ML20211N732
| ML20211N732 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/10/1997 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9710170090 | |
| Download: ML20211N732 (197) | |
Text
.
CorkmmersEnergy A CMS Degy Own m g, m uanaoa Utenstng October 10,1997 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 -LICENSE DPR-6 -BIG ROCK POINT DOCKET.50-255 -LICENSE DPR-20 -PALISADES PLANT
- REQUEST FOR APPROVAL OF CHANGES TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS (CPC-2A)
In accordance with 10 CFR Part 50.54(a)(3)(ii), Consumeis Energy Company requests approval for proposed changes to our report, " Quality Program Description for Operational Nuclear Power Plants"(CPC-2A). The changes are discussed in of this letter, which also provides the general basis fc,r concluding any, apparent reductions in commitment result in a Quality Program that continues to meet the requirements of 10 CFR 50, Appendix B. The left column in the Attachment Listg identifies which specific changes described in Attachment 2 involve potential reduction s
in commitment.
se
~jes is a detailed matrix comparing Revision 18 to the proposed Revision 19a, m
including the reason for each change and additional basis for concluding the Program M.
meets Appendix B. Attachment 3 is the currently approved and issued version of M-CPC-2A, Revision 18. Attachment 4 is the proposed revision of CPC-2A, identified as E.
Revision 19a.
Eg The changes to CPC-2A included in this request fall into four types, most of which are not considered reductions in commitment, as follows:
.I 1.
Changes related to recent Consumers Energy corporate structure changes.
'T fl The position of President and CEO of Consumers Energy has beon replaced b
by the two positions of President and CEO-Electric, and Presider't and 9710170090 971010 PDR ADOCK 05000155 W
PDR Yattsm%s NuckyPknt
- 27780 Blue Stw Memonalthynway. Covent, MI 49613
- Tel: 616 764 2913
.~at 6Ib 764 2490 u
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CEO-Gas. The President and CEO-Electric is now the top corporate position L -
responsible for safe operation of Consumers nuclear power plants. These changes do not represent a reduction in commitrnent.
- 2.
Changes relatedo altering the title and scope of CPC-2A to more clearly indicate that it will continue to apply to Consumers Energy nuclear plants-after they cease operation and enter the decommissioning phase of plant life.
As part of this change, plant life is redefined to be that period during which the plant rraii tains a valid 10 CFR 50 license, regardless of operational state.
i i
These changes do not represent a reduction in commitment.
3.
Changes related specifically to the change in status of the Big Rock Point plant, which has now permanently ceased operations and is entering the decommissioning phase. These changes include:
Management title change from Plant General Manager to Site General a
Manager. This change does not represent a reduction in commitment, b,
eilimination of some activities from the responsibilities of site management and the scope of this Program because they are no longer relevant. Because these changes may be construed as reductions in commitment with respect to previous revisions of this Program, NRC approvalis required.
c.
Relocation of some operating plant Technical Specification sections to th'is Program as part of the creation of Big Rock's Permanently Defueled Technical Specifications (PDTS). Relocation is consistent
_with Ni.: Administrative Letter 95-06. (CPC-2A has contained these sections since Revision 16, in anticipation that plants would submit 1 requests to remove the requirements from operating Technical
' Specifications. Palisades has aheady submitted such a request; Big -
Rock had not done so.) These changes do not lepresent a reduction -
in commitment.-
d.
Revision of some of the relocated requirements for Big Rock Point's on-site safety review function (formerly the Plant Review Committee).
The changes reflect the permanently. shutdown condition. With respect to the previous revision of CPC-2A, some of these changes may be construed as reductions in commitment requiring NRC approval prior to implementation.
41 Correction of editorial errors from Revision 18. These changes do not represent reduction in commitment.
3 Upon approval of these changes by the NRC, a revision will be approved and issued to incorporste the changes into CPC-2A.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
A Thomas C. Bordine Manage.r, Licensing CC:
Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachments
)
ATTACHMENT 1 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 LICENSE DPR-6 PALISADES PLANT DOCKET 50-255 LICENSE DPR-20 1
REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A)
DETAILS OF CHANGES a
2 Pages
Discussion of Reasons for Changes Involving Potential Peduction :n Commitment, and Basis for Continued Compliance with 10 CFR 50, Appendix B Change Reason for Change saels for continued compliance with 10 CFR Part 50, Appendit B Deleted Big Rock Point As Big Rcck permanantly The Program continues to responsibilities in section 1.2.2 ceaseri operations on August describe the important related to start-Lp and 29,1997, these responsibilities management positions and operational testing, are no longer relevant, since the responsibilities for implementing accident / transient and physics activities cited will no longer be the quality assurance elements, analysis of reloads, core performed.
Activities that will still be performance, and core thermal performed are stillidentified.
hydraulics, probabilistic safety The description provided assessment (formerly "PRA")
continues to meet Criterion I of and inservice inspection.
10CFR50, Appendix B, in that the authority and duties of Further detailin Attachment 2 persons and organizations items: 11,13,15,17, performing activities affecting the safety-related functions of structures, systems and components is clearly established and delineated in writing.
Deleted requirements for Big As Big Rock permanently The Program continues to Rock to have procedures for ceased operations on August identify the types of procedures startup, shutdown, power 29,1997, such procedures are that will be required to control operation / load changing, core no longer relevant, since the safety-related activities at Big alterations and refueling from activities cited will no longer be Rock Point during the section 5.2.
performed.
decommissioning phase. (This includes the addition of Further detallin Attachment 2 procedures for fuel handling and items: 38,39,40,41,42, decommissioning.) Thus, the description continues to meet Criterion V of 10CFR50, Appendix B, in that activities affecting quality will be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances.
Provided allowance, in section This extends allowance already As approval authority remains 6.1 and Exception / Interpretation given for Palisades to Big Rock clearly specified, the Quality 2h, for the Big Rock Site Point. At Big Rock, these Program continues to meet General Manager to delegate, in requirements were formerly also 10CFR50, Appendix B, Criterion writing, procedure and part of Plant Technical VI.
temporary change approval to Specifications, but are being managers reporting to him moved to CPC-2A with the creation of Permanently Further detailin Attachment 2 Defueled Technical items: 45, 59, 60.
Specifications.
1
. - - - =.-
4 Change Reason for Change Basl* for continued complianc.
with 10 CFR Part 60, Appendix B Deleted requirements for Big As Big Rock permanently The program continues to Rock to perform pre-operational ceased operations on August identify the types of te;;ts that i
and startup tests from Section 29,1997, such tests are no will be required at Big Rock 11.2.2 longer relevant, since the plant Point during the i
will never restart.
decommissioning phase. Thus, Further detailin Attachment 2 the description continues to items: 53,54.
meet Criterion XI of 10CFR50, Appendix B, in that testing required to demonstrate that remaining safety related structures, systems and i -
components will perform satisfactorily in service will be identified and performed.
Deleted commitment to The portions of Appendix R to This commitment was not 10CFR50, Appendix R for Big which Big Rock was committed required by 10CFR50, Appendix Rock Point, as identified in in CPC-2A related to alternate B. Thus, changing CPC-2A has e
Appendix A, Part 1, Item 21, shutdown capability. Since Big no effect on compliance.
Rock is now permanently shut Further detailin Attachment 2 down, these requirements are Item 66.
no longer relevant.
The Big Rock Point Plant Changes,'aflect the reduced 10CFR50, Appendix B does not Review Committee is replaced scope of safety-related activities address the onsite safety review by the " Safety Review subject to review by the onsite function. Thus, changing Committee"(SRC). SRC review body, as well as site CPC 2A has no effect on membership is reduced to a re-organization to support compliance.
Chairman and four members de-commissioning. The 4
from the PRC's nine members, changes are consistent.vith the i
Restrictions on which relief granted to other plants in departments members must this phase of plant life (usaally in represent are removed. With their Technical Specifications).
the reduction in number, the quorum requirement for meetings and routing reviews is also reduced from Chairman plus 4, with no more than 2 attemates. to Chairman plus 2, with no more than one attemate.
After spent fuelis removed from the storage pool, the SRC meeting frequency will be reduced to quarterly from the current monthly.
