palisades department manager is based on the i
activities addressed in the specific procedure, and will be predesignated in writing by the Pa'asades Plant General Manager.
21.
N18.7 Sec 5.2.6 4
Reauirement d
2 "In cases where required documentary evidence is not available, the associtited equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until l
suitable documentary evidence is available to show the equipment or material is in j
conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions."
Exceotion/Interoretation CPCo initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which is required to verify equipment i
acceptability. This action includes a technical evaluation of the equipment's operability status.
5 l
CPC 2A.R17 i
i Pags 53 Rev 17 Date: February 1,1997 j
2j.
N18.7, Sec 5.2.7 Reauirement The following standards contain useful guidance concerning design and construction-related activities associated with modifications and shall be applied to those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during initial plant design and construction: American National Standard Installation, inspection and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power Generation Station, N45.2.4-1972 (IEEE 336-1972) [6);
American National Standard Supplementary Quality Assurance Requirements for Installation, inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, N45.2.5-1974 [7); American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973 [5); American National Standard Supplementary Quality Assurance Requirements for installation, inspection and Testing of Mechanical Equipment and Systems for Construction Phase of Nuclear Power Plants, N45.2.8-1975 [8);
American National Standard Quality Assurance Requirements for the Design of Nuclear Power Plants, N45.2.11 1974 [9); and American National Standard Quality Assurance for Protectiva Coating Applied to Nuclear Facilities N101.41972 [10]. Considerable care is required in assessing which operational phase activities are comparable in nature and extent i
to activities normally associated with design and construction.
Exceotion/ Clarification Work that is within the skills of CPCo personnel and is covered by CPCo procedures may be j
inspected by independent verifiers in accordance with Section 10.2.3 and 10.2.7 and 10.2.10, rather than ANSI N45.2.6.
2k.
N18.7, Sec 5.2.8 Reauirement "A surveillance testing and inspection program...shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections."
Exceotion/interoretation Separate master schedules may exist for different programs such as ISI, Pump and Valve Testing, and Technical Specification Surveillance Testing.
CPC 2A.R17
Psg3 54 Rev 17 Date: February 1,1997 21.
N18.7. Sec 5.2.13.1 Reauirement "To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 -
1971Property "ANSI code" (as page type) with input value "ANSI N45.2 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.."
Excention/Interoretation To the extent necessary, procurement documents require that the supplier have a l
documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.
2m.
N18.7. Sec 5.2.13.2 Reouirement ANSI NI8.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.
Exceotion/Interoretation The required documentary evidence is available at the site prior to use, but not necessarily prior to installation. This allows installation to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
2n.
N18.7, Sec 5.2.15 Reauirement Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable.
Exceotion/Inten etation Consumers Power has in place programmatic procedure preparation, review and usage controls that ensure procedures are technically and administrative!y correct and make a biennial review program unnecessarily duplicative. These controls ensure that procedures are reviewed when pertinent source materialis revised (such as when Technical Specifications are revised), when unusual incidents occur, when plant modifications are made, and when significent deficiencies are identified. In addition, procedures may be reviewed because industry experience reviews or self-assessments identify deficiencies or opportunity for improvement. Revisions are made as necessary.
Because of their critical nature, non-routine procedures, such as Emergency Operating Procedures, Off-Normal Procedures, Special Operating Procedures, Special Test Procedures, Fuel Handling Procedures, Emergency Plan implementing Procedures, and others where use CPC-2A.R17
-. - ~... --. ~ _ _
~ - -. -
Pags 55 Rev 17 Date: February 1,1997 i
l would be dictated by a particular event are reviewed at least every two years and revised as appropriate, l
in addition, procedures that have not been used or reviewed for two years are reviewed l
prior to use to determine if changes are necessary or desirable.
j An assessment performetd at least every two years includes examination of selected plant procedures to determine procedure acceptability and verify that the procedure review and revision controls are effectively implemented. Identified deficiencies are corrected in accordance with Section 16.0 of this QPD.
l 20.
N18.7. Sec 5.2.16 Reauirement Records shall be made and equipment suitably marked to indicate calibration status.
Exceotion/Interoretation See item 9c.
2p.
N18.7. Sec 5.2.17 Reauirement For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities (see also Section 5.2.7)
Exceotion/Interoretation Maintenance and modification activities which are within the skills of CPCo maintenance personnel and is carried out using CPCo procedures may be inspected by independent verifiers in accordance with Sections 10.2.3,10.2.7, and 10.2.10 of this program description.
2q.
N18.7. Sec 5.2.17 Reauirement If mandatory inspection hold points are required, the specific hold points shall be indicated in appropriate documents. Information concerning inspection shall be obtained from the related design drawings, specifications, and/or other controlled documents.
Excention/Interoretation j
CPCo uses the terminology " independent verification points" as equivalent to hold points.
r I
l CPC 2A.R17
i i
Paga 56 Rev 17 Date: February 1,1997 2r.
N18.7. Sec 5.3.5(3)
Reauirement 4
i instructions shall be included, or referenced (in maintenance procedures), for returning the equipment to its normal operating status, s
a Exceotion/lnteroretation At CPCo, equipment is returned to its normal operating status, i.e., declared Werable, by licensed Operations Department personnel, not Maintenance personnel. Ope stions personnel verify and document equipment operability through second level lir e-up verification or appropriate functional testing.
i 2s.
N18.7, Sec 5.3.5(4) a Reauireme 31 This section requires that where sections of documents such as vendor manuals, operating and maintenance instructions, or drawings are incorporated directly or by reference into a maintenance procedure, they shall receive the same level of review and approval as operating procedures.
Exceotion/Interoretation i
Such documents are reviewed by appropriately qualified personnel prior to use to ensure 3
j that, when used as instructions, they provide proper and adequate information to ensure the required quality of work. Maintenance procedures which reference these documents j
receive the same level of review and approval as operating procedures.
3a.
RG l.33. Sec C4a i,
Reauirement 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.
Exceotion/Interoretation Performance trends are reviewed by the Nuclear Performance Assessment Specialists. In addition, the corrective action system is audited in accordance with Appendix D, Audit
]
Frequencies.
k i
2 I
CPC-2A.R17 4
l Pago 57 Rc;v 17 Date: February 1,1997 4
. 3b.
RG 1.33. Sec C4b i
Reauirement l
The conformance of facility operations to provisions contained within the Technical Specifications and applicable license conditions-at least once per 12 months, f
Excention/Interoretation Consistent with guidance presented in NRC letters dated March 29,1983 (RLSpessard to 4
JMTaylor) and January 30,1984 (JGPartlow to RLSpessard), Consumers Power Company interprets the commitment to audit Technical Specification / license conditions contained in 18.2.2 of this QPD, and in Appendix D, Audit Frequencies, as follows:
Consumers Power Company maintains a matrix that identifies all applicable Technical Specification line items to be audited. The matrix is updated annually to conform to approved Technical Specification changes. During each 12 month period, a selected sample of line items, with the exception of the onsite and offsite review committee which are audited every 24 months, is audited:
1.
Limiting Conditions for Operation 2.
Limiting Safety System Settings 3.
Reactivity Control Systems 4.
Power Distribution Limits 5.
Instrumentation 6.
Emergency Core Cooling System 8.
Containment Systems 9.
Plant Systems 10.
Electrical Power Systems 11.
Refueling Operations 12.
Special Tests 13.
Onsite Committee 14.
Offsite Committee 15.
Administrative Controls Audits are scheduled so that allline items are covered within a maximum period of 5 years.
The audit period for any of the above elements may be reduced depending on Technical Specification compliance history.
4a.
ANS 3.1. General Exceotion/Interoretation The commitment to ANS 3.1 (12/79, draft) is limited to the requirements that apply to the training and qualification of persons performing independent quality assurance functions, except for Lead Auditors. Lead auditors are trained and qualified to Regulatory Guide 1.146 (8/801/ ANSI 45.2.231978. Other personnel are trained and qualified as designated in plant Technical Specifications.
CPC-2A.R17
)
f a,.--
Pags 58 Rav17 Date: February 1,1997 i
5a.
RG l.8, C.3.1, General Exceotion/fnteroretation The commitment to Regulatory Guide 1.8 (9/80, draft) is limited to the requirements that apply to the training and qualificatoin of persons performing independent quality assurance functions, except for Lead Auditors. Lead Auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.
Sb.
RG 1.8, Cl.2.2 Reauirement "When an individual is hired to temporarily function as a plant employee, such as for contracted services, evidence of previous educatio"., experience, and training should be provided and reviewed by the appropriate professional-technical group leaders. The appropriate group leaders should then determine the content for that individual's training, including plant-specific training. As a minimum, each individual should receive General Employee Training."
Excention/Interoretation CPCo understands that this requirement applies both to CPCo employees from another site and to contract personnel who are temporarily assigned to a nuclear power plant either as replacements for regular employees or to augment the staff during outages. CPCo employees so assigned possess the required qualifications as a prerequisite to the assignment and the review is waived. The qualifications of contract personnel are reviewed and arrangements made for any recessary training. Temporarily assigned personnel requiring unescorted access receive the site general orientation as embodied in General Employee Training.
6a.
N45.2.1. Sec 2.4 Reauirement Those personnel who perform inspection, examination, or testing activities required by this standard shall be qualified in accordance with ANSI N45.2.6 Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants.
Exceotion/Interoretation CPCo certifies its inspectors in 1ccordance with Paragraph 10.2.7 of CPC-2A unless the work is comparable in nature and extent to original construction (See item 2j).
CPC-2A.R17
~
Pags 59 Rev 17 Date: February 1,1997 6b.
N45.2.1. Sec 3.1 Raouirement i
N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items be so classified.
Exceotion/Interoretation instead ' f using the cleanness level classification system of N45.2.1, the required cleanness o
for specific items and activities is addressed on a case-by-case basis.
Cleanness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material. As a minimum, cleanness inspections are performed prior to system closure. Such inspections are documented.
6c.
N45.2.1. Sec 5
_l Reauirement
" Fitted and tack welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed."
Excention/Interoretation CPCo sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection.
7a.
N45.2.2, Ge neral Reauirement N45.2.2 establishes requirements and criteria for classifying safety-related items into protection levels.
Exceotion/Interoretation Instead of classifying safety-related items into protection levels, controls over the packaging, shipping, handling, and storage of such items are established on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.
I CPC-2A.R17 -
l 1
~.
Pcgs 60 Rsv 17 Date: February 1,1997 l 7b.
N45.2.2. Sec 2.4 Reauirement
"...Offsite inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N45.2.6."
Exceotion/Interoretation l
Offsite inspection, examination, or testing activities are audited or inspected by persons qualified and certified in accordance with ANSI N45.2.231978, as endorsed by Reg Guide 1.146, or by personnel meeting the requirements of 10.2.7, respectively. Monitoring activities not involving audit or inspection may be conducted by persons trained and qualified to effectively carry out such tasks, but not necessarily certified to either ANSI N45.2.23, N45.2.6 or Paragraph 10.2.7.
l 7c.
N45.2.2. Sec 3.4.1 and Appendix A, 3.4.1(4) and (5)
Reouirement
"(4)...However, preservatives for inaccessible inside surfaces containing reactor coolant water shall be indicated to f acilitate touch up.
(5) The name of the preservative used shall be the water flushable type."
Exceotion/Interoretation i
Based on comparison of these statements to ANSI /ASME NOA-21983, CPCo believes the intent was to establish the following as requirements:
"(4)...However, preservatives for inaccessible inside surfaces of pumps, valves, and pipe for systems containing reactor coolant water shall be the water flushable type.
(5) The name of the preservative used shall be provided to facilitate touch-up."
l 7d.
N45.2.2, Sec 3.9 and Appendix A 3.9 Reouirement "The item and the outside of containers shall be marked."
(Further criteria for marking and tagging are given in the appendix.)
Excention/Interoretation 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 CPC-2A.R17
Pagn 61 Rav 17 j
Date: February 1,1997 i
requirements are implemented to the extent necessary to assure traceability and integrity of 1
the item.
7e.
N45.2.2. Sec 5.2.2 l
Reauirement "The inspections shall be performed in an area equivalent to the level of storage."
]
Excention/Interoretation Receiving inspection area environmental controls may be less stringent than storage i
environmental requirements for an item. However, such inspections are performed in a manner and in an environment which do not endanger the required quality of the item.
7f.
N45.2.2, Sec 6.2.4 l
Reauirement "The use or storago of food, drinks, and salt tablet dispensers in any storage area shall not be permitted."
Exceotionlinteroretation Packaged food for emergency or extended overtime use may be stored in material stock i
rooms. The packaging assures that materials are not contaminated. Food will not be "used" in these areas.
7g.
N45.2.2. Sec 6.3.4 l
Reouirement "Allitems and their cuntainers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."
Exceotion/Interoretation See N45.2.2, Section 3.9 (Exception 7d.).
7h-.
N46.2.2. Sec 6.4.1 l
Reauirement v
" Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its container...is being maintained."
CPC-2A.R17
Pigs 62 Rav 17 Date: February 1,1997 l
Exceotion/Interoretation The requirement implies that allinspections and examinations of items in storage are to be performed on the same schedule. Instead, the inspections and examinations are performed and documented in accordance with material storage procedures which identify the characteristics to be inspected and include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.
8a.
N45.2.3. Sec 2.1 Reauirement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.
Exceotion/Interoretation Instead of the five-level zone designation system referenced in ANSI N45.2.3, CPCo bases its controls over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modifications work, are developed on a case by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard Janitorial and work practices to the extent possible. However, in preparing these procedures, j
consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3.
j i
9a.
N45.2.4. Sec 2.2
{
Reauirement 1
l Section 2.2 establishes prerequisites which must be met before the installation, inspection, i
and testing of instrumentathn and electrical equipment may proceed. These prerequisites i
include personnel qualification, control of design, conforming and protected materials, and I
availability of specified documents.
Exceotion/interoretation l
i During the operations phase, this requirement is considered to be applicable to modifications and initial start-up of electrical equipment. For routine or periodic inspection and testing, the prerequisite conditions will be achieved as necessary.
l 9b.
N45.2.4. Sec 2.2(5)
Reauirement Section 2.2(5) of ANSI N45.2.4 lists documents which are to be available at the construction site.
CPC-2A.R17
Pagn 63 Rav 17 Date: February 1,1997 I
4 i
Excention/Cicrification 2
All of the documents listed are not necessarily required at the plant site for installation and testing. CPCo assures that they are available to the site as necessary.
9c.
N45.2.4. Sec 6.2.1 l
Reauirement
" Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed the calibration."
Exceotion/Interoretation Frequently, physical size, and/or location of Installed Plant Instrumentation (IPI) mandates that calibration labels or tags not be affixed to IPl. Instead, each instrument is uniquely identified and is traceable to its calibration record.
A scheduled calibration program assures that each instrument's calibration is current.
10a, N45.2.5. Sec 2.4 Reauirement
" Persons charged with engineering managerial responsibility of the inspection and testing organization at the site in either a resident or non-resident capacity shall be certified for level 111 capability."
Exceotion/Interoretation This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activity in the areas of concrete and structural steel which do not generally occur at an operating plant. At Consumers Power, persons having engineering managerial responsibility for inspections and tests' may be certified to Level lit, or may meet other qualification criteria established for the position, including, but not hmited to, nuclear power and management experience. For major modifications involving significant concrete or structural steel work, the services of a properly qualified Level lil individual will be obtained in at least an advisory capacity.
within the scope of N45.2.5 10b. N45.2.5. Sec 2.5.2 Reauirement "When discrepancies, malfunctions, or inaccuracies in inspection and testing equipment are found during calibration, allitems 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."
CPC 2A.R17
Pags 64 Rav 17 Date: February 1,1997 4
Exceotion/Iriteroretation CPCo uses the requirements of NI8.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2.
The NI8.7 requirements are more applicable to an operating plant.
l l
l 10c. N45.2.5, Sec 5.4 Reauirement
" Hand torque wrenches used for inspection shall be controlled and must be calibrated at i
least weekly and more often if deemed necessary, impact torque wrenches used for inspection must be calibrated at least twice daily."
1
]
Exceotion/Interoretation t
Torque wrenches are controlled as measuring and test equipment in accordance with ANSI NI8.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 l
11a. tL43 2.6. Sec l.2 j
Reauirement j
"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 sit 9, during construction, during preoperational and start up testing, and during operational phases nf nuclear power plants."
Exceotion/Interoretation See Exception / Interpretation 2] for those inspectors who must be certified to this standard.
Others are qualified to Paragraph 10.2.7 of CPC 2A.
Qualification of plant personnel who are involved with testing associated with plant operation is provided in specific plant specifications. In addition, personnel participating in inspection or testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 but need only be trained to the extent necessary to perform the assigned function.
12a. RG 1.58. Sec C.l Recu;rement "However, for qualification of personnel (I) who approve preoperational, start-up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start-up and operational tests, the guidelines contained in Regulatory Guide 1.8, Personnel Selection and Training, should be followed in lieu of the Guidelines of ANSI N45.2.6 1978."
CPC-2A.R17
Page 65 Rav 17 Date: February 1,1997 Exceotion/interoretation CPCo endorses i.his position, as also stated in lla, above, except that offtite support organizations involved in testing rnay apply ANSI N45.2.6. Some of these departments have already developed their qualification programs based on ANSI N45.2.6, and provide services throughout the operations phase of CPCo Nuclear Plants.
12b. RG 1.58. Sec C.5 l
Reauirement
'In addition, the individual should be capaFe of reviewing and approving inspection, examination end testing procedur*u md of evaluating the adequacy of such procedures to accomplish the inspection, exar n and test objectives."