Further detallin Attachment 2 j.
Items 67,68,70,71,81.
2 4
..... ~. - - -
-.. ~ -. -.. -.
e ATTACHMENT 2 2
CONSUMERS ENERGY BIG ROCK POINT PLANT l
DOCKET 50-155 LICENSE DPR 6 PALISADES PLANT DOCKET 50-255 LICENSE DPR 20 l-CHANGE MATRIX QUALITY PROGRAM DESCRIPTION (CPC-2A)
REVISION 19a b
23 PAGES
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ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALITY PDGRAM DESCRIPTION (CPC 2Al REVISION 19e Item Revielen 18 Routalen 19e Reason for Change Seele for Cenetoelen l'
CPC-2A cover letter CPC-2A cover letter This program name cfienge recopres No offect on w. f - with 10CFR50, the Quanty Program wNl apply beyond Apperds 8.
STATEMENT OF RESPONSl88UTY AND STATEMENT OF RESPONS181UTY AND the " Operational" phase through AUTHORITY REGARDING THE AUTHORITY REGAP. DING THE termmetson of Big Rock Point's
[
CONSUMERS ENERGY PROGRAM FOR CONSUMERS ENERGY PROGRAM FOR 10CFR50 liconee OPERATIONAL NUCLEAR POWER '
NUCLEAR POWER PLANTS PLANTS I
i 1'
2 CPC-2A cover letter CPC-2A cover letter Change in corporate structure provided The program contmuss to provide and i
First paragraph, la sentence First paragraph,1st sentence seperate Proesdent and CEOs for establien the orgeneration, poestions and I
l electric and gas divessons. Also, responutsastaes for its implomontation, as.
3 Program name change as above noted. ! requeed by Criteria a and 11 of 10CFR50,
[
As Presedent and Chief F-- stive As Proeident and Chief Executive Officer Officer of Consumers Er erf y, I have the
- Electric of Consumers Energy, I have Appendsx 8.
ultimate managemeM autnority for the the ultimate management authority for Consumers Enerav Quaktv Proaram the Consumers Enerov Quaktv Pronram Descnotson for Oneratannel Nuclear Power Plants
}
3 CPC-2A cover letter CPC-2A cover letter Program name change as above noted.
No effect on =-- f with 10CFP50.
S First paragraph, last sentence First paragraoh, last sentence Also adds commetment to use this Appendix 8.
Program to control em.._.
(
The Quality Program Desenption for The Quairty Program Desenption for Operational Nuclear Power Plants Nuclear Power Plants outimes the
.I outlines the actions that aire actions that are implemented for
-i implemented during the operational miportant activities includmg fussing.
l phase includmg fuelmo, testmg, testing, operation, refueling, 4
op. ration. refuenne, procur.m.nt, procuromont, mainionence, repair, maintenance, repair, and modification mods. cation dee.gn and con.iruction, j
design and construction of the safety-and -f+ --....
, of the safety-7 related portions of the nuclear rower related portsons of the nuclear power plants.
plants.
j t
4 CPC-2A cover letter CPC-2A cover letter Change in corporate structure (reduced No effect on compliance with 10CFR50, Second paragraph,1st sentence Second paragraph,1st sentence reporting relationshaps by one Appendix B.
management levee.
I have delegated responsibekty for I have delegated responashelity for 1
estabbsheng, maintaining and establishmg, maintaining and
,[
implementing the QuaEty Program amplementing the Quakty Program Description through the Executive Vice Description to the St or Vice Preendent.
Presedent and Chief Operating Officer-Nuclear, Fossd and Hydro Operations.
Electric to the Sr. Vice Presedent, J
Nuclear, Fossa and Hydro Operations.
l i
j Page 1
=
ATTACHMENT 2 CHANGE MATRIX f
09/05D7 QUALfTY PROGRAM DESCRIPTION (CPC 2Al REVISION 19e i
item Revision 18 Revision 19e Reason for Change Seeis for Ccnoluelen 5
1.1 (Page 1) 1.1 (Page 1)
This change recognizes the Quality The Program content and commrtments are Paragraph 1 first sentence Parag aph 1 first sentence Program will apply bevond the not altered by this change. This change,
' operational phase", and through and others described below, extends Consumers Energy is responsde for es-Consumers Energy is responsible for es-dm.,,....R until termination of a
.g.,4 ;Op of the Program through finet tablishing and innviementing the Quality tableshmg and implementing the Qualitv 10CFRSO liew per 10CFR50.82.
Iicense termination. The Procram continues Program, as described herein, for the Program, as described herein, for its Change rewy to support Big Rock to meet 10CFRSO, Appendix B.
operational phase of its nuclear power nuclear power plants.
Point shutdown.
plants.
6 1.2.1 (Page 1) 1.2.1 (Page 1)
Change in corporate structure provided The program continues to provide and Paragraph 1 Paragraph 1 separate President and CEOs for.
establish the organization. positions and electric and gas divissons Also, added responsitwTrties for its implementation, as The President and Chief Executive The Preeident and Chief Executive respons.tniity for decommisssoneng, as requirea by Criteria i and il of 10CFRSO, Officer (see Figure 1, Company Officer - Electric (see Figure 1, Company Big Rock Point was shut down Appermit B.
Organization Chart) of Consumers Organization Chart) of Corwurners permanently on August 29,1997.
Energy is responsible for safe operation Energy is responseble for safe operatbn of Consumers Energy nuclear power and decommissioning of Consumers plants. Authority and responsibility for Energy nuclear power plants. Authority establishing and implementing the and responsibihty for estableshing and Quality Program for plant operations, implementing the Quality Program for maintenance and modifications is plant operations, maintenance, delegated through the Executive Vico modifications and decommesseorung is President and Chief Operating Officer -
delegated to the Senior Vice Pressdent -
Electric to the Senior Vice President -
Nuclear, Fossil, and Hydro Operations.
Nuclear, Fossif, and Hydro Operations.
This delegation is formalized in a This delegation is formalized in a STATEMENT OF RESPONSIBluTY AND STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and AUTHORITY signed by the President Chief Executive Officer - Electric. Other and Chief Executive Officer. Other quality-related functions are provided by quality-related functions are provided by other organizations as described herein.
other organizations as described herein.
Page 2
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ATTACHMENT 2 CHANGE MATr*X 09/05'97 QUAUTY PfiOGRAM DESCRIPTION fCPC-2A1 f4EVTSION 19a seam moviesen is nousion 1s.
nomeen ser Change assie for -
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10 1.2.2.b (Page 4) 1.2.2.b (Page 41 Change in title of sermor manager N The program contmues to prende and l
Paragraph 5 Paragraph 5 Big Rock Poet.
estat4sh the argeruratiert poemons and j
responsenties for its knpiementaten. as Modifyng _,~. a. _P! ant General Modifyng cornponents... Site General rarstared by Cntene I and 5 of 10CFR50, Manager.
Manager.
Appenden B.
11 1.2.2.b (Page 4) 1.2.2 b (Page 4)
At Big Rock P5et, which is now As the deleted actnretes wiB no longer be Paragraph 10 Paragraph 10 shutdown permanendy, there will no p Mormed due to shutdowrt, they do not longer be any startup or other tests need Regrarn controis appled.
Performmg start <sp and operational Perfornung necessary survedance related to reactor operation or power testing, such as preentical and crrtscaisty testeg.
production. There will be some The program contmuss to promde and tests. Iow-power, power ascensen and survoimance tests for spent fuel estatseh the orgeruraten, poortions and plant tests, and sunreafance testing.
storage systems, as promded in the respono66tses for its implementaten, as plant's Permanently Defueled regured by Catone I and N of 10CFR50.
Techrscal Spec (cations.
Appendra 8.
12 1.2.2 b (Page 5) 1.2.2.b (Page 5)
D=armg h....._4 Bag Rock The program contmues to requwe Paragraph 16 Paragraph 16
': nt's co5ecten of safety related identdication of SSCs and actnrites to be SSCs and actraties wsII necessar#y be covered by the Program, and provides Properation review, and approval of Q-Preparatiori, review, and approval of reduced to those needed to provide controls conerstent with thew importance 99 Irst updates.
means that identify safety-related plant safe spent fuel storage and ~6i.v..
safety, as regured by Cntenon 5 of structures. systems and components, of. Aa and the public. The 10CFR50, Appendix B.
and actrwites to which this OPD appfy, wording change aar nrs for contmued as described in Secten 2.0, depending ederrtificaten of SSCs and actraties to on plant cardtions during which the Program shot apply, but not
- d or entiement.
necesesniy vie a mast.-
f 13 1.2.2.b (Page 5) 1.2.2.b (Page 51 Since S=g Rock Point has riow ceased As the dee.d armivites wig rio longer be Paragraph 18 Paragraph 18 operaten, ansfysis of renoods, reacter y=i"..---; due to sfWowes they do not core, and nuclear fuel design are re feed negare. cor trois applied.
Reactor engineenng such as accident.
Nuclear engmeenng such as accsdent-longerv.J... #
transent and phyrh aralysis of transsent and physics analyses of spent The program contmues to provide and reloads, reactor core and nuclear fuel fuel storage configurations.
estat$sh the orgeruratert. poortsons and desagn and core therme>fiydrsufic and responeit> Trees for its implementation, se nuclear support of plant mod (scations req.sred by Cntana I and N of 10CFR50, and operatsons.
Appendim B.
14 1.2.2.b (Page 5) 1.2.2.b (Page 5)
Editonal change to use more inclusive The program conemues to prowde and Paragraph 19 Paragraph 19 terminofogy Big Rock is, in effect, no establish the ergeruratmo% poortions and longer a
- nuclear operstmg* facility.
responsibilities for its implementation, as Establishmg, nnplementog, and Estat$shmg, unplementing and regured by Cntena I and N of 10CFR50, documentog.. nuclear operations...
&,G a.aing... operating...
Appendix 8.
Page 4
ATTACHMENT 2 CHAPdGE MATRIX 09/05/97 QUALITY PROGRAM DESCRIPTW (CPC 2Al REVfSION 19a sosia ser '-
?
hem movision 15 newmien 13e asemen ser Change r
15 1.2.21 (Page 5) 1.2.2.b (Page 5)
Since Bag Rock Ptunt has rew ceased
- The prograrn continues to powide and Paragraph 20 Paragraph 20 operatert, PSA modehng is rio longer estabish the organization, posstsons ad relevert and is not identdied as a responesbsTsties for its impiamentation as Ca4a. and utkation of nuclear Paragraph deleted.
responstnTrty.
regured by Cnteria i and 5 of 10CFR50.
i plant probabkic safety assessment Appen6mB.
I models to evaluate safety and plant rekatmhty ingrovement 16 1.2.2.b (Page 5) 1.2.2.b (Page 5)
Since Big Rock Point has ceased The program continues to provide and Paragraph 26 Paragraph 26 operation, it is no longer a estatdeh the orgenrration, poestens and
- generating
- plant. However, responstnTeties for its implementation, as Performing the engineenng, Perforrrung the engreenng,
'"wi-, to remarang safety-reqtares by Cntens I and 5 of 10CFR50, construction, inspection and testing Loi.vu, inspection and testing related SSCs may stig be done.
ApperGx B.
assooated with generating plant associated with plant modsfication modsfication protects as asessned.
protects as assagned.
17 1.2.2.b (Page 6) 1.7 2 h (Page 5)
Since Big Rock Point has ceased The program corenues to provide and Paragraph 27 Paragraph 27 operation, the need for an inservice estatssh the organuation, poestens and inspectaan program no longer exists.
responsibdrbes for its implementators as Conducting the insennce irgection Paragraph deleted.
This change unE be reflected in the reqused by Cntens I and N of 10CFR50 program in a-with technscal PDTS which wit be submitted for NRC Appendix B.
specifications and State of Mactugan approval.
rules.
18 1.2.2.b (Page 6) 1.2.2.b (Page 5)
Change in trtle of senior maneger at The program continues to provide and Paragraph 29 Paragraph 27 Big Rock Ptnnt. Also. change in name estabbsh the orgeruration, poetens and of onsste safety review commrttee.
responabdities for its implementaters as Performmg reviews to advise the Plant Performing rewwws to advise the Site esqueed by Crvtona I and 5 of 10CFR50.
General Manager on matters rotated to General Manager on matters related to Appendt B.
nuclear safety, as specified in Appendix nuclear safety. as specified in Appendix B. Plant Review Commettee.
B. Plant Review Committee /Safetw Revew Commettee.
19 1.2.3 (Page 61 1.2.3 (Page 6)
Program name change to recognue The pogram contnues to provide and Paragraph 2 Paragraph 29 that one plant is no longer " operating *,
estatash them,. 4.i n, poortens and but that the Program sta apples.
responabdreses for its inylementation, as Assessment of the effectrweness of the Assessment of the effectrweness of the regured by Critens I and R of 10CFR50 Nuclear Operations Quakty Program.
Nuclear QuJety Program.
Appsmdix B.
Page 5
I l
ATTACHMENT 2 j
CM.aE MATHtX 09/05/97 QUALITY PROGRAM DESCR!PDOM (CPC-2A1
. i; l
REVISION 19a hem novimon 18 Rowsesen 19e Reason for Cheese Semie for Condumen 20 1.23 (Page 6!
1.2.3 (Page 63 Bn3 Rock Poirst is now permanentty The program contmuss to promde and Paragraph 8 Paragraph 8 shut down, so tnere is no need to estat6sh the orperuzatiors poortsons and sdentify the Site General Manager in respanobiErties for its implementation, as Recommendmg to the Sete Vice Am~..-..any to the Site Vee ttus context.
requesd by Cnteria I and W of 10CFR50, Pressdent, the Plant General Manager, or Pressdent or the Sensor Vce Presn$ent Asperds B.
the Senior Vece Pressdent NFHO that a NFHO that a plant be shut down af such plant be shut down if such action action appears necessary appears necessary 21 1.2.3 (Page 6)
T 2.3 (Page 6)
Program name change to recognee The program cormnues to prtnrede and Paragraph 12 Paragraph 12 that one plant is no longer "operaung",
establish the organesteort poestions and but that the program stir appises.
responimbilities for sts implementation, as Masntenance of the Quairty Program Mamtenance of the Quality Progren requirsd by Cntene I and II of 10CFR50, Description for Operational Nuclear Desenption for Nuclear Power Plants.
Apperda B.
Power Plants.
22 1.2.5.a (Page 7) 1.2.5.a (Page 7)
Corporate title changes.
The program contmues to promde and estatesh the organizatsort poortions and The Manager, Electnc 8ystem The Manager, Electric System responsibdces for its implementatiort as Operations (see Figure 1) is responsable Operations (see Figure 1) es responoble requeed by Cntene I and a cf 10CFR50, through the Vce Pressdent, Electne through the Vee Pressdent, Electne Appendia 8.
Transmission and Destnbution to the Transmessson and C-i,;;,vi-. to tre Executrwe Voce Pressdent and Ctuef Pressdent and Chief Executrve Offcer -
Operstmg Offscer - Electne for Electnc for determurung settings for determmmg settmgs for electnca:
electncal protectrue systems and relay protective systems and relay control control schemes, and for dessert review s@ emes, and for desagrt review and and recommending changes to electncal recommendmg changes to electncal
,,.amL+ schemes and associated protectrve schemes and as'ocasted settmos.
settsngs.
23 1.2.5.b (Page 7) 1.2.5.b (Page 7)
Corporate tnie changes.
The program continues to promde and Senter ce 1 Sentence 1 estat*sh the orgeruzersort postions and responsibilrties for its implementations as The Executnre Manager Fuels & Power The Executrwe Manager, Fuels & Ptrwer requesd by Cntens I and R of 10CFR50 Transactions is responsable to the Transactions is responssble to the vce Appendia 8.
Executive Vce Presr%nt and Chief Premdent and Ctwef Executswe Offscer -
Operstmg Orfeer - Electric for Electnc for maintaining the Records maintainmg the Records Management Management System incksdmg recured System includmg regured retentsort retentiors protection and retnewability.