Exceotion/Interoretation While a Level 111 individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives, this is not construed by CPCo as requiring personnel who review, approve or evaluate such procedures to be certified as l
Level 111 personnel.
12c. RG 1.58. Sec C.6 l
I Reauirement "Since only one set of recommendations is provided for tha education and experience of personnel, a commitment to comply with the regulatory positior4 of this guide in lieu of providing an alternative to the recommendations of the standarJ means that the specified education and experience recommendations of the standard will be followed."
Exceotion/Interoretation The education and experience reenrnmendations 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 equ; valent for the above reasor.s.
12.d RG 1.58, Sec C.10 l
Reauirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experienes should result in documented evidence (i.e., procedure and record of written testi demonstrating that the individual indeed does have comparable or equivalent corapetence to that wh!ch would be gained from having the required education and experience."
CPC-2A.R17
Page 66 Rev 17 Date: February 1,1997 Exceotion/Interoretation We will maintain documented objective evidence that demonstrates that an individual does have " comparable" or " equivalent" competence to that which would be gained ' rom having the required education and experience. However, this may take the form of doc umentation other than " procedures and records of written test" such as documentation of oral tests and on the-job performance demonstrations.
13a. N45.2.8, Sec 2.7 j
Recuirement 1
Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6.
Excention/interoretation See Exception / Interpretation 2),11a, and 12a. Test personnel who are part of the plant staff need not be certified to N45.2.6, provided they meet applicable qualification critoria of plant Technical Specifications.
l 13b. N45.24, Sec 2.9 Recuirement Section 2.9 establishes prerequisites which must be met before the installt. tion, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel i
and procedure qualification, control of design, material selection and fabrication, and availability of specified documents.
Exceotion/interoretation During the operations phase, this requirement is considered to be applicable to modifications of mechanical equipment. For routine or periodic inspection and testing, the prerequisites will be achieved as necessary.
l 13c. N45.2.8. Sec 2.98 BCQpirement 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.
Exceotion!!nteroretation All of the documents listed are not necessarily required pa the plant site for installation and testing. CPCo assures that they are available 12 the site as necessary.
CPC-2A.R17
Page 67 Rev 17 Date: February 1,1997 13d. N45.2.8. Sec 2.9e l
Recuirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.
Exceotion/Interoretation Equipment may be installed before final approval of engineering or design changes.
However, the system is not declared operable until such changes are documented and approved.
13e. N45.2.8. Sec 4.5.1 l
Recuirement
" Installed systems and components shall be cleaned, flushed, and conditioned according to j
the requirements of ANSI N45.2.1 Special attention shall be given to the following requirements:...." (Requirements are given for chemical conditioning, flushing and process controls.)
Exceotion/Interoretation Systems and components are cleaned, flushed and conditioned as determined on a case by-case basis. Measures are taken to help preclude the need for cleaning, flushing, and
]
conditioning through good practices during maintenance or modification activities.
14a.
N45.2.9. Sec 5.4, Item 2 1
Recuiremen_t Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel cabinets are preferred.
Egeotion/lnteroretation Records are suitably stored in steel file cabinets or on shelving in containers. Methods other than binders, folders or envelopes (for example, dividers or electronic media) may be used to organize the records for storage.
14b.
N45.2.9. Sec 6.2 l
Reouirement "A list shall be maintained designating those personnel who shall have access to the files."
CPC-2A.R17
Prgs 68 Rev 17 Date: February 1,1997 Exceotion/Interoretation 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 Reauirement "Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.91974. 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...."
Exceotion/interoretation CPCo adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Class 1 records (usually NFPA Class C,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Class 350),
15a. RG l.64. C2 Reauirement "Regardless of their title, individuals performing design verification should not (l) have immediate supervisory responsibility for the individual performing the design.. "
i Exceotion/Interoretation CPCo follows the requirements of ANSI N45.2.11-1974, Section G.1, and the guidance of j
Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9, herein). This approtsch is necessary to allow small organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks.
16a. RG 1.144. Sec C3a(l)
Reauirement This section requires that for operational phase activities, RG l.33 " Quality Assurance Program Requirements (Operations)" are to be followed. One of the RG l.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and CPC 2A.R17
Pzga 69 Rev 17 Date: February 1,1997 occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six months.
Excention/interoretation See item 3a for the exception to this requirement.
16b. RG 1.144. Sec C3a(2) l Raouirement 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.
Excention/interoretation Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.
16c. RG 1.144. Sec C3b(I) l l
Raouirement This section identifies procurement contracts which are exempted from being audited.
Exceotion/Interoretation In addition to the exemptions of RG 1.144, CPCo considers that Authorized inspection Agencies, NationalInstitute of Standards and Technology or other State and Federal Agencies which may provide services to CPCo are not required to be audited.
e 17a. N45.2.13. Sec 3.2.2 Reauirement N45.2.13 requires that technical requirements be specified in procurement documents bv reference to technical requirement documents. Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.11.
Exceotion/Interoretation For replacement parts and materials", CPCo follows ANSI N18.7, Section 5.2.13, Subitem I, which :.tates: "Where the originalitem or part is found to be commercially 'off the shelf' or without specifically identified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance."
CPC 2A.R17
I Page 70 Rev 17 l
Date: February 1,1997
{
i l ' 17b.
N45.2.13. Sec 3.2.3 Reauirement
" Procurement documents shall require that the supplier have a documented quality assurance program that implements portions all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards."
Exceotion/interotetation Refer to item 21.
l 17c. N45.2.13, Sec 3.3(a)
Reauirement l
l Reviews of procurement documents shall be performed prior to release for bid and contract
- award, i
Excention/Interoretation Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is put into l
service or before wod has progressed beyond the point where it would be impractical to reverse the action taken.
i i
l 17d. N45.2.13, Sec 3.3(b)
Raouirement
" 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."
Excention/interoretation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems I thiough 5.) The timing of reviews will be the same as for review of the original procurement document.
l 17e. N45.2.13. Sec 7.5 Reauirement
" Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as applicable."
f CPC-2A.R17
Page 71 Rev 17 Drte: February 1.1997 Exceotion/Interoretation Consumers Power qualifies audit personnel according to N45.2.23. Thus, personnel performing source verification audits may not be certified according to N45.2.6. Personnel performing inspection as part of source verification will be certified to N45.2.6 or qualified in allowance with Paragraph 10.2.7. However, personnel performing source surveillances may not be certified to any of those requirements.
17f.
N45.2.13. Sec 10.1 l
Egguirement "Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods."
Exceotion/Intercretation i
Refer to item 2m.
17g. N45.2.13. Sec 10.3.4 (as modified by RG 1.123, C6e)
[
l Reauirement
" Post-installation test requirements and acceptance documentation shall be mutually estabhshed by the purchaser and supplier."
j Exceotion/Interoretation in e>ercising its ultimate responsibility for its quality program, CPCo establishes post-installation test requirements, giving due consideration to supplier recommendations.
18a. RG 1.26, General Reauirement RG l.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are not.)
Exceotion/Interoretation RG l.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety-related determinations. Regulatory Guide 1.29, subject to Exception / Interpretation 20a, is used to determine what systems and equipment included in the Quality Program.
CPC-2A.R17
. -. ~
---~_.
i Pags 72
.Rev 17 a
Date: February 1,1997 i
19a. Branch Technical Position AS89.5.1 and 10 CFR SO Anoendix R.
Sections ill G. lil J.. and ll1 O.. General Exceotion/interorstation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 Appendix R except for the specific exemptions approved by the NRC.
2 20a. RG 1.29. Sec' C, Regulatcry Position Reauirement i
The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category I and should be designed to withs'tand the SSE.
Excection/Interoretation 1
i Both CPCo nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on criteria available prior to Revision 3 of this Regulatory Guide being issued.
The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respectively, and in other docketed analysis. Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.
The criteria of this Regulatory Guide are used at CPCo primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 20b, below).
l 20b. BG I.29, General Reauirement Apply pertinent Quality Assurance requireraents of 10 CFR 50, Appendix B.
Excention/Interoretation i
The pertinent quality requirements for these systems, structures and components will be l
determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.
21.
ANSf/ANS 3.1 -1987 Execotion/Interoretation i
The commitment to ANSI /ANS 3.1-1987 is limited to requirments that apply to persons performing the independent safety review function as specified in Appendix C to this QPD.
CPC.2A.R17 k
a
Pzga 73 Rev 17 Date: February 1,1997
]
i I
QPD MANUAL I
APPENDIX B PLANT REVIEW COMMITTEE (PRC) 81.
FUNCTION The Plant Review Committee (PRC) shall function to advise the Plant General Manager / Manager on all matters related to nuclear safety.
B2.
COMPOSITION The Palisades PRC is composed of nine regular members. The qualification level for PRC members shall be at least equivalent to those described in Section 4.4 of ANSI N 18.1 -1971. The PRC shallinclude representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Plant General Manager.
The Big Rock Point PRC is composed of nine regular members from the Big Rock Point staff.
l The PRC members shall meet or exceed the minimum qualifications described in Sections l
4.2 and 4.4 of ANSI N18.1-1971 for comparable positions. The PRC shallinclude l
representatives from the Operations, Chemistry / Health Physics, Maintenance, Engineering, i
and Safety and Licensing Departments. The member shall be designated in administrative I
procedures by the Plant Manager who is the Chairman of the PRC. The Plant Manager shall also designate an Alternate Chairman in writing, l
83.
ALTERNATES l
Alternate members of the PRC shall be appointed in writing by the PRC Chairman to serve i
on a temporary basis. No more than two alternates shall participate as voting members at any one time in PRC activities.
84.
MEETING FREQUENCY The PRC shall meet at least once per calendar month with special meetings as required.
i B5.
QUORUM A quorum of the Palisadcs PRC shall consist of the Chairman or alternate and four members or alternates. A quorum of the Big Rock Point PRC shall consist of the Chairman or alternate Chairman and four members or alternates.
i j
l CPC 2A.R17 1
PIga 74 Rev 17 Date: February 1,1997 B6.
RESPONSIBit.lTIES The PRC shall be responsible for nuclear safety review of:
a.
All procedures and programs specified by the Technical Specifications and changes thereto, and any other procedures or changes thereto as determined by the Plant General Manager / Manager to affect nuclear safety; all proposed tests or experiments that affect nuclear safety; all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
b.
All proposed changes to Operating License and Technical Specifications.
c.
Results of investigations of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and reccmmendations to prevent recurrence and be forwarded to the Vice President - NOD and to the Manager, Nuclear Performance Assessment Department (NPAD)).
d.
Plant operations to detect potential safety hazards.
e.
Reports of special reviews and investigations as requested by the Plant General Manager / Manager or NPAD.
f.
Site Emergency Plan and implementing procedures.
g.
All reportable events as defined in 10 CFR 50.72 and 50.73.
l h.
Allitems identified under B9.3 below as significant to nuclear safety (Palisades only).
l.
Monthly reports from Safety / Design Review (Palisades only).
j.
Nuclear industry operating experience.
k.
Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Plant Menager and to the Manager, Nuclear Performance Assessment Department (Big Rock Point only).
PRC review of the above items may be performed by routing, subject to the requirements of B7. below. The Palisades PRC may delegate review of item a. to Safety / Design Review staff, as described in B9. below.
CPC 2A.R17 e
Page 75 l
Rev 17 Date: February 1,1997 B7.
AUTHORITY l
The PRC shall:
I a.
Recommend in writing to the Plant General Manager / Manager approval or disapproval of items considered under B6.a. through j. above.
l b.
Render determinations in writing with regard to whether or not each item considered under B6.a, b, c, f (Palisades only) and h above constitutes an unreviewed safety l
question.
c.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC and the Plant General Manager / Manager; however, the Plant General Manager / Manager shall have responsibility for the resolution of such disagreements.
The PRC Chairman may recommend to the Plant General Manager / Manager approval of those items identified in B6. above based on a routing review provided the following conditions are met: (1) at least five PRC members including the Chairman and no more than 2 alternates, shall review the item, concur with determination as to whether or not the item constitutes an unreviewed safety question, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the PRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers for additional comments.
The item shall be reviewed at a PRC meeting in the event that: (1) Commerits are not resolved; or (2) the Plant General Manager / Manager overrides the recommeniaQns o' the PRC; or (3) a proposed change to the Technical Specifications involves a safety limit, a limiting safety system setting or a limiting condition for operation; or (4) the item was reportable to the NRC.
B8.
RECORDS The PRC shall maintain written minutes of each PRC meeting and shall provide copies for Independent Safety Review.
89.
TECHNICAL SUPPORT FOR PAllSADES PRC The Safety / Design Review organization shall function to examine proposed changes in design or operation and such other matters as the Palisades PRC may assign to identify issues significant to nuclear safety and recommend nuclear safety improvements.
89.1 The Safety / Design staff responsible for the review functicn shall be an experienced l
technical staff meeting the qualifications of Technical Specifications.
09.2 The Safety / Design Review staff may provide nuclear safety review as delegated by l
Palisades PRC for:
CPC 2A.R17
Prgs 76 Rev 17 Date: February 1,1997 Procedures, programs and changes thereto identified in the Technical Specifications a.
and any additional procedures and changes thereto identified by the Plant General Manager / Manager as significant to nuclear safety, b.
All proposed tests or experiments.
c.
All proposed changes or modifications to plant systems or equipment.
d.
The Site Emergency Plan and implementing procedures.
l 89.3 The Safety / Design Review staff shall determine those issues significant to nuclear safety which require review by the Palisades Plant Review Committee from items considered under
-l 89.2a. through d. above. For those items not referred to PRC, Safety / Design Review shall recommend in writing to plant management approval or disapproval of items considered l
under 83.2.
l 89.4 Reports of Safety / Design Review activities pursuant to B9 shall be submitted monthly to PRC.
i 4
CPC 2A.R17
_ _ ~..
Pigs 77 Rev 17 Date: February 1,.1997 QPD MANUAL APPENDIX C 4
J INDEPENDENT SAFETY REVIEW e
l The following exceptions / interpretations in Appendix A, Part 2, are relevant to i
implementation of the requirements of this section of the QPD:
t l
Annandix C Excentions/Interoretationa
{
2c, 2d, 2e, 2f, 21 C1.
FUNCTION The independent Safety Review Group (ISRG) shall function to provide independent review of activities in the areas of:
a.
Nuclear pcwor plant operation j
b.
Nuclear engineering j
c.
Chemistry and radiochemistry l
d.
Metallurgy j
e.
Nondestructive testing j
f.
Instrumentation and control g.
Radiological safety 1
h.
Mechanical and electrical engineenng 1.
Administrative controls and quality assurance practices J.
Emergency Planning k.
Training C2.
COMPOSITION The ISRG shallinclude the Manager, NPAD, who reports to the Vice President - NOD, and a full-time staff of posons reporting to the Manager, NPAD and designated as Nuclear Performance Specialists for the ISR function. The Manager, NPAD, and the Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4.7 of ANSl/ANS 3.1 1987. The ISRG shall have no direct responsibility for activities subject to j
its review.
1 i-C3.
CONSULTANTS i
i If sufficient expertise is not available within the ISRG to review particular issues, the ISRG shall have the authority to utilize consultants or other qualified organizations for expert i
advice.
1 j-C4.
RESPONSIBILITIES C4.1 REVIEW l
The ISRG shall review:
CPC 2A.R17
.g
.n a
.. ~.
.,.~.
_c Page 78 Rev 17 Date: February 1,1997 -
The safety evaluations for: 1) changes to procedures, equipment'or systems, and 2).
a.
tests for experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety question, b.
Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.
Proposed tests or experiments which involve an unreviewed safety question as defined
- c.
in 10 CFR 50.59.
d.
Proposed changes to Technical Specifications or the Operating License.
1 Violations of codes, regulations, orders, Technical Specifications, license requirements, e.
i or of internal procedures or instructions having nuclear safety significance.
f.
Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affects nuclear safety.
]
g.
All reportable events having nuclear safety significance.
\\
h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
1.
Reports and meeting minutes of the Plant Review Committee.
).
_ Fire Protection Program and implementing Procedure Changes (Palisades only).
k.
Reports of audits performed as specified in Appendix D, t
l ISRG review of the subjects in C4 above shall be performed by an assigned Nuclear Performance Specialist selected on the basis of technical expertise relative to the subject being reviewed. If the assigned Nuclear Performance Specialist determines the need for interdisciplinary review, a committee consisting of the Manager, NPAD, or his designate, and at least four Nuclear Performance Specialists, shall be assigned. Such committee shall meet as, conditions requiring interdisciplinary review arise, but no less than twice yearly.
j l C5 AUTHORITY The ISRG shall report to and advise the Vice-President, NOD, of significant findings
{
l associated with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.
l l C6 RECORDS Records of ISRG activities shall be maintained. Reports shall be prepared and distributed as indicated below:
l The results of reviews performed pursuant to C4 above shall be reported to the Vice-a.
President, NOD, at least monthly.
CPC-2 A.R17 4
Hm-e 4 r,rv v.,
-w---.w
Pago 79
~
Rev 17 Date: February 1,1997 b.
A report assessing each plant's overall nuclear safety performance shall be provided to l
l senior Consumers Power Company management annually.
I CPC 2A.R17
- -. _.. ~.... -.. -.. --
.- ~.-.. ~.
Pags 79 Rev 17 Date: February 1,1997 i
i QPD MANUAL.
APPENDIX D l
AUDIT FREQUENCIES t
D1.
AUDITS i
Audits of operational nuclear safety related activities are performed by the NPAD staff under the cognizance of Nuclear Performance Specialists. These audits encompass:
1 a.
The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
d b.
The performance, training and qualifications of the entire facility staff at least once per 12 months.
The performance of activities required by the Quality Program Description for c,
Operational Nuclear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50, Appendix B at least once per 24 months.
d.
- The Site Emergency Plan and implementing procedures at least once per 12 months.
The Site Security Plan and implementing procedures (as required by the Site Security e.
l Plan) at least once per 12 months.
f.
Any other area of plant operation considered appropriate by NPAD or the Vice President - Nuclear Operations.
t j
g, The plant Fire Protection Program and implementing procedures at least once per 24 i
months.
i h.
An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
l.
An inspection and audit of the fire protection and loss preventiorc program to be performed by an outside qualified fire consultant at intervals no grt,ater than 3 years.
4 i.
Radiological environmental monitoring program and the results thereof at least once 4
per 12 months.
)
k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least onco per 24 months.
I.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and j
packaging of radioactive wastes at least once per 24 months.
Audit reports encompassed by D1. above shall be forwarded to the Manager, NPAD, and i
Management positions r3sponsible for the areas audited within thirty (30) days af ter completion of the audit, j
CPC-2A.R17
-.g
I l
Pag 3 80 Rev 17 Date: February 1,1997 QPD MANUAL APPENDIX E RECORD RETENTION E1.
In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the fo!!owing records shall be retained for at least the minimum period indicated:
E2, The following records shall be retained for at least five years:
Records and logs of f acility operation covering time interval at each power level.
a.
b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principalitems of equipment related to nuclear safety, c.
All reportable events as defined in 10 CFR 50.72 and 50.73.
d.
Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications, Records of changes made to the procedures required by Plant Technical Specifications.
e.
f.
Records of radioactive shipments, g.
Records of sealed source leak tests and results, h.
Records of annual physical inventory of all source material of record.
E3.
The following records shall be retained for the duration of the Facility Operating License:
Record and drawing changes reflecting facility design modifications made to systems a.
and equipment described in the Palisades Final Safety Analysis Report or Big Rock Point Final Hazards Summary Report, b.
Rncords of new and irradiated fuelinventory, fuel transfers and assembly burnup histories.
l c.
Records of quarterly radiation exposure for all individuals entenng radiation control areas.
d.
Records of gaseous and liquid radioactive material released to the environs.
Records of transient or operational cycles for those facility components designed for a e.
limited number of transients or cycles.
f.
Records of inservice inspections performed pursuant to Plant Technical Specifications, i
g.
Records of Quality Assurance activities required by the Quality Program Description.
l CPC-2A.R17
_ _.... _... ~. _.. - _ _ - -. _.. _ -. ~. _, _.... _ _ _.. _ _ _. _ _... _ _.. - -. _ _ _
l Page 81 l
Rev 17 l
Date: February 1,1997
}
. h.
Records of reviews performed for changes made to procedures or equipment or i
reviews of tests and experiments pursuant to 10 CFR 50.59.
l.
l.
Records of meetings of the PRC and reviews performed by NPAD according to Appendix C.
j.
Records of monthly facility radiation and contamination surveys.
k.
Records of secondary water sampling and quality (Palisades only).
l l.
Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specifications. This shallinclude the date at which the service life l
commences and associated installation and maintenance records (Palisades only),
i Records for environmental qualifications which are covered under the provisions of 10 m.
CFR 50.49 (Big Rock Point only).
n.
Records of training and qualifications for members of the plant staff.
i
[
o.
Records of reactor tests and experiments, p.
Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM (Palisades only).
m l
i a
[
CPC-2A.R17
/
a
_I' l
t l
l ATTACHMENT 2 l
l l
CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 PALISADES PLANT DOCKET 50-255 i
l l
CPC-2A, Revision 17 Change Matrix i
l l
14 l
Pages l-
CHANT mTRIK 6/4/97 WALITY PROGRAN DESCRIPTION (CPC-2A)
REvl510N 17 Iten Revision 16 Revision 17 Reason for Change Basts for Conclusion 1
1.1 (Page 1) 1.1 (Page 1)
This section added to make clearer This chance does not affect content.
connection for users to the thus the ()PD continues to meet (Not in Revisien 16)
Added Paragraph 4 Exceptions / Interpretations in 10 CFR 50. Appendix B.
W dix A. Part 2. that relate to the s @ ject of this section.
2 1.2.2.4.
1.2.2.a. (Page 3)
These responsibilities were This change does not affect content, formerly in Nuclear Services and thus the OPS continues to meet (Not in Revision 16)
Added Subparagraphs 16 and 18.
were transferred to the Plant 10 CFR 50. Appendix B.
Manager 3
1.2.2.b. (Page 5) 1.2.2.b. (Page 4)
Change in terminology from "rtsk" This chan does not affect content.
Paragraph 20 Subparagraph 19 to
- safety
- to be consistent with thus the continues to meet Development and utilization of Development and utilization of nuclear plant probabilistic risk nuclear plant probabilistic safety assessment models to evaluate safety assessment models to evaluate safety and plant reliability improvement.
and plant reliability improvement.
4 1.2.3.a. (Page 8) 1.2.3.a. (Page 7)
Change reflects elimination of FMS is not an organization or function Field Maintenance Services group required by 10 CFR 50. Appendix B.
The The Manager. Equipment Services &
The Manager. Equipment Services from this organization. and name Site Vice President or Plant General field Maintenance Services provides provides electrical. rotating and change of unit. Maintenance Manager retain responsibility for, and electrical. rotating and stationary stationary equipment expertise.
services (personnel) may still be control of. maintenance performed in equipnent expertise and provides including developing and qualifying provided by Consumers inergy repair support of nuclear plant operations, field maintenance services for procedures for welding and heat crews fran other pwer plants.
Thus, the QPD continues to meet assigned modification and treating.
requirements of Criterion I for a maintenance tasks. This includes description of organizations that developing and qualifying procedures 1eptement the quality program, for welding and heat treating.
5 1.2.3.b. (Page 8) 1.2.3.b. (Page 7) 1.
Department name change.
This change does not alter the nature 2.
Clarifles that Big Rock of the Records Management System. The The Manager. Projects. Engineering The Director. Fuel Supply & Plant saintains its e safeguards QPD continues to meet the requirements and Construction. maintains the Operations maintains the Records information and is responsible of Criterion I for a description of the Records Managment System including Management System including required for doc ment quality.
organizations that implement the required retention. protection and retention. protection and program.
retrievability. This includes retrievability. This includes collecting. stor!ng. maintaining.
collecting storing. maintaining.
distributing and controlling plant distributing and controlling plant engineering / design docinents (Big engineering / design doctments (Big Rock only).
Rock only). This excludes Big Rock Safeguards infonnation doctments.
which are maintained at Big Rock.
The accuracy. quality. and correctness of Big Rock documents in the Records Management System are the responsibility of Big Rock Point.
10 3,: The dif ference in page numbers between Revisions 16 and 171s primarily due to format and type-font changes, not changes in content.
Page 1
h CHA EE MATRIX 6/4/97 OUALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 6
1.2.4.a. (Page 9) 1.2.4.a. (Page 8)
Organization name changes only.
This change does not affect content.
thus the QPD continues to meet The Manager. Transmission Energy The Manager. Electric System 10 CFR 50. Appendix B.
i Delivery (see Figure 1) is Operattens (see Figure 1) is respunsible through the Vice responsible through the Vice Pres 1&nt. Electric Transmission to President. Electric Transmission and the Executive Vice President and 01stribution to the Executive Vice Chief Operating Officer - Electric President and Chief Operating for determining settings for Officer - Electric for determining electrical protective systems and settings for dectrical protective relay control schemes and for systems and relay control schemes.
design. review and recommending and for design. review and changes to electrical protective recommending changes to electrical schemes and associated settings.
protectivt schemes and associated settings.
7 1.2.4.b. (Page 9) 1.2 4.b. (Pe p 8)
Organization name change only.
This change does not affect content, thus the OPD continues to meet The Executive Manager. Electric The Director. E ectric Employee 10 CFR 50. Appendix B.
Business Sup. port (see Figure 1) is Development (set FigJ e 1) is responsible to the Executive vice responsible to the Executive Vice President and Chief Operating President and Chief Operating Officer Electric for operating the Officer - Electric for operating the Skill Centers including the Skill Centers including the training.
training. and qualifying of and qualifying of personnel and personnel and equipment for welding equipment for welding operations.
operations.
8 1.2.4.e. (Page 10) 1.2.4.e. (Page 9)
Organization name changes only.
This change does not affect content.
thus the 0P0 continues to meet The Manager. Transmission Order The Manager. Electric Services is 10 CFR 50. Appendix B.
Fulfillment is responsible. through responsible. through the Vice the Vice President. Electric President. Electric Transsission and Transmission to the Executive Vice D utribution to the Executive Vice President and Chief Operating President and Chief Operating Officer Electric for testing and Officer - Electric for testing and maintaining electrical protective maintaining electrical protective devices. perfonning design devices, perfonning design verification testing associated with verification testing associated with electrical protective schemes.
electrical protective schemes.
devices and application of devices and application of associated associated settings.
settings.
1 a
N,Qf TD The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
Page 2
CHANGE MATRIX 6/4/97 00AtITY PROGRM DESCRIPTION (CPC-?A)
PEVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 9
2.1 (Page 13) 2.1 (Page 12)
Corrected reference to plant AOttlon of Appendix C adds Paragraph 3 Paragraph 3 Technical Specifications tha'.
not based on 10 CFR 50. Appendix 8.
requiretents to the QPD. but these are should have been changed. with Quality Program status. scope.
Quality Program status. scope.
Revision 16. to Appendix C.
Thus the QPD continues to meet l
adequacy and compliance with adequacy and compliance with Addition of Appendix C was made to 10 CFR 50 requirements.
10 CFR 50. Appendix B are regularly 10 CFR 50. Appendix B are regularly support removal of same material revi sed by CPCo Management through reviewed by CPCo Management through from Technical Specifications.
reports, meetings and review of reports. meetings and review of audit audit results. A preplanned and results. A preplanned and documented doctnented assessment of the nuclear assessment of the nuclear safety safety performance is conducted as performance is conducted as described described in Technical in Appendix C.
Specifications.
10 2.1 (Page 13) 2.1 (Page 12)
This section added to make clearer This change does not affect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 4 and 5.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
11 2.2.6.c. (Page 15) 2.2.6.c. (Page 14)
Change in terminology from " risk" This change does not affect content.
to " safety" to be consistent with thus the QPD continues to meet the extent to d ich controls The extent to d ich controls industry usage.
10 CFR 50. Appendix B.
specified in the Quality Program are specified in the Quality Program are applied to items is determined for applied to items is detemined for each item considering its relative each item considering its relative importance to safety. Such importance to safety. Such deteminations are based on data in determinations are based on data in such documents as the plant risk such doctments as the plant safety analysis, plant Technical analysis. plant Technical Specifications and the FSAR/FHSR Specifications and the FSAR/FHSR (See (See Appendix A).
Appendix A).
12 2.2.10.b. (Page 17) 2.2.10.b. (Page 15)
Corrected reference io plant Addition of Appendix C adds Technical Specifica%1ms that requirements to the 000, but these are Managemant teams assess the nuclear Manay. t teams assess the nuclear should have been ch.nged, with not based on 10 CFR 50. Appendix B.
safety performance as described in safe 6y performance as described in Revision 16. to Appendix C.
Thus the OPD continues to meet the Technical Specifications.
Appendix C.
Conclusions and Addition of Appendii C was made to 10 CFR 50 requirements.
Conclusions and recommendations are recommendations are reported to the support removal of same material reported to the Executive Vice Executive Vice President and Chief from Technical Specifications.
President and Chief Operating Operating Officer - Electric.
Officer - Electric.
13 3.1 (Page 18) 3.1 (Page 16)
This section added to make clearer This chan _ does not affect content.
connection for usars to the thus the continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
W d1x A. Part 2. that relate to the subject of this section.
!!0TD The difference in page numbers between Revisions 16 and 17 is primarily due to fornat and type-font changes, not changes in content.
Page 3
CHANG MATRIX 6/4/97 OIALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 14 4.1 (Page 22) 4.1 (Page 19)
This section added to make clearer This chan does not affect content.
connection for users to the thus the - continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix 8.
@ dix A. Part 2. that relate to tne subject of his section.
15 5.1 (Page 24) 5.1 (Page 21)
This section added to make clearer This chan does not affect content.
connection for users to the thus the continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
16 6.1 (Page 21) 6.1 (Page 24)
Change made to provide more exact The QPD provides controls over doctment Paragraph 1 Paragraph 1 match with wording being removed preparation. review. approval and use from plant Technical that continue to be consistent with Documents controlling safety-related Documents controlling safety-related Speci fications. " Prior to Criterion VI of 10 CFR 50. Appendix B.
activities within the scope defined activities within the scope defined implementation
- was always required The change enhances the clarity of In Section 2.0. @ALITY PROGRAM are in Section 2.0. @At!TY PROGRAM are by 6.2.4.2. but this change these requirements.
Issued and changed at. cording to 1ssued and changed according to clartfled the requirement in this established procedures. Doctnents established procedures. Documents section.
such as Instructions procedures and such as instructions. procedures and drawings. including changes thereto.
drawings. Including changes thereto.
are reviewed for adequacy. approved are reviewed for adequacy. approved for release by authorized personnel" for release prior to implementation and are distributed and used at the by authorized personnel and are location where a prescribed activity distributed and used at the location is perfonned.
where a prescribed activity is perfonned.
17 6.1.1 (*)(Page 27) 6.1.1 (*) (Page 24)
Change made to provide more exact The QPD provides controls over document eatch with wording being removed preparation review. approval and use For Palisades. an appropriate senior For Palisades, an appropriate senior from plant Technical that continue to be consistent with department manager. based on the department manager based on the Specifications.
Criterton VI of 10 CFR 50. Appendix B.
activities addressed in the specific activities addressed in the specific The change enhances the clarity of procedure. designated in writing by procedure predesignated in writing these requirements.
the Plant General Manager: or.
by the Plant General Manager or.
18 6.1 (Page 27) 6.1 (Page 24)
This section added to make cTearer This chan does not affect content, connectim for users to the thus the continues to meet (Not in Revision 16)
Added Paragraph 4.
Exceptions / Interpretations in 10 CFR 50. Appendix 8.
p dix A. Part 2. that relate to tne subject of this section.
19 7.1 (Page 29) 7.1 (Page 26)
This section added to make clearer lhls change does not affect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Port 2. that relate to the subject of this section.
N.O_T,1:
The dif ference in page ntabers between Revisions 16 and 171s primarily due to format and type-font changes. not changes in content.
0 Page 4
GANGE MATRIX 6/4/97 DJALITY PROGRAM DESCRIPTION (CPC-2A)
REVI5!ON 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 20 8.1 (Page 32) 8.1 (Page 29)
This section added to make clearer This change does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CfR 50. Appendix 8.
Appendix A. Part 2. that relate to the subject of this section.
21 9.1 (Page 33) 9.1 (Page 30)
This section added to make clearer This change does not affect content, u m ection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Excepitons/ Interpretations in 10 CFR 50. Appendix B.
W dix A. Part 2. that relate to the subject of this section.
22 10.1 (Page 34) 10.1 (Page 31)
This section added to make clearer This change does not af fect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
23 10.2.3 (Page 35) 20.2.3 (Page 32)
Organization name change only. No This change does not affcct content.
Paragraph 1 Pragraph I change in requirements.
thus tne OPD continues to meet 10 CFR 50. Appendix B.
...For activities performed at
...for activities performed at Palisades that are mder the Palisades that are under the cognizance of Nuclear Engineering cognizance of Nuclear Services, the and Constructim. the Manager.
Manager. Nuclear Projects and Nuclear Engineering and Construction Construct 1m 1s responsible for is responsible for review and review and c mcurrence of such concurrence of such programs, programs.
24 11.1 (Page 37) 11.1 (Page 34)
This section added to make clearer This change does not affect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
W. dix A. Part 2. that relate to the subject of this section.
25 12.1 (Page 39) 12.1 (Page 36)
This section added to make clearer This change does not affect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to tne subject of this section.
26 13.1 (Page 41) 13.1 (Page 38)
TMs section added to make clearer This change does not affect content, connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
NO]T[: The difference in page numbers between Revisions 16 and 171s primarily due to format and type font changes. not chanqes in content.
0 Page 5
CHANGE MATRIX 6/4/97 OUALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for N rie Basis for Conclusion n
27 14.1 (Page 42) 14.1 (Page 39)
TMs section added to make clearer This chan does not affect content.
unnection for er$ to the thus the continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptionu >tspretations in 10 CFR 50. Appendix B, Appendix A. Part 2. that relate to the subject of this section.
28 15.1 (Page 43) 15.1 (Page 40)
This section added to make clearer This chance does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
- ppsr.d 5 A. Part 2. that relate to the subject of this section.
29 17.1 (Page 46) 17.1 (Page 43)
This section added to make clearer This change does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
30 15.1 (Page 48) 18.1 (Page 45)
This section added to make clearer This change does not affect content, connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Apendix B.
Appersdix A. Part 2. that relate to the subject of this section.
31 APPENDIX A. Part I (Page 51)
APPENDIX A. Part 1 (Page 48)
Cm mitment added as part of This change adds a commitment for tr=tsfer of material from plant personnel qualifications for the (Not in Revision 16)
- 22. ANSI /ANS 3.1-1987. Selection.
Technical Specifications independent revi m function that Qualification, and Training of (Appendix C in this QPD) regarding previously existed in pisnt Technical Personnel for Nuclear Pmer qualifications of independent Specifications. The change enhances Plants application limited as reviewers in NPAD.
compliance with Criterton 11 of described in Append 1x C of this 10 CFR 50. Appendix B.
document.