- protection and retnevebsTety Page 6
ATTACHMENT 2 CHANGE MATMX 09/05/97 QUAlfTY PROGRAM DESCMPTION (CPC 2Al REVfSION 19a seem Redelen 18 Rowison 19e Reason for Change Basis forch 24 1.2.5.c (Page 71 1.2.5.c (Page 7)
Corporate orgaruraten change The program contmues to prende and cormed tfus responobihty into the estabheh the orgeruzation, positens and The Msnager, Production Serwces (see Paragraph deleted Electnc Sernces departmor* (see responesbirsties for its impiomentsteori, as Figure Il is responsible through the Voce below).
regured by Cntena I and 5 of 10CFR50, Premdent Electne Transnwssen and Appendan 8.
Distnbution to the Executive Vce P seedent and Chief Operating Officer -
Electric for operating the Skill Centers including the trainsng, and gushfymg of personnel and equipment for weidmg operations.
25 1.2.5.e (Page 8) 1.2.5.d (Page 71 Corporate title changes.
The program coronues to prowde and estabEsh tte orgeruzeten, poortions and The Manager, L...v.
.m.nal and The Manager, Ennronmental and
' *-. for its implementation, as Techrwcal Sennees (E&TS) is Techrscal Serwces (E&TS) is responsible.
eequired by Cntens I and 5 of 10CFR50, responsible, ttwough the Vice Presadent, through the Vee Premdent, information Appendix 8.
Information Technology and Operations Technology and Operations Services to Sonnces to the Pressdent and Cluef the Preesdent and Chief Executive Officer Executswo Officer for:
- Electne for:
26 1.2.53 (Page 81 1.2.5.e (Page 8)
Corporate trtle changes. Also, the The p.w contmues to prende and responsibikty for Sault Center Trammg, establish the organization, poortions and The M.mager, Electne Serwces is The Manager Electric Sonnees is formerly in the Producten services seaponobikties for sts implementation, as termnsable, through the Vice Pressdent, A, through the Vce Pressdent, department, has been moved to tfus regured by Cntene I and W of 10CFR50
- ectric Transnwssaan and Destnbution to Electnc Tr - ' -. and Distributen to department.
ApperwSm 8.
the Executrwe Vce Pressdent and Chief the Executive Vee Premdent and Chief Operating Offcer - Eloctric for testing E=ecutrwe Off~cer - Electric for testmg i
and maintenung electncal protective and maintaining electncal protective dewces, performmg demon wenfication dewees, performme dessen venfica*non testmg assocssted with electncat testing assocseted with electncal protective schems s, devices and protective schemes, devices and apphcation of associated settmgs.
application of associated settings. The manager, Electric Sennces is aieo responsible for operating the Skill Centers, includme the tranwns and quahrying of personnel and equement for weedme operations.
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l
ATTACHMENT 2 CHANGE MAT?tX 09/05/97 QUALITY PROGRAM DESCRFTION 'CPC 2Al REY!SION 19a Item Row 6 men 18 Rowielen 19e Reason for Change Semisforch 27 2.1 (Page 101 2.1 (Page 10)
Proyam rieme change to recogrure TPas Propam contmuss to be appEed to Paragraph 1 Paragraph 1 that one plant is no longer "operenng*.
both Cor surrrvs Energy nucteer pients, as but the program stig applies. Also, speedied in this and later secDorm, encludeg l
Policies that define and estabEsh the Policies that define and estabEsh thm more clearfy defined plant Efe as empasmentation through procedures and Consumers Energy Queirty Program for Consurners Energy Ouality Program for mcksding the penod up to 10CFH50 metruccons. This contmuss to meet Operational Nuclear Power Plants are Nuclear Power Plants are stated in the Ucense termmanon.
Cntenon 5 of 10CFR50. Appendir 8.
stated in the individual sectens of ttus endnndual sectens of this document.
document. The program is implemented The program is implemented tfrough through procedures and instructions procedures and instrucsons responstwo responseve to prowsons of the QuaEty to pronsens of the Quahty Program Program Desenpten and will be camed Desenpten and will be camed out for out for the hfe of each plant.
the Efe of endi plant. Plant Efe is defined as the period covered by a valid Econee tawler 10 CFR 50.
n 28 2.2.1 (Page 103 2.2.1 (Page 10)
Corpot ate title changes.
The program conunuas to provide and Sentence 1 Sentence 1 establish tf's orgerszeten, poestions and responstmhties for its enplementation, as The President of Consumers Energy, as The Presadent and Chief Executrve required by Cntena I and 2 of 10CFR50, Chierf Executrve Offcer, has stated in a Officer - Electric, has stated in a format Appendim B.
formal STATEMENT OF STATEMENT OF RESPONSIBIUTY AND RESPONSIBluTY AND AUTHORITY, AUTHOFUTY, sagned by him that it is signed by hem, that it is corporate policy corporate poEcy to comply with the to c*r iply with the provisions of provissons of appEcable legislaten and apphcable legestaten and regulatens regulations portammg to quaEty pertawung to quaEty assurance for assurance for nuclear power plants as de med by 10 CFR 50, Appendix B.
nuclear power plants as defmed by 10 r
CFR 50. Appendix B.
Page 8
ATTACHMENT 2 CHANGE MATRIX 09KW97 QUALITY PROGRAM DESCRif' TION (CPC 2Al REVfS10*419a
[
t Item Rowision 18 Row 6esen 19e Reason for C3senge Semie for Casadeelen 29 2.2.3.c (Page 11) 2.2.3.c (Page 11)
Extends Program appEcabshty to Part of this change merely entends
- decommessorung* actmtses affecting appEcatmTety of the Program, whech already The Quahty Program appEes to activities The Quakty Program appres to actndtves quairty of SSCs and consumables.
satis *ies the 18 Cntene of 10CFR50.
affecting the quality of safety 4etated affecting the quality of safety <eisted Also removes the term *Q4.ist* as a Appendia B to h~....
_.--. The other i
structures, systems. w.,~.-.is and structures, systems components and required entity. but retains regurement part mantams ttw Appendix B requrement j
related consumables during plant related consumables dunne plant and cntena for identifying safety-to identify SSCs to which the Program operation. maintenance, testing and all operation. maintenance. testing, related SSCs. For Big Rocit Pbint, the appEes, but does not restrict the j
modifications. Those actmtes hawmg a modifications, and decommisssonreg.
change recogruzed that chenyng plant identification to a "Q4ist*. As Appendum B derect impact on safety.related items Those activities having a dwect impact conditions during dismantlement may does not refer to *0-List *, the Program shall be corrtrolled Safety related on safety <eleted itemt, shes be contros-arter the list of SSCs to which the continues to meet Cnterion N. The forset structures, systems, components and ed. Safety 4etated structures, systems.
Program is appEed. but the change recognizes that changne plant i
related consumables are identified in O-
-.,~-.is and related consumables sdentificaten we be mesntained condhtsons as dismantlement progresses will Lists, which are developed and are identified in.
A.- with the current.
requre the ident(scation to be maintmened maintained for each plant in accordance cnteria of Regulatory Gu 1e 1.29 as current. Thrs also complies with Cnterson R.
with the enteria of Regulatory Guide clarifed by items No. 21s and No. 21b 1.29 as clarified by items No. 20a and in Part 2 of Appendix A to thss QuaEty No. 20b in Part 2 of Appendkx A to this Program Desenption. Identification may Quakty Program Description.
be via ~O4ists.* electrorec data bases.
or other eJ;.:4 means. For Big Roca Point. this ident(scation is mamtaened current with plant w.J.i
. dunng desmentlement.
30 2.2.4 (Page 11) 2.2.4 (Page 11)
Program name change to recogruze Thss Program contmues to be appbed to j
that one plant is re longer both Consumers Energy nucieer plants, as This Oualtty Program Descnption.
This QuaEty Program Desenpten.
" Operating", but the Program st4 specified in this and later esctens, erw4=%g organized to present the Consumers organized to present the Consumers appEes.
arnpiementation ttwough procedures and i
Energy Quakty Program for Operationaf Energy Quality Program for Nuclear
- ..i. A This contmues to meet Nuclear Power Plants in the order of the Power Plants in the order of the 18 Cnterion u of 10CFR50. Appendix B.