32 APPENDIX A. Part 2 (Page 55)
APPENDIX A. Part 2 (Page 52)
Change made to provide more exact The OPD nm provi9s controls over 2h. sec 5.2.2 2h. N18.7. Sec 5.2.2 match with temporary change wording temporary changes to procedures that Exception / Interpretation Exception / Interpretation being removed from plant Technical are rully consistent with 64 sat was in Paragraph 1 Paragraph 1 Specifications. Tech Specs -
plant Technical Specifications. -the currently allow temporary changes OPD continues to meet Criterla V and VI CPCo considers that thi< requirement CPCo considers that this requirement to Security and E Plan procedures -
of 10 CFR 50. Appendix B.
applies only to procedur w applies only to procedures identified previous CPC-2A wording did not identified in plant technMal in Plant Technical Specifications and (this will be removed from Tech specifications. Temporary changas to Security and Emergency Plans Specs in favor of CPC-2A).
to these proccslures may be made implementing procedures. Temporary provided:
changes to these procedures may be made provided:
gjTF The difference in page numbers between Revisions 16 and 17 is primarily due to for1 mat and type-font changes. not changes in content.
Page 6
CHANGE NATRIX 6/4/97 00ALITY PROGRAM DESCR1PT10N (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 33 APPENDIX A. Part 2 (Page 61)
APPENDIX A. Part 2 (Page 57)
This change restores the This change restores the clarity of the da. ANS 3.1. General 4a. ANS 3.1. General clarification of applicability of cuanttment to the draft standard, and.
Exception / Interpretation Exception /Interpretatta, this commitment to that originally in so doing. c-;sures that persons Paragraph 1 Paragraph 1 intended. Recent revisions had performing independent quality implied the commitment was non-assurance functions will be trained and Lead auditors are tratned and The commitment to ANS 3.1 (12/79.
relevant to any grour,. but this was quattfled so as to meet Criterion I: of qualifted to Regulatory Guide 1.146.
draft) is limited to the requirements never intended. The wording in 10 CFR 50. Appendix B.
All other personnel are trained and that apply to the training and Revision 11 and 12 of this QPD. as quaiifled as designated in the plant qualification of persons performing c m bined herein. more appropriately Technical Spectfications.
Independent quality assurance convey the Intended nature of this functions, except for Lead Auditors.
commitment.
Lead auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI 45.2.23-1978. Other personnel are tralned and qualified as designated in plant Technical Specifications.
34 APP [NDIX A. Part 2 (Page 61)
APPENDIX A. Part 2 (Page 58)
This change restores the This change restores the clarity of the Sa. RG 1.8. C.3.1. General Sa. RG 1.8. C.3.1. General clarification of applicability of commitment to the draft Regulatory E xception/Interpat ation Exception / Interpretation this commitment to that originally Guide. and. In so doing. assures that Paragraph 1 Paragraph !
intended. Recent revisions had persons performing independent quality implied the commitment was non-assurance functions will be trained ar;d lead auditors are trained and The comitment to Regulatory relevant to any group. but this was qualified so as to meet Criterton II of qualified to Regulatory Guide 1.146.
Guide 1.8 (9/80. draft) is limited to never intended. The wording in 10 CFR 50. Appendix B.
All other personnel are trained and the requirements that apply to the Revision 11 and 12 of this QPD as qualifted as designated in the plant training and qualification of persons combined herein. more appr@rtately Technical Specifications.
performing independent quality convey the intended nature of this assurance functions. except for Lead commitment.
Auditors. Lead Auditors are trained and quellfled to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978. Other personnel are tralned and qualified as esignated in plant Technical Specifications.
35 APPENDIX A. Part 2 (Page 63)
APPENDIX A. Part 2 (Page 59)
Editorial change - added the ANSI This change does not affect content, standard ntm6er.
thus the QPD continues to meet 6c. Sec 5 6c. N45.2.1. Sec 5 10 CFR 50. Appendix B.
36 APPENDIX A. Part 2 (Page 6'3)
APPENDIX A. Part 2 (Page 60)
Editorial change - added the ANSI This change does not affect content.
standard ntaber.
thus the QPD continues to meet 7b. Sec 2.4 7b.
M45.2.2. Sec 2.4 10 CFR 50. Appendix B.
37 APPENDIX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page 60)
Editorial change - added the ANSI This chan does not affect content.
standard ntaber.
thus the cantinues to meet 7c. Sec 3.4.1 and Apperdix A.
7c.
N45.2.2. Sec 3.4.1 and 10 CFR 50. Append 1x B.
3.4.1(4) and (5)
Appendix A. 3.4.1(4) and (5)
MTD The elf ference in page numbers between Revisions 16 and 171s primarily due to format and type-font changes. not changes in content.
Page 7
l CHANGE MATRIX 6/4/97 g?) 'TY PRNRM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basts for Conclusion 38 APPENDlX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page 60)
Editorial change added the ANSI This change does not affect content.
standard ntaber.
thus the QPD continues to meet 7d. Sec 3.9 and Appendix A. 3.9 7d.
N45.2.2. Sec 3.9 and Appendix A.
10 CFR 50. Appendix B.
3.9 39 APPENDIX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page 61)
Editorial change - added the ANSI This change does not affect content.
standard ntaber.
thus the QPD continues to meet 7e. Sec 5.2.2 7e. N45.2.2. Sec 5.2.2 10 CFR 50. Appendix B.
40 APPENDlX A. Part 2 (Page 65)
APPENDIX A. Part 2 (Page 61)
Editorial change - added the ANSI This chan does not affect content.
standard number.
thus the continues to meet 7f. Sec 6.2.4 7f.
N45.2.2. Sec 6.2.4 10 Cfd 50. Appendix B.
41 APPINDIX A. Part 2 (Page 65)
APPENDIX A. Part 2 (Page 61)
Editorial change added the ANSI This change does not af fect content.
standard number, thus the QPD continues to meet 79 Sec 6.3.4 79 N45.2.2. Sec 6.3.4 10 CFR 50. Appendix B.
42 APPENDlX A. Part 2 (Page 65)
APPEND:X A. Part 2 (Page 61)
Editorial change - added the ANSI This chance does not affect content, standard ntaber.
thus the QPD centinues to meet 7h. Sec 6.4.1 7h.
N45.2.2. Sec 6.4.1 10 CFR 50. Appendix B.
43 APPENDIX A. Part 2 (Page 66)
APPENDIX A. Part 2 (Page 62)
Editorial change - added the ANSI This change does not affect content standard number.
thus the QPD continues to meet 9b.
Sec 2.2(5) 9b.
N45.2.4. Sec 2.2(5) 10 CFR 50. Appendix B.
44 APPfNDIX A. Part 2 (Page 67)
APPENDIX A. Part 2 (Page 63)
Editorial change - added the ANSI This change does not affect content.
standard number.
thus the OPD continues to meet 9c. Sec 6.2.1 9c.
N45.2.4. Sec 6.2.1 10 CFR 50. Appendix B.
45 APPENDIX A. Part 2 (Page 68)
APPENDIX A. Part 2 (Page 64) fd tnrial change - added the ANSI This change does not affect content.
Standa.1 n'alber.
thus the QPD cor.tinues to meet loc. Sec 5.4 10c. N45.2.5. Sec 5.4 10 CFR 50. Appendix B.
46 APPENDIX A. Part 2 (Page 69)
APPENDIX A. Part 2 (Page 65)
Editorial change - added the Reg lhis change does not affect content.
Guide ntaber.
thus the QPD continues to meet 12b. Sec C.5 12b. RG 1.58. Sec C.5 10 CFR 50. Append 1x B.
47 APPENDIX A. Part 2 (Page 69)
APPENDIX A. Part 2 (Page 65)
Editorial change - added the Reg This chan does not affect content.
Guide n eber.
thus the continues to meat 12c. Sec C.6 12c. RG 1.58. Sec C 6 10 CFR 50. Appendix B.
48 APPENDIX A. Part 2 (Page 70)
APPENDlX A. Part 2 (Page 65)
Editoriat change - added the Reg This change does not affect content.
Guide ntmaer.
thus the QPD continues to meet 12d. Sec C.10 12d. RG 1.58. Sec C.10 10 CFR 50. Appendix B.
49 APPENDIX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 66)
Editorial change - added the ANSI This chance does not affect content.
standard ntater.
thus the QPD continues to meet 13b. Sec 2.9 13b. N45.2.8. Sec 2.9 10 CFR 50. Appendix B.
1i03,: The dif fer=nce in page ntabers between Revisions 16 and 17 is primarily due to format and type-font changes, not changes in content.
Page 8
CHANGE MATRIX 6/4/97 OHALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 50 APPENDIX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 66)
Change marked in error.
RA 13c. N45.28. Sec 2.9e 13c. N45.2.8. Sec 2.9e (Marked but didn't change) 51 APP [NDIX A. Part 2 (Page 71)
APPINDIX A. Part 2 (Page 67)
Editorial change added the ANSI This change does not affect content.
Standard ntaber.
thus the QPD continues to meet 13.d Sec 2.9e 13d. N45.2.8. Sec 2.9e 10 CFR 50. Appendix B.
52 APPENDlX A. Part 2 (Page 71)
APPfND11 A. Part 2 (Page 67)
Editorial change - added the ANSI This change does not affect content.
standard number.
thus the QPD continues to aeot 13e. Sec 4.5.1 13e. N45.2.8. Sec 4.5.1 10 CFR 50. Appendix B.
53 APPfNDIX A. Part 2 (Page 72)
APPENDIX A. Part 2 (Page 67)
Editorial change added the ANSI This change des not ef fect crtent.
standard ntaber.
thus the QPD continues to meet 149. Sec 6.2 14b. N45.2.9. Sec 6.2 10 CFR 50. Appendix B.
54 APPENDIX A. Part 2 (Page 74)
APPENDIX A. Part 2 (Page 69)
Editorial change added the Reg This change does not affect content.
Guide ntaber.
thus the QPD continues to meet 16b. Sec C3a(2) 16b. RG 1.144. Sec C3a(2) 10 CFR 50, Appendix B.
55 APPINDIX A. Part 2 (Page 74)
APPENDIX A. Part 2 (Page 69)
Editorial change - added the Reg This chan does not affect content.
Guide number.
thus the continues to meet 16c. Sec C3b(1) 16c. RG 1.144. Sec C3b(1) 10 CFR 50. Appendix B.
56 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This change does not affect content.
standard number.
thus the QPD continues to meet 17b. Sec 3.2.3 17b. N45.2.13. Sec 3.2.3 10 CFR 50. Appendix B.
57 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This chan. does not affect content.
standard nunber, thus the continues to meet 17c. Sec 3.3(a) 17c. N45.2.13. Sec 3.3(a) 10 CFR 50. Apper'!x B.
58 APP [NDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial t.hange - added the ANSI This change does not affect content, standard number, thus the QPD continues to meet 17d. Sec 3.3(b) 17d. N45.2.13. Sec 3.3(b) 10 CFR 50. Appendix B.
58 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This chan does not affect content.
standard ntaber.
thus the continues to meet 17e. Sec 7.5 17e. N45.2.13. Sec 7.5 10 CFR 50. Appendix B.
60 APPENDIX A. Part 2 (Page 76)
APPENDIX A. Part 2 (Page 71)
Editorial change - added the ANSI This change does not affect content.
standard ntrber, thus the QPD continues to meet 17f. Sec 10.1 17f. N45.2.13. Sec 10.1 10 CFR 50. Appendix B.
NOK: The dif ference in page numbers between Revisions 16 and 171s primarily due to format end type-font changes. not changes in content.
Page 9
l:s
'm CHANrE P%TRIX 6/4/97 OtAtITY PROGRAM DESCRIPTION (CPC-2A)
REYlSION 17 I
Revision 17 Reason for Change Basis for Conclusion Item Revision 16
+-
61 APP [NDlX A. Part 2 (Page 76)
APPENDIX A. Part 2 (Page 71)
Editorial change - added the ANSI
'his change does not affect content, standard number.
J us the OPD continues to meet 179. Sec 10.3.4 (as modified by 179. N45.2.13. Sec 19.3.4 (as 10 CFR 50. Appendix B.
RG 1.123. 06e) modified by RG 1.123. 06e)
?2 APPENDIX A. Part 2 (Paga 77)
APPENDIX A. Part 2 Change in terminology from " risk" This change does not af fect content.
20b. RG 1.29. General 20b. RG 1.29. General to " Safety" to be consistent with LNs the QPD continues to meet Exception /Interpretition Exception / Interpretation industry usage.
10 CFR 50. Appendix B.
Parag 9ph 1 Paraoraph 1 The pertinent quality requirements The pertinent quality requirements for these systems structures and for these systees. structures and components will be detemined in a components will be determined in a graded manner using tools such as graded manner using tools such as the the plant specific Probabilistic plant specific Probabilistic Safety Risk Assessment and the Technical Assessment and the Technical Specifications. and other docketed Specifications. and other docketed analyses to deterstne the degree analyses to determine the degree dich Appendix B of 10 CFR 50 whicn Appendix B of 10 CFR 50
- applies, applies.
63 (Not in Revision 16)
APPENDIX A. Part 2 (Page 72)
Change made to clarify nature of The OPD provides training and
- 21. ANSI /ANS 3.1-1987 commitment to ANS 3.1-1987. which qualification requirements (for persons Exception / Interpretation was transferred from plant performing independent safety reviews)
Technical Specifications, that meet those previously established The commitment to ANSI /ANS 3.1-1987 in plant lechnical Specifications.
Is limited to requirements that apply Thus the OPD continues to meet to persons performing the independent Criterton 11 of 10 CFR 50. Appendix B.
safety review function as specified in Appendix C to this QPD.
64 APPEND!X B (Page 79)
APPENDIX B (Page 74)
Change in referenced paragraph due This change does not affect content, to renumbering in foltawing section thus the QPD continues to aeet B6.h.
All items identified m der B6.h. All iters identified under (see item 67).
10 CFR 50. Arsenos." B.
B12. below as significant to B9.3 bei m as significant to nuclear safety (Palisades nuclear safety (Palisades only).
only).
65 APPENDIX B (Page 80)
APPENDIX B (Page 75)
Correction of references to provide These requirements contain details, cmplete consistency with wording fomerly in plant Technical B7.a. Rec amend in writing to the 87.a. Recommend in writing to the in plant Technical Specifications.
Specifications. that are not addressed Plant General Manager / Manager Plant General Manager / Hanager by 10 CFR 50. Appendix B.
Correction approval or disapproval of approval or disapproval of has no effect on compliance.
Items conO dered under B6.a.
Items considered under B6.a.
through 1. above, through J. above.
N0_Tp The dif ference in page ntabers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content, 0
Page 10
CHANrf MATRIX 6/4/97 GHAtlTY PMYAAM DESCRIPTIDN (CPC-2A)
REVISION 17 Itee Revision 16 Revision 17 Reason for Change Basis for Conclusion 66 APPENDIX B (Page 80)
APP [NDIX B (Page 75)
Correction of references to provide These requirments contain details, complete consistency with wording fcnnerly in plant Technical B7.b.
Render deteminations in B7.b. Render determinations in in plant Technical Specifications.
Specifications that are not addressed writing with regard to writing with regard to d ether by 10 CTR 50. Appendix B.
Correctfon whether or not each item or not each item considered has no effect on compilance, cmsidered under B6.a. c and under B6.a. b, c. f (Palisades g above constitutes an only) and h. above constitutes unrevi s ed safety question.
an unrevi sed sa' ty question.
67 APPENDIX B (Page 81)
APPENDIX B (Page 75)
Renumbered to provide more clarity This change does not affect content.
and better organization of thus the OPD continues to meet BIO.
The Safety / Design staff 89.1 The Safety / Design staff statements. No wording changes 10 CFR 50. Appendix B.
responsible for the reyt m responsible for the rev1 m
- made, function shall be an function shall be an experienced technical statf expertenced technical staff meeting the quaitfications of meeting the qualifications of Technical Specifications.
Technical Specifications.
68 APPENDIX B (Page 81)
APPElDIX 6 (Page 75)
Renumbered to provide more clarity This change does not affect content.
and better organization of thus the QPD continues to meet 811.
lhe Safety / Design Revtm B9.2 The Safety / Desist Review staff statements. No wording changes 10 CFR 50. Anpendix B.
staff may provide nuclear may provide nuclear safety made.
safety review as delegated by review as delegated by Palisades PRC for:
Palisades PRC for:
69 APPENDIX B (Page 81)
APPENDIX B (Page 76)
RenJabered to provide more clarity This change does not affect content.
e and better organization of thus the fjPD continues to meet B12.
The Safety / Design Revim B9.3 The Safety /Destgri Rev1w staff statements. and to correct 10 CFR 50. Appendix B.
staf f shall determine those shall determine those issues references based on renumbering of issues significant to nuclear significant to nuclear safety other sections.
safety which require rev1m which require review by the by the Palisades Plant Revi m Palisades Plant Review Committee from items Committee from items considered under B11.4.
considered under 89.2a.
through d. above. Fcr those through d. above. For those Itms not referred to PRC.
Items not referred to PRC, Safety / Design Review shall Saf5ty/ Design Review shall recommend in writing to plant reccuiend in writing to plant management approval or management approval or disapproval of itses disapproval of items considered under 811, considered under B9.2 70 APPLNDIX B (Page 81)
APPENDIX B (Page 76)
Renumbered to provide more clarity This change does not affect content, and better organization of thus the QPD continues to meet B13.
Reports of Safety / Design B9.4 Reports of Safety / Design statements. No wording changes 10 CTR 50. Appendix B.
Revi m activities pursuant to Review activities pursuant to made.
Bil. shall be submitted 89 shall be submitted amthly monthly to PRC.
to PRC.
M}K: The dif ference in page ntabers between Revisions 16 and 17 is primarily due to fomat and type-font chmg s, nit changes in content.