18 criteria of 10 CFR 50. Appendtx B.
cnteria of 10 CFR 50, Appendix B.
states Consumers Energy regurements states Consumers Energy regurements
['
for each of the enteria and describes for each of the criteria and describes how the controls pertinent to each are how the controls portment to each are i
camed out. Any changes made to this cer:ied out. Any chariges mace to this Quahty Program Desenption that de not Quality Progrars Desenption t%st do not t
I reduce the e... i..
..is previously reduce the commitments presiously accepted by the NRC must be accepted by the NRC must be submitted submrtted to the NRC at least anrr-ally to the NRC at least annua 5y as specified as specified by 10 CFR 50.71.e. Any by 10 CFR 50.71.e. Any changes made i
changes made to this Quatrty Program to this Quairty Program Desenption that i
Desenption that do reduce the commrt-do reduce the m..
4..-..:s previously
[
ments prewously accepted by the NRC accepted by the NRC must be submrtted i
must be submrtted to the NRC and to the NRC and recerve NRC approval
[
receive NRC approval prior to prior to implementation in accordance amplementation in accordance with the with the requirements of 10 CFR 50.54.
requirements of 10 CFR 50.54.
i Page 9 f
t m
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALITY PROGRAM DESCRif'Tf0N (CPC 2Al REY!SION 19a hem Revianon 18 Revimien 19s Monsen for Change Besie for CaN 31 2.2.5.a (Page 11) 2.2.5.a (Page 11)
Change accounts for the fact that one This Rogram contmues to be appled to plant is no longer
- operating
- by assing both Consumers Energy nucteer plants, as Admaustrative procedures specify the Admrustrative procedures specify the broeder termmology (i.e " plant specified in tfus and later sections. including standard methods of ow. 6.:.,
standard methods of wmd.
plant activities").
unplementaten through procedures and operational phase activities. Because activities. Because the Quality Program wistructions. This contmues to meet the Quairty Program is an integral part is an integral part of these actrvsties the Cntenon 5 of 10CFR50. Appendix B.
of the operational phase activities. the methods for impeementog Quakty methods for implementing Quality Program controis are integrated into Program controls are integrated into these documents.
these documents 32 2.2.5.c (Page 11) 2.2.5.c (Page 11)
ProgranVphase name change to This Program contmuss to be appled to Sentence 1 Sentence 1 recogrwe that one plant is no longer both Consumers Energy nudoar plants, as "operstmg*, but the Program is sta specified in this and later sections. encluding Applicable elements of the operations Appbcable eier'ients of the Queirty apphed as previously stated.
smplementaten through procedures and Quaisty Program are appled to Program are applied to emergency plans.
6hia This contmues to meet emergency plans. secunty plans.
secunty plans, radiation and fire Cntenon E of 10CFR50. Appendix B.
radiation and fire protection plans for protection plans for Consumers Eriorgy Consumers Energy nuclear power nuclear power plants, plants.
33 2.2.6 (Page 12) 2.2.6 (Page 11)
Program name change to recogrue In accordance with Cntenon 5 of 10CFP50, that one plant is no longer *operateg".
Appendix B thes Program contmuss to Provisions of the Quairty Program for
^ie..~.e of the Quality Program for but the Program stir apphes as apply to activites effectmg the quality of Operational Nuclear Power Plants apply Nuclear Power Plants apply to activities educated.
safety-related SSCa at both Consumers to activites affectmg the quahty of affecting the quality of safety 4 elated Energy plants.
safety-related structures, systems, structures, systems components and w...,~.-.is and related consumables, related consumables 34 2.2.6 b (Page 12) 2.2.6 b (Page 12)
Change atows identsfication of safety-This change maintains the 10CFR50.
related by means other than an Appendix B requrement to identify sa'ety-This identification by engineenng This identification by engmeenng
- equipment data base". but stiB related equipment ary" $$Cs to which the personnel results in the classification of personnet results in the classification of requres such information to be program apphes. As Appendix B does not equspment as either safety related or equipment as either safety related or controEed and made available to refer to en " equipment data base" or *Q-no+ safety related, and the inclusion of non-safety related; identificaten may be persons envolved in plant actrvites Ust", the Program contmues to meet this classification in an equipment data via "Q-Lists, electroruc data bases or (irwewems both operations and Cntenon II.
base. This data base is available for other controlled means. This information decommsssionog). Also. recognizes moury by indnnduals anvolved m plant is available for inqury by indrviduals the need to maintain the LLI.-.
operation. The classification of snvolved in plant activities. The cummt with plant conditions as Bag structures, systems and consumables is classsfication of structures, systems and Rock Point is dismantled.
also identitied, documented, and consumables is also identifed, controlled.
documented, and controlled For Big Rock Point. this identification is maintained current with plant wi.J.i-e during dismantlement.
Page 10 i
_.~. _ _
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALITY PROGRAM DESCRIPTION (CPC 2A)
REVISION 19a J
item Revision 18 Revissen 19e Roemen for Change seeie for
- h r
35 2.2.6.c (Page 12) 2.2.6.c (Page 12)
Editonal-changes FHSR/FSAR to No effect on compliance with 10CFR50, last sentence last sentence UFHSR and UFSAR to be consistent Appendix B.
with the industry /NRC terminology.
Such determinations are based on data Such determinatxms are based on data in such documents as the plant safety in such oocuments as the plant safety analysis, plant Techrucal Specifications analysis, plant Techrucal Specificatens and the FSAR/FHSR (See Appendix A).
and the UFSAR/UFHSR (See i
Appendsu A).
)
36 2.2.9.a (Page 12) 2.2.9.a (Page 12)
Program name change to recogruze No effect on compliance with 10CFR50 that one plant is no longer *operstmg".
Appendix 8.
l The training and indoctnnation program The training and L.&-.LWiion program provides for org.ing training and provides for ongoing training and periodic refamiliarization with the penodic refamiliarization with the Quality Ouality Program for Operational Nuclear Program for Nuclear Power Plants.
Power Plants.
37 2.2.10.b (Page 13) 2.2.10 b (Page 13)
Apperutix C addresses NPAD-tSRG Neether Appendix C of this document, nor i
responsitdeties, which are the same as this specific regurement, are required by l
Management teams assess tl=e nuclear NPAD - ISRG assesses the nuclear those formerly in Techrucal 10CFR50. Appendix B. The change merely I
safety performance as desenbod in safety performance as described in Specifications. It is more accurate to clarifies orgeruzationel responesbility and Appendix C. Conclusions and Appendix C. Conclusens and refer to ISRG than to " management establishes proper reportmg relationships.
f rew...c.Wations are reported to the recommendatens are reported to the teams,* even though ISRG includes Thss continues to meet Cntens I and R of Executive Vice Presadent and Chief Senior Vice President, Nuclear, Fossil, management levet staff. Reportrig to 10CFR50. Appendix 8.
t Operating Officer - Electric.
and Hydro Operations.
the Sensor VP, NFHO recognizes the recent corporate changes at the i
President level.
38 5.2.3 (Page 19) 5.2.3 (Page 19)
Big Rock Point is new permanently The Program contmues to meet Cnterion V shutdown and wiE not rieed such of 10CFR50. Appendix 8. in that Start-up procedures that provide for Start-up procedures that provide for procedures ever again.
procedures are requeed to control safety-starting the reactor from hot or cold starting the reactor from hot or cold related activities.
condition and recovenng from reactor condrtion and recovenng from reactor trips.
trips (Palisades only).
i i
1 39 5.2.4 (Page 19) 5.2.4 (Page 19)
Big Rock Point % now permanently The Program contmues to meet Cnterion V e
i shutdown and will not need such of 10CFR50 Appendix B. in that Shutdown procedures that provide for Shutdown procedures that provide for procedures ever again.
procedures are regured to control safety-controlled reactor shutdown or controlled reactor shutdown or related activities.
i shutdown following reactor trips.
shutdown followng reactor trips (Palisades only).
c Page 11
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUAUTY PROGRAM DESCRIPTION (CPC 2A)
REVISIOri 19a horn Revimien 18 Rowison 19e Romeen for Change Semis for Canchenen 1
40 5.2.5 (Page 19) 5.2.5 (Page 191 Beg Rock Point is now permanently The Program contmues to meet Cntenon V shutdown and wM not need such of 10CFR50, Appenda 8,in that Power operation and load changing Power operation and load changing procedures ever again, procedures are regured to control safety-procedures that provide for steady state procedares that provide for steady state re.eted actrwities.
power operation and load changerig, power operation and load changmg, ancludmg response to unanticipated load ancludng respeise to unanticipetM load I
changes.
changes (Palssados ordyl.
41 5.2.7.a (Page 20) 5.2.7.a (Page 20)
Big Rock Point is now permanently The Program continues to meet Cntenon V shutdown and wM not need such of 10CFR50, Appendia 8,in that Core alterations Core afterations (Palssades ordy) procedures ever again.
procedures are regured to control safetyi-related actmtses.
42 5.2.7.b (Page 20) 5.2.7.b (Page 20)
Big Rock Point is now permanentfy The Program contoues to meet Criterion V shutdown and will not need such of 10CFR50, Appendix 8,in thet Refueleg Refuelmg (Pahsades ordy) procedures ever again.
procedures are required to control safety-related actrwitnes.
43 5.2.7.f (Page 20) 5.2.7 f (Page 20)
This change recognued that fuel This is an increase in M4ip. The movement, outssde the reactor, should Program contmues to mW Cnterion V of Fuel movement be controlled by procedures, egardless 10CFR50, Appendia 8.
of the operational phase of the facasty (apphes both to Pahsades and Big Rock Point).
44 Not in Revisaon 18 5.2.16 (Page 21)
Adds regJirement to have This is an increase in commstment and A.. '---. procedures to control T4i, not covered in Appends 8 or Decommesseneng procedures that dismantlement (at Fg Rock Point).
other Regulatory guidance.
provide for control:ed dismantlement of the plant and restoration of the p*snt site.
45 6.1 (Page 23) 6.1 (Page 22)
At Big Rock Point, the usual " Plant
- No effect on compliance with 10CFR50, Paragraph 3,
- Paragraph 3,
- Technscal Specifications are being AppenGx8.
replaced by "T-di Defueled Personnel authonred to approve Personnel authorized to approve Techrscal Specsfications*, which have procedures specified by plant Technscal procedures specified by Plant or been submrtted for NRC approval.
Specifications are limited to:
Permanently Defueled Technscal Specifications are limited to an in addition, the change ecludes appropnate serwor department manager, allowance for controlled delegation of based on the actmties addressed in the procedure approval authonty et Big specific procedure, predesignated in Rock Point, as had been prewsously writing by the Site Vice President / Site provided for Palisades.
General Manager.
Page 12
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALITY PROGRAM DESCRIPTION (CPC 2A)
REVISION 19a leem Revisen 18 Revision 19e Romeen for Change Denis for Canehenen 46 6.2.2.d (Page 23) 6.2.2 d (Page 22)
Addrtion of decommissionmg as an This is an increase in commitment and actrvity covered by contromed 6741, not covered in Appeewha 8.
Instructions and procedures for instructions and procedures for activities documents.
activities such as fatwication, such as fabrication, construction, construction, modification, installation, modsficaten, installation, inspection, inspection, test and plant maintenance test, plant maintenance and operation, and operation which :.. a...ac.i the and decommisfyung which implement Quality Program.
the Qualety Program.
47 6.2.2.e (Page 23) 6.2.2.e (Page 22)
Edrtorial - prova$es conostency with No effect on crenpliance with 10CFR50 NRC and industry termmology.
Appendim 8.
Final Safety Analysis Report / Final Updated Foal Safety Armlyses Hazards Safety Report Report / Updated Fenal Hazards Safety Report 48 6.2.2.g (Page 24) 6.2.2.g (Page 23)
At Beg Rocit Pomt, the usual
- Plant
- No effect on compEance with 10CFR50 Technical Specifications are bemg Appendix B.
Plant Techrucal Specificatius Plant Tectncal Specificatiens (Palisades) repsaced by " Permanently Defueled Techracal Specircatens*, which have been submitted for NRC approval.
49 6.2.2.h (Page 24) 6.2.2.h (Page 23) (added)
At Big Rocit Posnt, the usual " Plant
- No effect on compliance with 10CPt50 Technmal 4,JfM. are being Appendix B.
T6.w n.ity Defueled Techrscal rep. aced by
- Permanently Defueled Specsfcations Techrucal SpecWicatens*, which have been submitted for NRC approval 50 10.2.2 (Page 28) 10.2.2 (Page 28)
Addsten of 4.w....
1--., as an This is an incresee in w.....a..-.a and First sentence First sentence activity subrect to inspecten.
wfuirnot covered in Appendix 8.
Inspections are applied to procurement, inspectons are applied to procurement, maintenance, modification, testing, fuel maintenance, modif' ation, testmg, fuel c
handimg, and insee srice inspection to handhng, enserv=ce enspection and verify that items and activities conform decommesesonmg to verify that items to specified requirements.
and activities conform to specified requirements.
51 10.2.3 (Page 29) 10.2.3 (Page 29)
Change in title of the senior manager No effect on compliance with 10CFR50, Last sentence Last sentence at Big Rock Point.
Apperwhx B.
The Site Vice PresidentiPlant General The Site Vice Pressc ent/ Site General e
Manager is responsable for review and Manager is resgr-6 for review and concurrence with plant training and w..w..
- with plant training and qualification programs that are under his qualrfication programs that are under has derect et o mbeirty direct responsibility Page 13
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALfTY PROGRAM DESCRIPTION (CPC 2Al REViSK)N 19a seem Rowseien 18 Revisen 19e Reason for Change Semie for Ca%
52 10.2.3 (Page 29) 10.2.3 (Page 291 Edstorial - corporate group tatto change No effect on compliance with 10CFR50, Paragraph 3 Paragraph 3 enedvertenefy missed in tres seccon Appendix 8.
with Revisson 18.
Trairwng and quakfacation programs for Trainmg and quahfication programs for System Maintenance and Construction Electnc Services personnel who perform Services (SM&CS) personnel who inspections are documented in Electnc perform inspections are documented in Services procedures.
SM&CS procedures.
53 11.2.2.c (Page 31) 11.2.2.c (Page 31)
Pre-op test wnII no longer apply to Big The Program contmues to meet Cnterion XI Rock Point as the plant will not restart.
of 10CFR50, Appendix B,in that necessary Prewational tests to assure proper Pre-operational tests to assure proper testmg is required.
I and safe operation of systems and
'ywf safe operation of systems and equepment pnor to startwap tests or equipment prior to start <sp tests or operations.
operations (Pahsades Ordy).
54 11.2.2.d (Page 31) 11.2.2.d (Page 31)
Startssp tes s wsN no longer apply to The Program contenws to meet Cntenon XI Beg Rock f% int as it is permanently of 10CFR50, Appendix B,in that necessary Start <sp tests, sncluding precntcal, Start 4sp tests, including precntical, shutdown.
testing is requeed.
criticality, lowwwer, and power enticahty, lowwwer, and power ascensson tests, performed after ascensson tests, performed after j
refueling to assure proper and safe refueling to assure propor and safe operation of systems and equipment.
operation of systems and eque,w (Pairsades Only).
55
,17.2.2.f (Page 39) 17.2.2.f (Page 39)
Edrtorial. Records requeements This is an increase in specific.ty not covered formerfy in Plant Technscal in Appendix 8.
Records required by the Plant Technscal Records required by Appendix E S44 have been included Spoofications instead in Appendix E to ttus Program.
This change was inedvertently omitted from Revisson 18.
56 Appendix A. Part 1 (Page 44)
Appendix A Part 1 (Page 44)
As the sections of Appendix R relate No effect on compliance with 10CFR50, item 21 Item 21 to aftemate safe shutdown capabihty, Appendix 8.
they no lenger apply to Big Rock Pomt.