Page 11 L
~-..
- -.. -.. -.. _.. - - - - - ~. -.. -..
. ~
I t
CHANGE MATRIX 6/4/97 DJALITY PROGRAM DESCRIPTION (CPC.2A)
REVISION 17 l
Ifen Revision 16 Revision 17 Reason for Change Basis for Conclusion l
I 71 APPENDIX C (Page 82)
APPENDIX C (Page 77)
This section added to make clearer This chan does not affect content.
connection for users to the thus the continues to meet (Not in Revision 16)
Added Paragraph 1.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
)
i 72 APPENDIX C (Page 82)
APPENDIX C (Page 77)
Change made to provide more exact The OPD now provides controls over the C2.
Ctaposition C2.
C0f051 TION match with wording being removed independent safety review function that
[
from plant Technical are fully consistent with what was.in i
The 15RG shall include the Manager.
The 15iiG shall include the Manager.
Speci fications. Tech Specs used Technical Specifications. lhese NPAD. who reports to the Vice NPAD. idio reports to the Vice
- Full-time staff reporting 10..."
reautrements contain details not President - N00, and a staff of President - NOD. and a full-time addressed by 10 CFR 50. Appendix B.
persons desi pated as Nuclear staff of persons reporting to the Correction has no effect on compliance.
Performance Specialists for the IM Manager. NPAD and desi p ated as function. The Manager. NPAD and Nuclear Performance Specialists for i
the Nuclear Performance Specialists the ISR function. The Manager. NPAD; shall meet or exceed the and the Nuclear Performance qualifications described in Specialists shall meet or exceed the i
Section 4.7 of ANSI /ANS 3.1 1987.
qualifications described in i
The 15RG shall have no direct Section 4.7 of ANSI /ANS 3.1-1987.
I responsibility for activities The ISRG shall have no direct subject to its review, respons1b111ty for activities subject t
to its review.
73 APPENDIX C (Page 82)
APPENDIX C (Page 77)
Renumbered to provide more clarity This change does not affect content.
I and better organization of thus the QPD continues to meet C5.
Review C4.1 REVIEW statements. No wording changes 10 CFR 50. Appendix B.
I made.
74 APPENDIX C (Page 83)
APPE E IX C (Page 78)
Correction of reference due to This change dces not affect content.
C5.
Review C4.1 REVIEW rents l bering.
thus the QPD continues to meet l
Final Paragraph Paragraph 13 10 CFR 50. Appendix B.
15RG revi m of the subjects in C5.
ISRG review of the subjects in C4.
above shall be performed by above shall be performed by.
I 75 APPENDIX C (Page 83)
APPE W IX C (Page 78)
Rentabered to provide more clarity This change does not affect content.
and better organization of '
thus the QPD continues to meat C6.
AUTHORITY C5 AUTHORITY statements. No wording changes -
10 CFR 50. Appendix B.
L made.
r I
9 fpJTD The difference in page ntabers between Revisions 16 and 17 is primarily due to fors i and type-font changes. not changes in content.
Page 12 4
- w.
-m-
CHANGE MATRIX 6/4/97 OUALITY PROGRM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 76 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Rentabered to provide more clarity This chan does not affect content.
C6.
AUTHORITY CS MTHORifY and better organization of thus the continues to meet Paragraph 1 Paragraph I statements. No wording changes 10 CFR 50. Appendix B.
made. Change in referenced The ISRG shall report to and advise The ISRG shall report to and advise paragraph due to renumbering in the Vice-President. NOD. of the Vice-President. N00. of section.
significant findings associated with significant findings associated with those areas of responstb111ty those areas of responsibility specified in C5. above and specified in C4. above and Appendix D. Audit frequencies.
Appendix D. Audit frequencies.
11 APP [NDIX C (Page 83)
APPENDIX C (Page 78)
Rentabered due to earlier number This change does not affect content.
- changes, thus the QPD continues to meet C7.
RECORDS C6 RECORDS 10 CFR 50. Appendix 8.
78 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Change in referenced paragraph due This chan. does not affect content, to renumbering in section.
thus the continues to maet C7.a. The results of reviews CG.a.
The results of reviss 10 CFR 50. Appendix B.
perfonned pursuant to C5.
perfomed pursuant to 04.
above shall be reported to above shall be reported to the the Vice-President, NOD. at Vice-President. N00. at least least monthly.
monthly.
t 79 APPENDIX C (Page 84)
APPENDIX C (First Page 79)
Rentabered due to earlier number These requirements contain details, changes. Made this applicable to formerly in plant Technical
+
C7.b. A report assessing the C6.b. A report assessing each both operating plants. as Specifications. that are not addressed overall nuclear safety plant's overall nuclear safety Revision 16 was in error in by 10 CFR 50. Appendix B.
Change has performance of Palisades performance shall be provided restricting it to Palisadas.
no effect on cmpliance.
shall be provided to senior to senior Constners Pmer Consumers Power Company Company management annually.
managemmt annually.
80 APPENDIX D (Page 85)
APPENDIX C (Second Page 79)
Change made to provide more exact This GPD now provides controls over DI.
AUDITS DI.
ALOITS match with wording being removed audits that are fully consistent with Paragraph 1 Paragraph I from plant Technical what was in plant Technical Specifications. Tech Specs specify Spectfications. These requirements Audits of operational nuclear safety Audits of operational nuclear safety (as does section 1.2.2c of this contain details not addressed by related activities shall encompass:
related activities are performed by QPD) that NPAD perfoms audits.
10 CFR 50. Appendix 8.
Correction has the NPAD staff under the cognizance no effect on compliance, of Nuclear Performance Specialists.
Tech Specs also required the These audits encompass:
cognizance of the Nuclear Performance Specialists responsible for independent safety review per Appendix C.
g,R: The dif ference in page numbers between Revisions 16 and 171s primarily due to format and type-font changes, not changes in content.
Page 13
m CHANrE MATRIX 6/4/97 (XiAtITY PR0rAAM DESCRIPTION (CPC-?A)
REVISION 17 Item Revision 16 -
Revision 17 Reason for Change Basis for Conclusion 81 APPENDlX E (Page 87)
APPENDIX E (Page 80)
Change made as approved in NRC NRC letter approving this change correspondence dated October 8, indicated the OP0 continues to meet E 3.c. Records of monthly radiation E3.c. Records of quarterly radiation 1996.
the requirements of 10 CFR 20 and exposure for all Individuals exposure for all individuals 10 CFR 50. Appendix B" entering radtation control entering radiation control areas.
areas.
k h
i g: The dif ference in page ntnbers between Revisions 16 and 17 is primarily due to format and type-font changes, not changes in content, Page 14
a
)
3 i
i 1
i ATTACHMENT 3 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 PALISADES PLANT DOCKET 50-255 Revision 18 of CPC-2A 1
)
i l
84 Pages 4
4 o
9707010004 970627 PDR ADOCK 05000155 P
PM r
b
i 0 2 1167 i
Program Description d
l for
\\
Operational Nuclear Power P1-mt.
I l
C:?C 2A 1
i I
EHEEL 2
exx
i e
i n
0" I
m i
I,I l
iii i ii i i - j
(
E Iag gl e e P6USGDES q,
j l
I i
i i
i 4
4 6
4 OfS fvA at'cr>
Mtchsel G. Morris y
t o..
p.
e June 6,1997
SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS ENERGY PROGRAM FOR OPERATIONAL NUCLEAR POWER
[
PLANTS As President and Chief Executive Officer of Consumers Energy, I have the ultimate management c. thority for the Consumers Enerov Quditv Proaram Descriotion for Ooerational Nuclear Power Plants. The Quality Program Description complies with the quality assurance requirements contained in Appendix B of 10 CFR 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the additional guidance contained in ANSI N18.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of applicability imposed by N18.7. The Quality Program Description for Operational Nuclear Power Plants outlines the actions that are implemented during the operational phase including fueling, testing, operation, refueling, procurement, maintenance, repair, and modification design and construction of the safety-related portions of the nuclear power plants.
I have delegated responsibility for establishing, maintaining and implementing the Quality Program Description through the Executive Vice President and Chief Operating Officer-Electric to the Sr. Vice President, Nuclear, Fossil and Hydro Operations. I have delegated selected l
portions of the Quality Program to the Vice President, Electric Transmission and Distribution:
Vice President, Information Technology and Operations Services Division; and through a Vice Chairman of Consumers Energy to the Vice President and Secretary. This Quality Program Description describes the Consumers Energy organizations responsible for implementation.
The Quality Program Description contains mandatory requirements which must be implemented and enforced by all responsible organizations and individuals.
[ud'It 05 l
P:g] ii Rev 18 Date: June 6,1997 1
\\
)
QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS REVISION 18 J
APPROVED BY:
$ SO S?
3 E M ve Vice esiden and Chief Operating Officer Electric Dafte j
David W. Joos h
J 30 97 l
l Sr. Vice P' resident, N' clear, Fossil, and Hydro Operations u
Date Robert A. Fenech M
@f/M93 Vice President, Electric Trannsion and Distribution Date'
~
Carl L. English (br
/
Vice President, Information Technologf and e tions Services Dato Konruth Emery
'W S/30/97
^
Vice Pretident and Secretary
' Date Thomas A. McNish
~...
. ~
J
-i Psgn iii i
Rav 18 Date: June 6,1997 QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS I
CONTENTS i
Section Title g
Statement of Responsibility and Authority i
4 Approval Page ii Contents lii i
1.0 ORGANIZATION
........................................... 1 e
2.0 QUALITY PROGRAM.........
............................ 10 3.0 D E S I G N C O NTR O L.......................................... 14 4.0 PROCUREMENT DOCUMENT CON TROL........................... 17 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS..................... 19
................................... 22 j
6.0 DOCUMENT CONTROL...
i j
7.0 CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICES....... 24 8.0 IDENTIFICATION AND CONTROL OF ITEMS........................ 26 4
9.0 CONTROL OF SPECIAL PROCESSES 27 10.0 I N S P E CTIO N.............................................. 28 11.0 TEST CONTROL
.......................................... 31 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT.................. 33 13.0 HAN DLING, STORAGE AND SHIPPING............................ 35 14.0 INSPECTION, TEST AND OPERATING STATUS...................... 36 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 37 16.0 CORRECTIVE ACTION 39 f
17.0 QUALITY RECORDS..
40 18.0 AU DITS.........
42
,4
.3
Pags iv Rev 18 Date: June 6,1997 APPENDlX A..........
............................ 44 APPENDIX B...
............................ 71 APPENDIX C........
.................. 74 APPENDIX D.......
........................... 77 APPENDlX E 78 FIGURE l
1 Consumers Energy Corporato Organization.........
............. 9 1
i
)
CPC.2 A.R18
Pign 66 Rsv 17 Date: February 1,1997 l.
Exceotion/Interoretation We will maintain documented objective evidence that demonstrates that an individual does have " comparable" or " equivalent" competence to that which would be gained from having the required education and experience. However, this may take the form of documentation other than " procedures and records of written test" such as documentation of oral tests and on the-job performance demonstrations.
13a. N45.2.8, Sec 2.7 Reauirement Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6.
Exceotion/Interoretation See Exception / Interpretation 2j,11a, i.,d 12a. Test personnel who are part of the plant j
staff need not be certified to N45.2.6, pcovided they meet applicable qualification criteria of plant Technical Specifications, i
l 13b. N45.2.8, Sec 2.9
)
i Reautrement l
1 Section 2.9 establishes prerequisites which most be met before the installation, inspection and testing of mechanical equipment may r oceed. These prerequisites include personnel and procedure qualification, control of duign, material selection and fabrication, and availability of specified documents.
Exceotion/Interoretation During the operations phase, this requiremea;is considered to be applicable to modifications of mechanical equipment. For routine or periodic inspection and testing, the prerequisites will be achieved as necessary, l
l 13c. N45.2.8. Sec 2.9e hrement 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, 4
Exceotion/interoretation All of the documents listed are not necessarily required al the plant site for installation and testing. CPCo assures that they are available 12 the site as necessary.
CPC-2A.R17 f
Pago 67 Rav17 Date: February 1,1997 13d. N45.2.8. Sec 2.9e l
Reauirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation, Exceotion/Interoretation Equipment may be installed before final approval of engineering or design changes.
However, the system is not declared operable until such changes are documented and approved.
13e. N45.2.8. Sec 4.5.1 l
Reauirement
" Installed systems and components shall be cleaned, flushed, and conditioned according to the requirements of ANSI N45.2.1 Special attention shall be given to the following requirements:...." (Requirements are given for chemical conditioning, flushing and process controls.)
Exceotion/Interoretation l
Systems and components are cleaned, flushed and conditioned as determined on a case-by.
case basis. Measures are taken to help preclude the need for cleaning, flushing, and conditioning through good practices during maintenance or modification activities.
14a.
N45.2.9, Sec 5.4, item 2 Reauirement Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel cabinets are preferred.
Exceotion/Interoretation i
Records are suitably stored in steel file cabinets or on shelving in containers. Methods other than binders, folders or envelopes (for example, dividers or electronic media) may be used to organize the records for storage.
14b.
N45.2.9. Sec 6.2 l
Reauirement "A list shall be maintained designating those personnel who sbr.ii have access to the files."
CPC-2A.R17
~. - - -
. - ~ - - -... -.
Pzg3 68 Rav17
)
Date: February 1,1997 J
Exceotion/Interoretation i
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 inciude a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or 3
microforms exist for general use and backup.
14c. RG 1.88. C2 Reauirement i
"Two methods of protection of quality assurance records from the hazards of fire are i
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 l
provisions listed in Subdivision 5.6...When NFPA 232-1975 is used, quality assurance records should be classified as NFPA Class 1 records...."
Exceotion/Interoretation CPCo adheres to ANSI N45.2.91974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232 1975 for Class 1 records (usually NFPA Class C,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Class 350).
l 15a. RG l.64. C2 i
i Raouirement "Regardless of their title, individuals performing design verification should not (I) have immediate supervisory responsibility for the individual performing the design...."
Excention/interoretation CPCo follows the requirements of ANSI N45.2.11-1974, Section G 1, and the guidance of I
Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9, herein). This approach is necessary to allow small organizationel units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks.
16a. RG 1.144. Sec C3a(l)
Reauirement This section requires that for operational phase activities, RG l.33 " Quality Assurance Program Requirements (Operations)" are to be followed. One of the RG l.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and CPC-2A.R17
Pags 69 Rsv 17 Date: February 1,1997 occur in facility equipment, structures, systems, or method of Operation are to be audited at least once per six months.
Exceotion/Interoretation See item 3a for the exception to this requirement.
16b. RG 1.144. Sec C3a(2) l Recuiroment 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.
Excention/Interoretation Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.
16c. RG 1.144, Sec C3b(i) l i
Reauirement i
This section identifies procurement contracts which are exempted from being audited, j
Exceotion/Interoretation in addition to the exemptions of RG 1.144, CPCo considers that Authorized Inspection Agencies, NationalInstitute of Standards and Technology or other State and Federal i
Agencies which may provide services to CPCo are not required to be audited.
17a. N45.2.13. Sec 3.2.2 Beauirement N45.2.13 requires that technical requirements be specified in procurement documents bv reference to technical requirement documents. Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.11.
Excention/interoretation For replacement parts and materials", CPCo follows ANSI N;8.7, Section 5.2.13, Subitem I, which states: "Where the original item or part is found to be commercially 'off the shelf' or without specifically identified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance."
CPC-2A.R17
~. _ - -.
Pzga 70 Rsv 17 Date: February 1,1997 1
4 l 17b.
N45.2.13. Sec 3.2.3 Reauirement
" Procurement documents shall require that the supplier have a documented quality assurance program that implements portions all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards."
Exceotion/Interoretation Refer to item 21.
l 17c. [145.2.13. Sec 3.3(a)
Reauirement Reviews of procurement documents shall be performed prior to release for bid and contract 3
award.
Excention/Interoretation a
Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is put into service or beforo work has progressed beyond the point where it would be impractical to reverse the action taken.
l 17d. N45.2.13. Sec 3.3(b)
Reauirement
" 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."
Excention/Interoretation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems I through 5.) The timing of reviews will be the same as for review of the original procurement document.
l 170. N45.2.13. Sec 7.5 Reauirement
" Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as applicable."
CPC-2A.R17
P. ga 71 Rrv 17 Date: February 1,1997 Excention/Interotetation Consumers Power qualifies audit personnel according to N45.2.23. Thus, personnel performing source verification audits may not be certified according to N45.2.6. Personnel performing inspection as part of -ource verification will be certified to N45.2.6 or qualified in allowance with Paragraph 10.;
However, personnel performing source surveillances may not be certified to any of those requirements.
17f.
N45.2.13. Sec 10.1 l
Reauirement "Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods."
Exceotion/InterDretation Refer to item 2m.
17g. N45.2.13. Sec 10.3.4 (as modified by RG 1.123, C6e) l Reauirement
" Post-installation test requirements and acceptance documentation shall be mutually established by the p;rchaser and supplier."
Exceotion/Interoretatnn in exercising its ultimata responsibility for its quality program, CPCo establishes post-installation test requirements, giving due consideration to supplier recommendations.
18a. RG I.26. General Recuirement RG l.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are not.)
Exceotion/Interoretation RG l.26 was used as a reference to establish piping system boundaries, but not for defining specific quality grcups or making safety-related determinations. Regulatory Guide 1.29, subject to Ecarf.on/ interpretation 20a, is used to determine what systems and equipment included in the Quality Program.
CPC-2A.R17
Pagn 72 Rsv 17 Date: February 1,1997 19a. Branch Technical Position AS89.5.1 and 10 CFR SO Accendix R.
Sections lli G. ll1 J. and lli O, General Exceotion/Interoretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 Appendix R except for the specific exemptions approved by the NRC.
20a. RG 1.29. Sec C, Regulatory Position Reauirement The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category I and should be designed to withstand the SSE.
Exceotion/Interoretation Both CPCo nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on crituria available prior to Revision 3 of this Regulatory Guide being issued.
The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respectively, and in other docketed analysis. Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.,
The criteria of this Regulatory Guide are used at CPCo primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 20b, below).
20b. RG l.29. General Recuirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B.
I Exceotion/Interoretation The pertinent quality requirements for these systems, structures and components will be l
determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.
21.
ANSI /ANS 3.1 -1987 Execotion/interoretation The commitment to ANSI /ANS 3.1-1937 is limited to requirments that apply to persons performing the independent safety review function as specified in Appendix C to this QPD.
l CPC 2A.R17
)
Paga 73 Rrv 17 Date: February 1,1997 t
I QPD MANUAL l
APPENDIX B PLANT REVIEW COMMITTEE (PRC) l B1.
FUNCTION l
The Plant Review Committee (PRC) shall function to advise the Plant General l
Manager / Manager on all matters related to nuclear safety.
82.
COMPOSITION The Palisades PRC is composed of nine regular members. The qualification level for PRC members shall be at least equivalent to those described in Section 4.4 of ANSI N 18.1 -1971. The PRC shallinclude representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Plant General Manager.
The Big Rock Point PRC is composed of nine regular members from the Big Rock Point staff.
The PRC members shall meet or exceed the minimum qualifications described in Sections 4.2 and 4.4 of ANSI N18.1 1971 for comparable positions. The PRC shallinclude representatives from the Operations, Chemistry / Health Physics, Maintenance, Engineering, and Safety and Licensing Departments. The member shall be designated in administrative procedures by the Plant Manager who is the Chairman of the PRC. The Plant Manager shall also designate an Alternate Chairman in writing.
)
B3.
ALTERNATES l
Alternate members of the PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis. No more than two alternated shall participate as voting members at any one time in PRC activities.
B4, MEETING FREQUENCY The PRC shall meet at least once per calendar month with special meetings as required.
85.
QUORUM A quorum of the Palisades PRC shall consist of the Chairman or alternate and four members or alternates. A quorum of the Big Rock Point PRC shall consist of the Chairman or alternate Chairman and four members or alternates.
CPC-2A.R17
m_
a Pags 74 Rav 17 Date: February 1,1997 B6.
RESPONSIBILITIES
.The PRC shall be responsible for nuclear safety review of:
)
l l a.-
All procedures and programs specified by the Technical Specifications and changes l
thereto, and any other procedures or changes thereto as determined by the Plant General Manager / Manager to affect nuclear safety; all proposed tests or experiments that affect nuclear safety; all proposed changes or modifications to plant systems or
. equipment that af'ect nuclear safety, b.
All proposed changes to Operating License and Technical Specifications, c.
Results of investigations of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and recommendations to prevent recurrence and
~
be forwarded to the Vice President - NOD and to the Manager, Nuclear Performance Assessment Department (NPAD)).
d.
Plant operations to detect potential safety hazards, e.
Reports of special reviews and investigations as requested by the Plant General Manager / Manager or NPAD.
f.
Site Emergency Plan and implementing procedures, g.
All reportable events as defined in 10 CFR 50.72 and 50.73.
l h.
All items identified under 89.3 below as significant to nuclear safety (Palisades only).
l.
Monthly reports from Safety / Design Review (Palisades only).
j.
Nuclear industry operating experience.
k.
~ Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Plant Manager and to the Manager, Nuclear Performance Assessment Department (Big Rock Point only).
PRC review of the above items may be performed by routing, subject to the requirements of B7. below. The Palisades PRC may delegate review of item a. to Safety / Design Review staff, as described in B9. below.
4 CPC-2A.R17
~
~
Pags 75 Risv 17 Date: February 1,1997 i
B7.
AUTHORITY l
The PRC shall:
l a.
Recommend in writing to the Plant General Manager / Manager approval or disapproval j
I of items considered under BB.a. through j. above.
l
)
l b.
Render determinations in writing with regard to whether or not each item considered under B6.a, b, c, f (Palisades only) and h above constitt.tes an unreviewed safety l
question.
c.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President Nuclear Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC and the Plant General Manager / Manager; however, the Plant General Manager / Manager shall have responsibility for the resolution of such disagreements.
The PRC Chairman may recommend to the Plant General Manager / Manager approval of those items identified in B6. above based on a routing review provided the following conditions are met: (1) at least five PRC members including the Chairman and no more than 2 alternates, shall review the item, concur with determination as to whether or not the item constitutes an unreviewed safety question, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the PRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers for additional comments.
The item shall be reviewed at a PRC meeting in the event that: (1) Comments are not resolved; or (2) the Plant General Manager / Manager overrides the recommendations of the PRC; or (3) a proposed change to the Technical Specifications involves a safety limit, a limiting safety system setting or a limiting condition for operation; or (4) the item was reportable to the NRC.
88.
RECORDS The PRC shall maintain written minutes of each PRC meeting and shall provide copies for independent Safety Review.
89.
TECHNICAL SUPPORT FOR PAllSADES PRC The Safety / Design Review organization shall function to examine proposed changes in dc::;rn or operation and such other matters as the Palisades PRC may assign to identify issu.ss significant to nuclear safety and recommend nuclear safety improvements.
B9.1 The Safety / Design staff responsible for tha review tunction shall be an experienced l
technical staff meeting the qualifications of Technical Specifications, B9.2 The Safety / Design Review staff may provide nuclear safety review as delegated by l
Palisades PRC for:
l t
CPC-2A.R17
Pign 76 Rav17 Date: February 1,1997 Procedures, programs and changes thereto identified in the Technical Specifications a.
1 and any additional procedures and changes thereto identified by the Plant General Manager / Manager as significant to nuclear safety.
i b.
All proposed tests or experiments.
c.
All proposed changes or modifications to plant systems or equipment.
Q d.
The Site Emergency Plan and implementing procedures.
l 89.3 The Safety / Design Review staff shall determine thoso issues significant to nuclear safety which require review by the Palisades Plant Review Committee from items considered under l
l 89.2a. through d. above. For those items not referred to PRC, Safety / Design Review shall recommend in writing to plant management approval or disapproval of items considered l
under B9.2.
l 89.4 Reports of Safety / Design Review activities pursuant to B9 shall be submitted monthly to PRC.
1 i
l i
1 i
i i
1 i
CPC 2A.R17
=
_ -_ _ _ ~ --.
. -.. ~ =
- - _ -.. ~. - -
Y Piga 77 Rsv 17 i
Date: February 1,1997 QPD MANUAL l
APPENDlX C INDEPENDENT SAFETY REVIEW t
The following exceptions / interpretations in Appendix A, Part 2, are relevant to i
implementation of the requirements of this section of the QPD:
Anoendix C Excentions/InterDretations 2c, 2d, 2e, 2f, 21 C1.
FUNCTION The Independent Safety Review Group (ISRG) shall function to provide independent review of activities in the areas of:
a.
Nuclear power plant operation b.
Nuclear engineering c.
Chemistry and radiochemistry d.
Metallurgy e.
Nondestructive testing f.
Instrumentation and control g.
Radiological safety h.
Mechanical and electrical engineering 1.
Administrative controls and quality assurance practices 1
Emergency Planning
, k.
Training C2.
COMPOSITION The ISRG shall include the Manager, NPAD, who reports to the Vice President - NOD, and a full-time staff of persons reporting to the Manager, NPAD and designated as Nuclear Performance Specialists for the ISR function. The Manager, NPAD, and the Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4.7 of ANSI /ANS 3.1-1987. The ISRG shall have no direct responsibility for activities subject to its review, C3.
CONSULTANTS If sufficient expertise is not available within the l'RG to review particular issues, the ISRG shall have the authority to utilize consultants or other qualified organizations for expert advice.
C4.
RESPONSIBILITIES C4.1 SEY_lEW l
l The ISRG shall review:
CPC 2A.R17 l
Paga 78 Rav17 Date: February 1,1997 l
The safety evaluations for: 1) changes to procedures, equipment or systems, and 2) a.
tests for experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety question, b.
Proposed changes to procedures, equipment or systems which involve an unreviewed j
safety question as defined in 10 CFR 50.59.
j c,
Praposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59.
d.
Proposed changes to Technical Specifications or the Operating License.
Violations of codes, regulations, orders, Technical Specifications, license requirements, e.
or of intern 61 procedures or instructions having nuclear safety significance, f.
Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affects nuclear safety.
g.
All reportable events having nuclear safety significance.
h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation cf structures, systems, or components that could affect nuclear safety, l.
Reports and meeting minutes of the Plant Review Committee.
t j.
Fire Protection Program and Implementing Procedure Changes (Palisades only).
k.
Reports of audits performed as specified in Appendix D.
l ISRG review of the subjects in C4 above shall be performed by an assigned Nuclear Performance Spscialist selected on the basis of technical expertise relative to the subject being reviewed. If the assigned Nuclear Performance Specialist determines the need for interdisciplinary review, a committee consisting of the Manager, NPAD, or his designate, and at least four Nuclear Performance Specialists, shall be assigned. Such committee shall meet as conditions requiring interdisciplinary review arise, but no less than twice yearly.
l C5 AUTHORITY The ISRG shai! report to and advise the Vice President, NOD, of significant findings l
associated with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.
l C6 RECORDS Records of ISRG activities shall be maintained. Reports shall be prepared and distributed as indicated below:
l a.
The results of reviews performed pursuant to C4 above shall be reported to the Vice-President, NOD, at least monthly.
CPC-2A.R17
..-. _..~.-,-. - -...-... ~...... ~.__..-.
-.... -.. - - - - -. ~.. -.......
1)
I Pag 3 79 RIy17 Date: February 1,1997 i
i-b.
A report assessing each plant's overall nuclear safety performance shall be provided to l'
i senior Consumers Power Company management annually, s
7 4,
i b
i-1-
1' f
n s
. 4 t
l i
4 1
- j.
4 4
4 4
1 J
1 1
i
~1 r
4 5
i CPC 2A.R17
l Pigs 79 Rsv 17 Date: February 1,1997 1
QPD MANUAL APPENDIX D AUDIT FREQUENCIES D 1.
AUDITS j.
Audits of operational nuclear safety related activities are performed by the NPAD staff under the cognizance of Nuclear Performance Specialists. These audits encompass:
a.
The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months, b.
The performance, training and qualifications of the entire facility staff at least once per 12 months.
c.
The performance of activities requirad by the Quality Program Description for Operational Nuclear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50,.
Appendix B at least once per 24 months, d.
The Site Emergency Plan and implementing procedures at least once per 12 months.
e.
The Site Security Plan and implementing procedures (as required by the Site Security
= Plan) at least once per 12 months.
f.
Any other area of plant operation considered appropriate by NPAD or the Vice President - Nuclear Operations.
g.
Thh plant Fire Protection Program and implementing procedures at least once per 24 months.
h.
An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
l.
An inspection and audit of the fire protection and loss prevention program to be l
performed by an outside qualified fire consultant at intervals no greater than 3 years.
j.
Radiological environmental monitoring program and the results thereof at least onte per 12 months.
k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
l.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
Audit reports encompassed by D1. above shall be forwarded to the Manager lNPAD, and Management positions responsible for the areas audited within thirty (30) days after l
. completion of the audit.
l l
CPC 2A.R17
.~
1 Pigs 80 Rsv 17 Date: February 1,1997 i
QPD MANUAL APPENDIX E RECORD RETENTION 4
E1.
In addition to the applicable record retention requirements of Title 10, Code of Federal l
Regulations, the following records shall be retained for at least the minimum period indicated:
}
E2, The following records shall be retained for at least five years:
Records and logs of facility operation covering time interval at each power level.
a.
b.
Records and logs of principal maintenance activities, inspections, repair and i
replacement of principalitems of equipment related to nuclear safety.
E c.
All reportable events as defined in 10 CFR 50.72 and 50.73.
j d.
Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications.
1-e.
Records of changes made to the procedures required by Plant Technical Specifications.
f.
Records of radioactive shipments.
1 g.
Records of sealed source leak tests and results.
j h.
Records of annual physicalinventory of all source material of record.
E3, The following records shall be retained for the duration of the Facility Operating License:
a.
Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Palisades Final Safety Analysis Report or Big Rock Point Final Hazards Summary Report.
b.
Records of new and irradiated fuelinventory, fuel transfers and assembly burnup histories, j
a l
c.
Records of quarterly radiation exposure for allindividuals entering radiation control areas.
d.
Records of gaseous and liquid radioactive material released to the environs.
s e.
Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles.
f.
Records of inservice inspections performed pursuant to Plant Technical Specifications.
I g.
Records of Quality Assurance activities required by the Quality Program Description.
4 i
i CPC 2A.R17 0
_ ~
_ ~ ~ - - -.. -. _ _ - - _ =. _ ~
A j
Piga 81 Rev 17 Date: February 1,1997 1
1 h.
Records of reviews performed for changes made to procedures or equipment or reviews of tests end experiments pursuant to 10 CFR 50.59.
4 i
1.
Records of meetings of the PRC and reviews performed by NPAD according to
{
Appendix C, 1
j.
Records of monthly facility radiation and contamination surveys.
k.
Records of secondary water sampling and quality (Palisades only).
l.
Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specificetions. This shallinclude the date at which the service life commences and associated installation and maintenance records (Palisades only).
Records for environmental qualifications which are covered under the provisions of 10 m.
1 CFR 50.49 (Big Rock Point only).
- n. f Records of training and qualifications for members of the plant staff.
o.
Records of reactor tests and experiments.
p.
Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM (Palisades only).
l 1
f 1
4 CPC 2A.R17
1 l
1 i
l ATTACHMENT 2 i
I
(
CONSUMERS ENERGY COMPANY j
BIG ROCK POINT PLANT DOCKET 50-155 l
PALISADES PLANT DOCKET 50-255 CPC-2A, Revision 17 Change Matrix l
I i
1 l
1 l
l 1
I I
i i
l l
l t
14 Pages 1
I i
C@rf MTRIX 6/4/97 GUALITY PROGRAN DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 ReasonforCp Basis for Conclusion 1
1.1 (Page 1) 1.1 (Page 1)
This section added to make clearer This chance does not affect content, connection for users to the thus the OPD continues to meet (Not in Revision 16)
Ad&d Paragraph 4 Exceptions / Interpretations in 10 GR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
2 1.2.2.a.
1.2.2.a. (Page 3)
These responsibilities were This change does not affect content.
formerly in Nuclear Services and thus t'e OPD cont 1rp:es to meet (Not in Revision 16)
Added Subparagraphs 16 and 18.
were transferred to the Plant 10 CR 50. Appendix 8.
Manager 3
1.2.2.b. (? age 5) 1.2.2.b. (Page 4)
Change in terminology from " risk" This change does not af fect content.
Paragraph 20 Subparagraph 19 to " safety" to be consistent with thus the QPD continues to meet Industry usage.
10 CFR 50. Appendix B.
Development and utilization of Development and utilization of nuclear plant probabilistic risk nuclear plant probabilistic safety assessment models to evaluate safety assessment models to evaluate safety and plant reliabilfly improvement.
and plant reliability improvement.
4 1.2.3.a. (Page 8) 1.2.3.a. (Page 7)
Change reflects elimination of FMS is not an organization or function Field Maintenance Services group required by 10 Cf# S0. Appendix B.
The The Manager. Equipment Services &
The Manager. Equipment Services fra this organization. and name Site Vice President or Plant General field M-*tenance Services provides provides electrical. rotating and change of unit. Maintenance Manager retain responsibility for. and electriu l, rotating and stationary stationary equipment expertise, services (personnel) may still be control cf. maintenance performed in equipment expertise and provides including developing and qualifying provided by Consm ers Energy repair support of nuclear plant operations.
field maintenance services for procedures for welding and heat crms from other pwer pla-ts.
Thus. the QPD continues to meet assigned modification and treating.
requirements of Criterion I for a maintenance tasks. This includes description of organizations that developing and qualifying procedures implement the quality program.
for welding and heat treating.
5 1.2.3.b. (Page 8) 1.2.3.b. (Page 7) 1.
Department name change.
This change does not alter the nature 2.
Clarifies that Big Rock of the Records Management System. The The Manager. Projects. Engineering The Director. Fuel Supply & Plant maintains its om safeguards QPD continues to s.eet the reptrements and Construction, maintains the Operations maintains the Records information and is responsible of Criterion I for a description of the Records Management System including Management System including required for doc ment quality, organizations that implement the required retention. protection and retention. protection and program.
retrievability. This includes retrievability. This includes collecting. storing. maintatning.
collecting storing. maintaining.
distributing and controlling plant distributing and controlling plant engineering / design doc ments (Big engineering / design doc ments (Big Rock only).
Rock only). This excl e Big Rock Safeguards information duc ments.
which are maintained at Big Rock.
The accuracy. quality and correctness of Big Rock documents in the Records Management System are the responsibility of Big Rock Point.
!QE: The difference in page numbers between Revisions 16 and 17 is primarily due te format and type-font changes. not changes in content.
Pagt I
CHANGE MATRIX 6/4/97 00ALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 6
1.2.4.a. (Page 9) 1.2.4.a. (Page 8)
Organization name changes only.
This chan does not affect content.
thus the continues to meet The Manager. Transmission Energy The Manager. Electric System 10 CFR 50. Arp m dix B.