IP CFR 50, Appendix R. Fire Protection 10 CFR 50, Appendix R, Fire Protection which is permaner tfy shut down and Program for Nuclear Power Faciisties Rogram for Nucle 9 Power Faciirtes defueled.
Operating Prior to January 1,1979, Operateg Prior to January 1,1979, Sections m G., m J. and m O.
Sections m G., m J. and III O. (Not appbcable to Bsg Rock Point)
Page 14
ATTACHMENT 2 CHANGE MATRIA 09XE17 3
REYGON 19a hem Rowision 18 Rowsmen 19e Reemen for Change Semie forch 57 Appendix A. Part 1 (Page 47)
Apperdx A. Part 1 (Page 47)
Change recoyuzes that actrwees at No effect on w.,
wth 10CFR50 Item 2f.
Item 2f.
the plant ooms decomnussened wiB Appendix 8.
aino be sutgect to suets.
Excentson/Internretaten Excactm1nternretaten Austs of operatonal nuclear safety Audets of nuclear safety related faciEty related facility actinctes a o actrwities are performed under the
@-k,ca d order the cognirance of cognizance of the Nuclear Performatice
[
the Nuclear Performance Assessment Assessment Department as desenbod Department as described in Apperda in Apperda C. Independent Safety f
C. Independent Safety Renew.
Review 58 Appendix A. Part 1 (Page 48)
Appendix A. Part 1 (Page 48)
Change recogruzes that Big Rock Point No effect on compEence *wth 10CFR50, item 2h. : Exceptiorenterpretation b.
Item 2h. : Exc.v;M a r.i.0.-. b PRC wie become SRC* upon approwel Appendix 8.
of this change. Aieo. Big r.ock war no The change is approved by two fhe change is approved by two longer have Ecorwed Senior Reactor members (or des.gnated afternates) of members (or designated attomatest of Operators, but win have Cartried Fuel the PRC at least one of whom holds a the PatC/SRC, at least one of whom Handlers. The Ft# Henr9er Senior Reactor Operator I.Jeenee; and holds a Sener Reactor Operator tscense certification program hos been (Palisades) or is a Certsfied Fuel Handler submstted separately for N9C review.
(Big Rock Point); and 59 Appendix A. Part 1 (Page 48)
Apperdx A. Part 1 (Page 48)
This change provides elbowerce for No effect on compEence with 10CFR50.
i ttem 25. : Exception /Interpretaten c item 2h. Excepten/ Interpretation c carecaed delegation of procedure Apperdx 8.
[
temporary change approvat authonty The change is de umented, h change is h.
aed.
at Big Rock Point, as had been j
subsequently reviewed by the PRC subsequently reviewed by the Palisades prewsously snovided for PaEsodes. This wrthin 30 days of issuence and PRC w. thin 30 days of issuance, or by change is consstant with the same approved by:
the Big Rock Point SAC at its next change erwJe to section 6.1.
p recusar meetmo, and approved by an
- 1. Appropnate* senior Palisades appropnete* senior department maneger department manager predesegnated by the Sete Vice predemonated by the Site vece Preesdent/ Site Generaf Maneger.
President; or I
- 2. h B.g Rock Point Plant General Manager.
i Page 15 i
ATTACHMENT 2 CHANGE MATRIX 09/0997 CUALITY PROGRAM DESCIW' TION (CPC 2Al REVISION 19a hem Revision 18 Revision 19e Roemen for Change Semis for Ph 60 Appendix A. Part 1 (Page 48)
Appendx A, Part 1 (Page 48)
This cherige provides agowance for
% effect on -, f,, with 10CFR50, item 2h. : Exception,1nterpretation c*
Item 2h. ; Exception / interpretation c*
controned C 4.of procadure Apperufax 8.
temporary change approwel authonty Determenation of the apprornate senior Determmation of the appropnote sermor at Big Rock Point, as had been PaEsades department manager is based department manager is based on the previously included ire the Paloudes on the actrvities addressed in the actrwities addressed in the specire Techrscal Specsrcations. This change specific procedure, and win be procedure, and wiU be predessgneted in is conesstent with the same change predesignated in wntmg by the writing by the Palisades Plant Site Vee made to section 6.1.
Palisades Plant Site Yace Pressdent.
Weesdent/ Beg Rock Pbint Site General Menager.
61 Appendix A. Part 1 (Page 51)
Apperufix A Part 1 (Page $1)
Edtorial - change "is* to "are* to No effect en compliance with 10CFR50, from 2p. : Exception / Interpretation item 2p. : Exception /Inte.twetation correct grammatical error.
Appendix B.
Maintenance and modarcation activities Maintenance and enoderscation actrwitnes which are withwi the skills of which are within the skins of Cornumers Consumers Energy maintenance Energy mentenance parsonnet and are personnel and is camed out using camnf out using Consumers Energy Consumers Energy procedures may be procedures may be inspected by mopeced bv independent venfiers mdspendent verifiers qualified in quairfiet ccordance with Sections accordance wrth Sectums 10.2.3, 10.2.3, Z.7 and 10.2.10 of this 10.2.7, and 10.2.10 of this program g
program c scriptiort desenption.
62 Appendix A. Part 1 (Page 64)
Appendim A, Part 1 (Page 64)
Estenal-change *G.1* to *8.1* to No effect on comphence with 10CFM50, Itam 15e : Ex6,n,.#.s.,.ention item 15e : Exception / Interpretation correct typograchcal error.
Appendix 8.
first sentence first sentence Coneus. ors Energy fosows the Coneurr ers Energy fotows the requwements of ANSI N45.2.11-1974, regurements of ANSI N45.2.11-1974, Mion G.1, and the guidance of Section 6.1, and the guidance of Section Section 3E4(a) of the Standard Review 3E4(a) of the Standard Review Plon, Plan, with the exceptum that use of with the exception that use of supennsors as deesgn venfiers may be supennsors as doesgn venfiers may be contro5ed by a processe instead of contro5ed by a procedure instead of monnduasy approved in advance in each mdividuany approved in advance in each case (see Section 3.2.9, heremp.
case (see Section 3.2.9, hereini.
63 Appendix A. Part 1 (Page 681 Appendix A, Part 1 (Pege 68)
Estonal - changes :-.-@ to be No effect on comphance with 10CFR50.
frem 21a : Exception / Interpretation item 21a : Exception /Interpretatr9 conesstent with NRC and industry Appendix B.
Second sentence Second sentence usage.
The specife dessgn citena and seesme The specife design cntena and sessme dessgnations are reflected in the FHSR wesignations are reflected in the UFHSR and FSAR, respectrvely, and in other and UFSAR, respectrvebr, and in other docketed analyses.
docketed a intyses.
Page 16
ATTACHMENT 2 CHANGE MATR!X 09/05/97 QUALITY PROGRAM DESCRIPTION (CPC 2Af IEVfSION 13a Item Rowloien 18 Rowissen 19e Roosen 9er Change Semie 9erch 64 Apperufoces B. C. D, and E Apperufices B. C, D, and E (with These Appendices contae 10CFR50 Appenen B. does not promde changes utentified belowl regurements formerfy encluded is. Beg explicrt regurements for function of onsite Rock's operating plant Techrucat safety reweew Howwwer, Plant Techracat Sv Jw Wrth tre change to Specrrications did provide these I
PWrmanentfy Defueled Techrecal regurements.
l Specifications, these regurements are j
bemg reiocated to ttus Program, i
consistent with NRC gualence in I
Admrustratrwe Letter 95-06. Changes l
from the operetnig Plant Techncal j
Specshcations are sdent(sed and j
drecussed endnnduopy below. ( Note j
that these regurements were included I
in CPC.2A. begrwung with f% vmsion 16, in anocipation of ree-@ %
operating Plant Techre af r
Spoofications. Final NRC approval of relocation from the Palisades Tech Specs is aritscosted by October 1997.