Delivery (see Figure 1) is Operations (see Figure 1) is responsible through the Vice responsible through the Vice President. Electric Transmission to President. Electric Transmission and the Executive Vice President and Distribution to the Executive Vice Chief Operating Officer - Electric President and Chief Operating for determining settings for Officer - Electric for determining electrical protective systems and settings for electrical protective relay control schemes. and for systems and relay control schemes, design. review and recommending and for design. revi m and changes to electrical protective recommending changes to electrical schemes and associated settings.
protective schemes and associated settings.
7 1.2.4.b. (Page 9) 1.2.4.b. (Page 8)
Organization name change only.
This chance does not affect content.
thusthe6PDcontinuestomeet The Executive Manager. Electric The Director. Electric Employee 10 CFR 50. Appendix B.
Business Support (see Figure 1) is Development (see Floure 1) is responsible to the Executive Vice responsible to the (xecutive Vice President and Chlef Operating President and Chief Operating Officer - Electric for operating the Officer - Electric for operating the Skill Centers including the Sk111 Centers including the training.
training. and qualifying of and qualifying of personnel and personnel and equipment for welding equipment for welding operations.
operations.
8 1.2.4.e. (Page 10) 1.2.4.e. (Page 9)
Organization name changes only.
This change does not affect content, thus the QPD continues to meet The Manager. Transmission Order The Manager. Electric Services is 10 CFR 50. Appendix B.
Fulfillment is responsible. through responsible. through the Vice the Vice President. Electric President. Electric Transmission and Transmission to the Executive Vice Distribution to the Executive Vice President and Chief Operating President and Chief Operating Officer - Electric for testing and Officer - Electric for testing and maintaining electrical protective maintaining electrical protective devices. performing design devices, performing design vcrification testing associated with verification testing associated with electrical protective schemes, electrical protective schemes, devices and application of devices and application of associated associated settings.
settings.
N_0T : The difference in page nunbers between Revisions 16 and 17 is primarily due to format and type-font changes, not changes in content.
J Page 2
C MNGE MATRIX 6/4/97 OUALITV PROGRM DESCRIPTION (CPC-2A)
REVISION 17 Iten Revision 16 Revision 17 Reason for Change Basis for Conclusion 9
2.1 (Page 13) 2.1 (Page 12)
Corrected reference to plant Addition of Appendix C adds Paragraph 3 Paragraph 3 Technical Specifications that requirements to the 000. but these are should have been changed. with not based on 10 CFR 50. Appendix B.
Quality Program status, scope.-
Quality Program status, scooe.
Revision 16. to Appendix C.
Thus the Or0 continues to meet adequacy and cmpliance with adequacy and cmpliance with Addition of Appendix C was made to 10 CTR 50 requirements.
10 CfR 50. Appendix B are regularly 10 CFR 50. Appendix B are regularly support removal of same material reviewed by CPCo Management through revi sed by CPCo Management through from Technical Specifications.
reports meetings and review of reports. meetings and revis of audit audit results. A preplanned and results. A preplanned and documented documented assessment of the nuclear assessment of the nuclear safety safety perfomance is conducted as performance is conducted as described d
described in Technical in Appendix C.
Specifications.
g-10 2.1 (Page 13) 2.1 (Page 12)
This section added to make clearer This chance does not affect content, connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 4 and 5.
Excepthns/ Interpretations in 10 CFR 50. Appendix B.
pendix A. Part 2. that relate to
{
e subject of this section.
11 2.2.6.c. (Page 15) 2.2.6.c. (Page 14)
Change in terminology frm " risk
- This change does not affect content.
to " safety
- to be consistent with thus the QPD continues to meet The extent to which controls The exted to which controls industry usage.
10 CFR 50. Appendix 8.
specified in the Quality Program are specified u the Quality Program are applied to items is determined for applied tc iter.s is determined for each item considering its relative each item considering its relative importance to safety. Such importance to safety. Such determinations are based on data in determinations are based on data in such doctnents as the plant risk such doctnents as the plant safety analysis. plant Technical analysis, plant Technical Specifications and the FSAR/FHSR Specifications and the FSAR/FHSR (See (See Appendix A).
Appendix A).
12 2.2.10.b. (Page 17) 2.2.10.b. (Page 15)
Corrected refererce to p! ant Addition of Appendix C adds Techni;al Spec ficattms thtt requirements to the OPD. but these are Management teams assess the nuclear Managen... teams assess the nuclear shou 1C have beei ch a ged with not based on 10 CFR 50. Appendix B.
safety performance as described in safety perfo-mance as described in Revision 16. tc Wadix 0 Thus the OPD continues to meet the lachnical Specifications.
Appendix C.
Conclusions and Addition t,i 44en6% C 'n. :=ade to 10 CFR 50 requirements.
Conclusions and recommendations are recommendations are reported to the support remova Sf s e m e:'ai reported to the Executive Vice Executive Vice President and Chief from Technical '
., a tions.
President and Chief Operating Operating Officer - Electric.
Of ficer - Electric.
13 3.1 (Page 18) 3.1 (Page 16)
This section added to make clearer This change does not affect content.
connection for users to the thus tt.e OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix P.
Appendix A. Part 2. that relate to the subject of this section.
MK: The different.* in page numbers between Revisions 16 and 1715 primarily due to fomat and type-font changes, not changes in content.
Page 3
. - -.. ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
r CHANGE tMTRIX 6/4/97 OJALITY PROGRAM DESCRIPTION (CPC T f
REVISION 17 7
i t
I Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 14 4.1 (Page 22) 4.1 (Page 19)
This section added to make clearer This change does not affect content.
4 connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
r pdix A. Part 2. that relate to r
tne subject of this section.
15 5.1 (Page 24) 5.1 (Page 21)
This section added to make clearer This change does not affect content, connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations %
10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
j 16 6.1 (Page 27) 6.1 (Page 24)
Change made to provide more exact The QPD provides controls over docuent Paragraph 1 Paragraph I match with wording being rmoved preparation, review, approval and use from plant Technical that continue to be consistent with Documents controlling safety-related Documents controlling safety-related Specifications.
- Prior to Criterton VI of 10 CFR 50. Appendix B.
activities within the scupe defined activities within the scope defined implementation
- was always required The change enhances the clarity of
+
in Section 2.0. QUALITY PROGRAM are in Section 2.0. QUALITY PROGRAM are by 6.2.4.2. but this change these requirements.
issued and changed according to issued and changed according to clarifted the requirement in this established procedures. Docments established procedures. Documents section.
such as instructions procedures and such as instructions. procedures and drawings. including changes thereto.
drawings. including changes thereto.
are reviewed for adequacy. approved are reviewed for adequacy, approved for release by authorized personnel" for release prior to implementation and are distributed and uSed at the by authorized personnel and are location where a prescribed activity distributed and used at the location 1s performed.
d ere a prescribed activity is performed.
i 17 6.1.1 (*)(Page 27) 6.1.1 (*) (Page 24)
Change made to provide more exact The QPD provides controls over doc uent match with wording being removed preparation, revi s. approval and use For Palisades, an appropriate senior For Palisades, an appropriate senior from plant Technical that continue to be consistent with department manager. based on the department manager, based on the Specifications.
Criterion VI of 10 CFR 50. Appendix B.
activities addressed In'the specific activities addressed in the specific The change enhances the clarity of I
procedure. designated in writing by procedure. predesignated in writing these requirements, the Plant General Manager; or.
by the Plant General Manager: or,.
j 18 6.1 (Page 27) 6.1 (Page 24)
This section added to mate clearer This change does not affect content.
connection for users M. the thus the QPD continues to meet y
(Not in Revision 16)
Added Paragraph 4.
Exceptions /Interpr. cations in 10 CFR 50. Appendix B.
[
3 Appendix A. Part I, that relate to the subject of th1' section.
19 7.1 (Page 29) 7.1 (Page 26)
This section added to make clearer This chan does not affect content.
I
' connection for users to the thus the continues to meet i
(Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
t Appendix A. Part 2. that relate to the subject of this section, f
F i
!OTE: The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
i Page 4 4
CHAGE MATRIX 6/4/97 (MLITY DROGRNi DESCRIPTION (CPC-2A)
REVISION 17 Item-Revision 16 Restsioc U Reason for Change Basis for Conclusion 20 8.1 (Page 32) 8.1 (Page 29)
This section added to make clearer This cha e does not affect content.
connection for users to the thus the continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
l Appendix A. Part 2. that relate to I
the subject of this section.
21 9.1 (Page 33) 9.1 (Page 30)
This section adden to make cleare-This change does not affect content.
connection for users G: ine thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptimis/ Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
22 10.1 (Page 34) 10.1 (Page 31)
This section added to make clearer This change does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
23 10.2.3 (Page 35) 10.2.3 (Page 32)
Organization name change only. No This change does not affect content.
Paragraph 1 Paragraph I change in requirements.
thus the QPD continues to meet 10 CFR 50. Appendix B.
...for activities performed at
...for activities p v formed at Paltsades that are under the Palisades that are ondar the cognizance of Nuclear Engineering cognizance of Nuchar Services, the and Construction. the Manager.
Manager. Nucle", Projects and Nuclear Engineering and Construction Construction is responsible for is responsible for review and review and concurrence of such concurrence of uch programs.
programs.
24 11.1 (Page 37) 11.1 (Page 34)
This section added to make clearer This change does not affect content.
connection for users to the thus the OPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
25 12.1 (Page 39) 12.1 (Page 36)
This section added to make clearer This change does not affect contmt.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
26 13.1 (Page 41) 13.1 (Page 38)
This section added to make clearer This change does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to the subject of this section.
M: The dif ference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
Page 5
J CMGE MTRIX 6/4/97 O!AtITY PROGRAM DESCRIPTION (CPC-?A) f REVISION 17 L
Iten Revision 16 Revision 17 Reason for Change Basis for Conclusion
[
I 27 14.1 (Page 42) 14.1 (Page 39)
This section added to make clearer This change does not affect content.
connection for users to the thus the QPD continues to meet (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A.' Part 2. that relate to the s @ ject of this section.
28 15.1 (Page 43) 15.1 (Page 40)
This section added to make clearer This change does not affect contmt, h
connection for usars to the thus the QPD continues to meet l
(Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to tne seject of this section.
29 17.1 (Page 46) 17.1 (Page 43)
This section added to make clearer This change does ovi. iect content, connection for users to the thus the QPD continues to meet I
(Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50 Appendix B.
ApperJ1x A. Part 2. that relate to i
Ene subject of this section.
t 30 18.1 (Page 48) 18.1 (Page 45)
This section added to make clearer This change does not affect content.
[
connection for users to the thus the QPD continues to meet' (Not in Revision 16)
Added Paragraph 2.
Exceptions / Interpretations in 10 CFR 50. Appendix B.
Appendix A. Part 2. that relate to i
tne subject of this section, f
31 APPENDIX A. Part 1 (Page 51)
APPENDIX A. Part 1 (Page 48)
Commitment added as part of This change adds a ccamitment for
}
transfer of material from plant personnel qualifications for the (Not in Revision 16)
- 22. ANSI /ANS 3.1-1987. Selection.
Technical SpM1fications independent revis function that Qualification. and Training of (Appendix C in this 000) regarding previously existed in plant Technical Personnel for Nuclear Power qualifications of independent Specifications. The change enhances Plants application limited as reviewers in NPAD.
comp 11ance with Criterion II of described in Appendix C of this 10 CFR 50. Appendix B.
t document.
32 APPENDIX A. Part 2 (Page 55)
APPENDIX A. Part 2 (Page 52)
Change made to provide more exact The QPD now provides controls over 2h. Sec 5.2.2 2h. N18.7. Sec 5.2.2 match with temporary change wording temporary changes to procedures that Exception / Interpretation Exception / Interpretation betn removed from plant Technical are fully consistent with d at was in
'j Paragraph 1 Paragraph 1 Spec fications. Tech Specs plant Technical Specifications. The currently allow te.mporary changes OPD continues to meet Criteria V and VI i
CPCo considers that this requirement CPCo considers that this requirement to security and E Plan procedures -
of 10 CFR 50. Appendix 8.
t applies only to procedures applies only to procedures identified previous CPC-2A wording did not Identified in plant technical in Plant Technical Specifications and (this will be removed from Tech t
spec *fications. Temporary changes to Security and Emergency Plans Specs in favor of CPC-2A).
to these procedures may be made implementing procedures. Temporary provided:
changes to these procedures may be made provided:.
[
i l
N_DK: The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
l Page 6 4
t a
CHANGE fGTRIX 6/4/97 OIALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change
' asis for Conclusion 33 APPENDIX A. Part 2 (Page 61)
APPENDIX A. Part 2 (Page 57)
This (.hange restores the This chang' restores the clarity of the 4a. ANS 3.1. 6eneral 44.
ANS 3.1. General clarification of applicability of commitment to the draft standard, and.
Exception / Interpretation Exception / Interpretation this commitment to that originally in so doinc. assures t. hat persons Paragraph 1 Paragraph 1 Intended. Recent revisions had performing independent quality implied the commitment was non-assurance functions will be trained and Lead auditors are trained and The commitment to ANS 3.1 (12/79.
relevant to any <Iroup. but this was qualif ted so as to meet Criterion 11 of qualified to Regulatory Guide 1.146.
draft) is limited to the requirements never intended. The wording in 10 CFR 50. Appendix B.
All other personnel are trained and that apply to the training and Revision 11 and 12 of this QPD. as i
qualtfled as designated in the plant qualification of persons performing combined herein. more appr@riately Technical Specifications.
Independent quality assurance convey the intended nature of this functions. except for Lead Auditors.
Commitment.
Lead auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI 45.2.23-1978. Othar personnel are trained and quellfied as designated in plant Technical Specifications.
34 APPENDIX A. Part 2 (Page 61)
APPENDIX A. Part 2 (Page 58)
This change restores the This change restores the clarity of the Sa. RG 1.8. C.3.1. General Sa. RG 1.8. C.3.1. General clarification of applicability of commitment to the draft Regulatory Exception / Interpretation Exception /Interpretar.lon this commitment to that originally Guide, and. In so doing. assures that Paragraph 1 Paragraph 1 intended. Recent revisions had persons performing independent quality implied the commitment was non-assurance functions will be trained and Lead auditors are trained and The commitment to Regulatory relevant to any group. but this was qualified so as to meet Criterton II of qualified to Regulatory Guide 1.146.
Guide 1.8 (9/80. draf t) is limited to never intended. The wording in 10 CFR 50. Appendix B.
All other personnel are trained and the requirements that apply to the Revision 11 and 12 of this QPD. as qualified as designated in the plant training and qualification of persons combined herein. more appropriately Technical Specifications.
performing independent quality convey the intended nature of this assurance functions, exCept fOr lead Commitment.
Auditors. Lead Auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Spectfications.
35 APPENDIX A. Part 2 (Page 63)
APPENDIX A. Part 2 (Page 59)
Editorial change - added the Abi This change does not affect content.
standard n eber.
thus the OPD continues to meet 6c. Sec 5 6c. N45.2.1. Sec 5 10 CFR 50. Appendix B.
36 APPENDIX A. Part 2 (Page 63)
APPENDIX A. Part 2 (Page 60)
Editorial change - added the AMI This change does not affect centent.
standard number.
thus the QPD continues to meet 7b. Sec 2.4 7b.
N45.2.2. Sec 2.4 10 CFR 50. Appendix B.
37 APPENDIX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page 60)
Editorial change - added the ANSI This change does not affect content, standard number.
thus the QPD continues to meet 7c. Sec 3.4.1 and Appendix A.
7c.
N45.2.2. Sec 3.4.1 and 10 CFR 50. Appendix B.
3.4.1(4) and (5)
Appendix A. 3.4.1(4) and (5) tKO.TD
.he dif ference in page nebers between Revisions 16 and 17 is primarily due to format and type-font changes, not changes in content.
Page 7
CHANGE MATRIX 6/4/97
[
OIALITY PROGRAM DESCRIPTION (CPC-2A)
PEYlSIDN 17 Item Revision 16 Revision 17 Reason for Change Basis for' Conclusion
.[
38 APPENDIX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page 60)
Editorial change - added the ANSI This ch
'does not affect content.
standard number.
thus the continues to meet 7d. Sec 3.9 and Appendix A. 3.9 7d.
N45.2.2. Sec 3.9 and Appendix A.
10 CFR 50. Appendix B.
_[
3.9
?
39 APPENDIX A. Part 2 (Page 64)
APPENDIX A. Part 2 (Page il)
Editorial change - added the ANSI This chan does not affect content.
I standard number.
.thus the continues to meet 7e. Sec 5.2.2 7e.
N45.2.2. Sec 5.2.2 10 CFR 50. Appendix B.
I 40 APPENDIX A. Part 2 (Page 65)
APPENDIX A. Part 2 (Page 61)
Editorial change - added the ANSI This change does not affect content, f
standard number.
thus the QPD continues to meet t
7 f.
Sec 6.2.4 7f. N45.2.2. Sec 6.2.4 10 CFR 50. Appendix B.
[
F 41 APPENDIX 1. Part 2 (Page 65)
APPENDIX A. Part 2 (Page 61)
Editorial change - added the ANSI This change does not affect content.
standard ntaber, thus the OPD continues to meet t
4 79 Sec 6.3.4 7g. N45.2.2. Sec 6.3.4 10 CFR 50. Appendix B.
{
t 42 APPENDIX A. Part 2 (Page 65)
APPENDIX A. Part 2 (Page 61)
Editorial change - added the ANSI lhts change does not a'fect content; standard ntaber.
thus the OPD continues to meet 7h. Sec 6.4.1 7h. N45.2.2. Sec 6.4.1 10 CFR 50. Appendix B.
43 APPENDIX A. Part 2 (Page 66)
APPENDIX A. Part 2 (Page 62)
Editorial change - added the ANSI This chan does not affect content.
standard number.
thus th continues to meet 9b. Sec 2.2(5) 9b. N45.2.4. Sec 2.2(5) 10 CFR 50. Appendix B.
f j
44 APPENDIX A. Part 2 (Page 67)
APPENDIX A. Part 2 (Page 63)
Editorial change - added the ANSI This chan does not affect content, standard ntaber.
thus the continues to meet 9c. Sec 6.2.1 9c. N45.2.4. Sec 6.2.1 10 CFR 50. Appendix B.
l 45 APPENDIX A. Part 2 (Page 68)
APPENDIX A. Part 2 (Page 64)
Editorial change - added the ANSI This change does not affect content.
standard number.
thus the QPD continues to meet i
10c. Sec 5.4 10c. N45.2.5. Sec 5.4 10 CFR 50. Appendix B.
46 APPENDIX A. Part 2 (Page 69)
APPENDIX A. Part 2 (Page 65)
Editorial change,added the Reg This change does not affect content.
~
Guide ntaber.
thus the QPD continues to meet i
12b. Sec C.5 12b. RG 1.58. Sec C.5 10 CFR 50. Appendix B.
r 47 APPENDIX A. Part 2 (Page 69)
APPENDIX A. Part 2 (Page 65)
Editorial change - added the Reg This chan does not affect content.
^,
Guide ntaber.
thus the - continues to meet 12c. Sec C.6 12c. RG 1.58. Sec C.6 10 CFR 50. Appendix B.
48 APPENDIX A. Part 2 (Page 70)
APPENDIX A. Part 2 (Page 65)
Editorial change - added the Reg This change does not affect content.
Guide number, thus the OPD continues to meet
.t 12d. Sec C.10 12d. RG 1.58. Sec C.10 10 CFR 50. Appendix B.
49 APPENDIX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 66)
Editorial change - added the ANSI This change does not affect content.
standard ntaber.
thus the GPD continues to meet' 13b. Sec 2.9 13b. N45.2.8. Sec 2.9 10 CFR 50. Appendix B.
I
!QE: The difference in page numbers between Revisions 16 and 171s prin.arily due to format and type-font changes not changes in content.
Page 8
CHANr;E MTRIX 6/4/97 OIALITY PROGRM DESCRIPTIDN (CPC-PA)
REVISICW 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 50 APPENDIX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 66)
Change marked in error.
NA 13c. N45.28. Sec 2.9e 13c. N45.2.8. Sec 2.9e (Marked but didn't change) 51 APPENDIX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 67)
Editorial change - added the ANSI This thenge does not affect content.
standard number.
thus the OPD ccntinues to meet 13.d Sec 2.9e 13d. N45.2.8. Sec 2.9e 10 CFR 50. Appendix B.
52 APPENDlX A. Part 2 (Page 71)
APPENDIX A. Part 2 (Page 67)
Editorial change added the ANSI This change does not affect content.
standard number.
thus the QPD continues to meet 13e. Sec 4.5.1 13e. N45.2.8. Sec 4.5.1 10 CTR 50. tppendix B.
53 APPENDIX A. Part 2 (Page 72)
APPENDIX A. Part 2 (Page 67)
Editorial change added the ANSI This change does not af fect content.
standard number, thus the OPD continues to meet 14b. Sec 6.2 14b. N45.2.9. Sec 6.2 10 CFR 50. Appendix B.
54 APPENDIX A. Part 2 (Page 74)
APPENDIX A. Part 2 (Page 69)
Editorial change added the Rag This change does not affect content.
Guide nts:ber.
thus the OPD continues to meet 16b. Sec C3a(2) 16b. RG 1.144. Sec C3a(2) 10 CFR 50. Appendix B.
55 APPENDIX A. Part 2 (Page /4)
APPENDIX A. Part 2 (Page 69)
Editorial change - added the Reg This change does not affect content.
Guide number.
thus the QPD continues to meet 16c. Sec C3b(1) 16c. RG 1.144. Sec C3b(1) 10 CFR 50. Appendix B.
56 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This change does not affect content, standard number.
thus the QPD continues to meet 17b. Sec 3.2.3 17b. N45.2.13. Sec 3.2.3 10 CFR 50. Appendix B.
57 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This chance does not affect content, standard number.
thustheDPDcontinuestomeet 17c. Sec 3.3(a) 17c. N45.2.13. Sec 3.3(a) 10 ffR 50. Appendix B.
58 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This change does not affect content.
standard number.
thus the QPD continues to meet 17d. Sec 3.3(b) 17d. N45.2.13. Sec 3.3(b) 10 CFR 50. Appendix B.
58 APPENDIX A. Part 2 (Page 75)
APPENDIX A. Part 2 (Page 70)
Editorial change - added the ANSI This change does not affect content, standard number.
thus the OPD continues to meet 17e. Sec 7.5 17e. N45.2.13. Sec 7.5 10 CFR 50. Appendix B.
60 APPENDIX A. Part 2 (Page 76)
APPENDIX A. Part 2 (Page 71)
Editorial change - added the ANSI This change does not affect content, standard number.
thus the OPD continues to meet 17f. Sec 10.1 17f. N45.2.13. Sec 10.1 10 CFR 50. Appendix B.
MK: The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
Page 9
CHAEE MATRIX 6/4/97 00ALITY PROGRAM DESCR!PTION (CPC-2A)
REVISION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 61 APPENDIX A. Part 2 (Page 76)
APPENDIX A. Part 2 (Page 71; Editorial change - added the ANSI This change does not affect content.
standard number, thus the OPD continues to meet 179. Sec 10.3.4 (as modified by 179. N45.2.13. Sec 10.3.4 (as 10 CFR 50. Appendix B.
RG 1.123. C6e) modified by RG 1.123. C6e) 62 APPENDIX A. Part 2 (Page 77)
APPENDIX A. Part 2 Change in terminology from *rtsk*
This change does not affect content.
20b. RG 1.29. General 20b. RG 1.29. General to *5afety" to be consistent with thus the QPD continues to meet Exception / Interpretation Exception / Interpretation industry usage.
10 CFR 50. Appendix B.
Paragraph 1 Paragraph 1 The pertinent quality requirements The pertinent quality requirements for these systems, structures and for these systems. structures and components will be determined in a components will be determined in a graded manner using tools such as graded manner using tools such as the the plant specific Probabilistic plant specific Probabilistic Safety Risk Assessment and the Technical Assessment and the Technical Specifications, and other docketed Specifications. and other docketed analyses to determine the degree analyses to determine the degree which Appendix B of 10 CFR 50 which Appendix B of 10 CFR 50 applies.
applies.
63 (Not in Revision 16)
APPENDIX A. Part 2 (Page 72)
Change made to clarify nature of The QPD provides training and
- 21. ANSI /ANS 3.1-1987 commitment to ANS 3.1-1987. which qualification requirements (for persons Exception /It.terpretation was transferred from plant performing independent safety reviews)
Technical Specifications.
that meet those previously established The cummitment to ANSI /ANS 3.1-1987 in plant Technical Specifications, is limited to requirements that apply Thus. the QPD continues to meet to persons performing the independent Criterion 11 of 10 CFR 50. Appendix B.
safety revi s function as specified in Appendix C to this QPD.
64 APPENDIX B (Page 79)
APPENDIX B (Page 74)
Change in referenced paragraph due This change does not affect content.
to renumbering in foll wing section thus the QPD cor.tinues to meet B6.h.
All items identified under B6.h. All items identified under (see Item 67).
10 CFR 50. Appendix B.
B12. below as significant to B9.3 below as significant to nuclear safety (Palisades nuclear safety (Palisades only).
only).
65 APPENDIX B (Page 80)
APPENDIX B (Page 75)
Correction of references to provide These requirements contain det H ls.
complete consistency with wording formerly in plant Technical B7.a. Recommend in writing to the 87.6.
Recmmend in writing to the in plant Technical Specifications.
Specifications. that are not addressed Plant General Manager / Manager Plant General Manager / Manager by 10 CFR 50. Appendix B.
Correction approval or disapproval of approval or disapproval of has no effect on compliance.
items considered under B6.a.
Items considered under B6.a.
through 1. above.
through J. above.
NOR: The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content.
Page 10
~.- - - - _
-~.
CHANGE MATRIX 6/4/97 00ALITY PROGRN1 DESCRIPTIDN (CPC-2A)
REVISION 17 L
lten Revision 16 Revision 17 Reason for Change Basis for Conclusion 66 APPENDIX B (Page 80)
APPENDIX B (Page 75)
Correction of references to provide These requirements contain details.
complete consistency with wording fomerly in plant Technical B7.b. Render determinations in 87.b. Render determinations in in plant Technical Specifications.
Specifications, that are not addressed writing with regard to writing with regard to d ether by 10 CFR 50. Appendix B.
Correction whether or not each item or not each item considered has no effect on compliance.
considered under B6.a. c and under B6.a. b. c. f (Palisades g above constitutes an only) and h. above constitutes unreviewed safety question.
an unreviewed safety question.
t 67 APPENDIX B (Page 81)
APPENDIX B (Page 75)
Ranumbered to provide more clarity This chance does not affect content.
and better organization of thustheQPDcontinuestomeet B10.
The Safety / Design staff B9.1 The Safety / Design staff statements. No wording changes 10 CFR 50. Apperdix B.
responsible for the review responsible for the review made.
function shall be an function shall be an r
experienced technical staff experienced technical staff meeting the qualifications of meeting the qualifications of l
Technical Specifications.
Technical Specifications.
68 APPENDIX B (Page 81)
APPENDIX B (Page 75)
Renumbered to provide more clarity This change does nos affect content.
[
and better organization of thus the OPD continues to meet 4
B11.
The Safety / Design Review B9.2 The Safety / Design Revi s staff statements. No wording changes 10 CFR 50. Appendix B.
i staff may provide nuclear may provide nuclear safety made.
safety review as delegated by review as delegated by Palisades PRC for:
Palisades PRC for:.
69 APPENDIX B (Page 81)
APPENDIX B (Page 76)
Renumbered to provide more clarity This change does not affect content.
and better organization of thus the QPD continues to meet B12.
The Safety / Design Review 89.3 The Safety / Design Review staff statements and to correct 10 CFR 50. Appendix B.
staff shall determine those shall determine those issues references based on renumbering of issues significant to nuclear significant to nuclear safety other sections.
safety which require review which require review by the by the Palisades Plant Review Palisades Plant Review Committee from items Committee from items considered under 811.a.
considered under B9.2a.
through d. above. For those through d. above. For those items not referred to PRC.
Items not referred to PRC.
Safety / Design Review shall Safety / Design Review shall recommend in writing to plant recommend in writing to plant management approval or management approval or disapproval of items disapproval of It m s considered under B11.
considered under B9.2 70 APPENDIX B (Page 81)
APPEND *X B (Page 76)
Renumbered to provide more clarity This change does not affect content.
and better organization of thus the OPD continues to meet B13.
Reports of Safety / Design 89.4 Reports of Safety / Design statements. No wording changes 10 CFR 50. Appendix B.
Review activities pursuant to RevW activities pursuant to made.
B11. shall be subeltted PS shall be submitted monthly v
monthly to PRC.
to PRC.
}
l I
1 N_0T[: The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes. not changes in content, Page 11
i t
CHANrI $TRIX 6/4/97 OIALITY PROGR#f DESCRIPTION (CPC-?A)
{
REVISION 17 l
Item Revision 16 Revision 17 Reason for Change Basis for Conclusion '
71 APPENDIX C (Page 82)
APPENDIX C (Page 77)
This section added to make clearer This change does not affect content.
I connectim for users to the thus the QPD cnntinues tn meet (Not in Revision 16)
Added Paragraph 1.
Exceptions / Interpretations in 10 CFR 50. Appendix B, Appendix A. Part 2. that relate to the subject of this section.
72 APPENDIX C (Page 82)
APPENDIX C (Page 77)
Change made to provide more exact The 000 n w provides controls over the C2.
Composition C2.
COMPOSITION match with wording being removed independent safety review fmetton that from plant Technical are fully consistent with d at was in i
The ISRG shall include the Managw.
The ISRG shall include the Manager.
Specifications. Tech Specs used Technical Specifications. These NPAD. who reports to the Vice NPAD. who reports to the Vice
- Full-time staff reporting to_
requirasents contain details not President - NOD. and a staff of President - NOD. and a full-time aooressed by 10 CFR 50. Appendix B.
i persons designated as Nuclear staff of persons reporting to the Correction has no effect on compliance.
i Performance Specialists for the ISR Manager. NPAD and designated as function. The Manager. NPAD. and Nuclear Performance Specialists for l
the Nuclear Performance Specialists the ISR function. The Manager. NPAD.
shall meet or exceed the and the Nuclear Perfonaance qualifications described in Specialists shall meet or exceed the Section 4.7 of ANSI /ANS 3.1-1987.
qualifications described in Tne ISRG shall have no direct Section 4.7 of ANSI /ANS 3.1-1987.
responsibility for activities The ISRG shall have no direct 1
subject to its review.
responsibility for activities subject to its review.
I 73 APPENDIX C (Page 82)
APPENDIX C (Page 77)
Rentabered to provide more clarity This chan does not affect content.
?
and better organization of thus the continues to meet C5.
Review C4.1 REVIEW statements. No wording changes 10 CFR 50. Appendix B.
made.
i 74 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Correction of reference due to This chance does not affect content.
C5.
Revi m C4.1 REVIEW rentabering.
thus the QPD continues to meet final Paragraph Paragraph 13 10 CFR 50. Appendix B.
ISRG revi m of the subjects in C5.
ISRG review of the subjects in C4.
above shall be performed by above shall be performed by i
15 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Renumbered to provide more clarity This change does not affect content.
and better organization of thus the QPD continues to meet C6.
AUTHORITY C5 AUTliDRITY statements. No wording changes 10 CFR 50. Appendix B.
1 made.
?
f s
l
!!O.H: The difference in page ntmbers between Revisions 16 and 17 is primarily due to format and type font changes. not changes in content.
'f Page 12 t
CHANGE MATRIX 6/4/97 OJAllTY PROGRAM DESCRIPTION (CPC.2A)
REVISION 17 Ites Revision 16 Revision 17 Reason for Change Basis for Conclusion 76 APP [NDIX C (Page 83)
APPENDIX C (Page 78)
Ren mbered to provide more clarity This chan does not affect content.
C6.
AUTHORITY C5 AUTHORITY and better organization of thus the continues to meet Paragraph 1 Paragraph 1 statements. ho wording changes 10 CFR 50. Appendix B.
made. Change in referenced The ISRG shall report to and advise The ISRG shall report to and advise paragraph due to ren sbering in the Vice President. NOD. of the Vice-President. N00, of section.
significant findings associated with significant findings associated with those areas of responsibility those areas of res sibility specified in C5. above and specified in C4. a ve and Appendix D. Audit frequencies.
Appendix D. Audit Frequencies.
77 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Renumbered due to earlier number This change does not affect content.
changes.
thus the OPD continues to meet C7.
RECLRDS C6 RECORDS 10 OfR 50. Appendix B.
78 APPENDIX C (Page 83)
APPENDIX C (Page 78)
Change in referenced paragraph due This change does not affect content.
to renumbering in section.
thus the QPD continues to meet C7.a.
The results of revi ms C6.a.
The results of reviews 10 CTR 50. Appendix B.
performed pursuant to C5.
performed pursuant to C4.
above shall be reported to above shall be reported to the the Vice-President. NOD. at Vice-President. NOD at least least monthly.
monthly.
79 APPENDIX C (Page M)
APPENDIX C (first Page 79)
Renumbered due to earlier number These requirements contain details.
changes. Made this applicable to formerly in plant Technical C7.b. A report assessing the C6.b. A report assessing each both operating plants. as Specifications. that are not addressed overall nuclear safety plant's overall nuclear safety Revision 16 was in error in by 10 CFR 50. Appendix B.
Change has performance of Palisades performance shall be provided restricting it to Palisades.
no effect on compliance.
shall be provided to senior to senior Cmsumers Powr Conswers Power Company Company management annually.
management ennually.
80 APPENDIX D (Page 85)
APPENDIX C (Second Page 79)
Change made to provide more exact This QPD now provides controls over Dl.
AUDITS DI.
AUDITS match with wording being removed audits that are fully consistent with Paragraph 1 Paragraph I from plant Technical what was in plant Technical Specifications. Tech Specs specify Speci fications. These requirments Audits of operational nuclear safety Audits of operational nuclear safety (as does Section 1.2.2c of this contain details not addressed by related activities shall encompass:
related activities are performed by QPD) that NPAD performs audits.
10 CFR 50. Appendix B.
Correction has the NPAD staff under the cognitance no effect on compliance, of Nuclear Performance Specialists.
Tech Specs also required the These audits encompass:
cognizance of the Nuclear Performance Specialists responsible for independent safety review per Appendix C.
NOTD The difference in page numbers between Revisions 16 and 17 is primarily due to format and type-font changes, not changes in content.
T Page 13
CHAEE MATRIX 6/4/97 OIALITY PRorAM DESCRIPTION (CPC-2A)
REvfSION 17 Item Revision 16 Revision 17 Reason for Change Basis for Conclusion 81 APPINDIX E (I'm 87)
APPENDIX E (Page 80)
Change made as approved in NRC NRC letter approving this change correspondence dated OctcLer 8.
Indicated the OPD ' continues to meet E3.c. Records of monthly radiatim E3.c. Records of quarterly radiation 1996.
the requirements of 10 CfR 20 and exposure for all individuals exposure for all individuals 10 CFR 50. Appendix B*
entering radiation control entering radiation control areas.
areas.
w l
[
M: The difference in page ntsnbers between Revisions 15 and 17 is primarily due to format and type-font changes, not changes in content.
Page 14