Approvas of Big Rock PDTS was complete the reiocatiord 65 QPD M ANUAL. APPENDIX B (Page 71)
QPD MANUAL, APPENDIX B (Page 709 Portions of the previous Big Rock Peint 10CFR50. Appendia B. does not prownse Title Cunnge Title Change technical Spec (scacon are now' empisest regurements for function of oneste included in this Program. With this safety review. However, Plant Techracal QFD MANUAL QPD MANUAL: APPDetX B revisum, changes are mode (as Spectications did provide these APPENDtX B F1 ANT REVIEW COMM'TTEE (PRO
<lescribed belowl to make regurements, and ttus Program's PLANT REVIEW COMMITTEE (PRO (PALfSADES) regurements for the onerte review commitment to Riig Guide 1.33 also SAFETY REYtEW COMM!TTEE fSRO function consistent with those granted inc9udes regurements for ttus function.
(BIG ROCK POfMT1 to other plants in the 4n~..-
_-e.e phase,includwig changing the nome to
" Safety Review Commettee*.
Permanentfy defueded Techrucal Sv~FA. have been submrtted for NRC approval twrthout the regurements covered hereinl.
66 QPD MANUAL. APPENDfX B (Page 71)
QPD MANUA( APPENDtX B (Page 708 Change to Big Rock Point SRC, and No effect on compliance with 10CFR50, B1 B1 change in title of senior manager at Appenda B.
Big Rock Point.
The Plant Review Commrttee (PRQ The Plant Review Commrttee shas function to advise the Sete Vice (PRQ/ Safety Review Committee (SRQ PressdentJPlant General Manager on as shall function to adnse the Site Vice matters related to nuclear safety.
Pressdenusite General Manager on as matters related to nuclear safety.
Page 17
A7TACHMENT 2 CHANGE MATRIX 09/05/9#
QUALfTY PROGRAM DESCRFTION (CPC 2Af REV'S!ON 19a leem Rowissen 18 Rowissen 19e Roseen for Change Seeie foreh 67 QPD MANUA*. APPENDtX B (Page 71)
QPD MANUAL APPENDIX B (Page 70)
Changes matte the Big Rock Point SRC 10CFM50. Appendra B. does not grovute l
B2 Paragraph 2 B2 Paragraph 2 regurements conostent vnth those empact regurements for funcnon of onerte granted other plants in safety renew. However, Plant Tedrucal The Big Rock Point PRC is composed of The Big Rock Point SRC is composed of decommesssorung, and recognize the Spec #catens did prowde these nine regular members from the Beg Rock a Charman and a trunamum of four sagndicantty reduced scope of safety-reguremants.
Point staff. The PRC members shes members from the Big Rock Point staff.
related actrwrties to which ttus review l
meet or exceed the merumum The 3RC members shas meet or exceed function appries. 8% duction to 5 Whde the trununum nurnber of SRC qualifications desenbod in Sections 4.2 the mrumum qualifications desenbod in members and, etwtunatiori of spec #ic members is reduced. qual (scation and 4.4 of ANS! N18.1 1971 for Sections 4.2 and 4.4 of ANSI N18.1-departmental memberstup rogurements remore the same. Reg Guide comparable positaans. The PRC shaR 1971 for comparable positens. The regurernents is also related to reduced 1.33 (ANSI N18.7) does not estabirah a include representatnres from the members shaE be designated in scope of safety 4 stated actrweties.
spoofic number of persons for the oneste Operations. Chemistry / Health Physics, adrr:snestrative procedures by the Site safety review functen. Thus, the Program Maintenrnce. Engmeenng, and Safety General Manager. The Site General carenues to meet Cretenon N of 10CFR50.
and Lscensmg Departments. The Manager shall also dessgnate an Appendix B.
membertshall be designated in Altemate Charman in writing.
admirustrative procedures by the Plant Manager who is the Charman of the PRC. The Plant Manager sha5 also designate en Altemate Chasrman in wnting.
68 QPD MANUAL. APPENDfX B (Page 71)
OPD MANUAL. APPENDEX B (Fage 70)
Because the total SRC memberstup 10CFR50. Appendur B. does not prowde B3 83 and quorum regurements are reduced, espect sequwements for funcnon of onsste it is appropnate to reduce the allowed safety reweew. However. Mont Technscal Altemate members of the PRC shaE be Altemate members of the PRC/SRC shes number of SRC attemetes. This is Spec #scatens did prowde these appomted in wnting by the PRC be opponted in wntog by the PRC/SRC consistent with Techncal regurements.
Charman to serve on a temporary Charman to serve on a ternporary basis.
S N
L-for other basis. No more than two aftomates No more than two altamates shas decommessened plants.
shaE participa'e as voting members at participrer as voting members at any any one time in PRC actintes.
one time in Palisades PRC actnnties, nor i
more than one aftomate in Big Rock Point SRC activites 69 QPD MANUAL APPENDIX B (Page 71)
OPD MANUAL. APPENDtX B (Page 709 Split to retari Palmades PRC meeting No effect on cornpEance with 10CFR50.
B4 Paragraph 1 B4 Paragraph 1 frequency as before (see below).
Appende B.
The PRC shaE meet at least once per The Palisades PRC sheE meet at least calendar month with speaal meetmos once per calendar month with special as required.
meetings as regured.
Page 18
\\
ATTACHMEOT 2 CHANGE MATRIX 09/05/97 OUAUTY PFIOCRAM DESCRIPTION (C5'C 2A)
REVISION 19e Row elon 18 Revision 19e Rennen for Change Seelefor'" h s
stem 70 QPD MANUAL. APPENDtX B (Page 71)
OPD MANUAL APPENDIX B (Page 708 Recogruzes that once spent fuel is 10CFR50. Appendus B. does not provide B4 Paragraph 2 B4 Paragraph 2 safely stored outssde the former spent expEat regurements for function of onerte fuel pool (dry storaget. only the sa'ety renew. However Plant Techrucal Paragraph added in CPC-2A, Rev 19a.
The Big Rock Point SRC sha5 meet at penode moratonne of that poserve Specifications 6d prowde these least monthly while fuel is stored in the storage system wiB be subyect to SRC regurements.
spent fuel pool dunng the pre-renew. Reducten in meetmg dismantlement and desmentlement frequency is conoster:t with reduced phases. Dunne the safe storage phone risk to the heefth and safety of the (no fuel in the r ent fuel poo0. SRC shes public.
meet at least gi Jterly.
.I OPD MANUAL. APPENDtX B (Page 71)
OPD MANUAL. APPENDtX B IPage 701 Because the total SRC membership is 10CFR50. Appendra B. does not prowde B5 B5 reduced,it was appropnete to reduce expliert regureme its for functen of oneste the number recured for a quorum, safety renew However Plant Technscal A quorum of the Palisades PRC sha8 A quorum of the Palisades PRC shen This is conesstent with the approach Speedications ed provide these consist of the Chosrman or attemate and consnst of the Charman or altomate and for onsite sefety renew at other regurements.
four members or altamates. A quorum f.msr members or aftemates. A quorum
(.--....- 4 plants.
of the Big Rock Pbint PRC shot consist of the Beg Rock Point SRC shaR consist of the Charman or attemate Chosrman of the Charman or altamate Charman and four enembers or a!temetes.
and two mer bers or attemates.
72 QPD MANUAL. APPENDtX B (Page 71)
OPD MANUAL APPENDIX B (Page 701 Name change to include Big Rock No effect on compreence with 10CFR50 B6 86 Posnt SRC.
Amendia B.
The PRC shaR be responssble for nuclear The PRC/SRC shot be responsible for safety review of:
nuclear safety rewew of:
73 QPD MANUAL. APPENDEX B (Page 71)
OPD MANUAL. APPENDtX B (Page 703 Change in title of sernor manager at No ef*ect on compliance with 10CFR50.
86.a B6.a Big Rock Point.
Appendix 8.
A5 procedures and programs specified AE procedures and programs spec fied by the Techrmcal Specifications and by the Techrucal Spearications and changes thereto, and any other changes thereto, and any other procedures or changes thereto as procedures or changes thereto as determined by the Site Vsce determined by the Site Yace President / Plant General Manager to President / Site General Manager to affect aCfect nuclear satety; as proposed tests nuclear safety; as proposed tests or or expenments that affect nuclear expenments that affect nuclear safety-safety; a5 proposed changes or a5 proposed changes or modirscations to modsfications to p' ant systems or plant systems or equiprnent that affect equepment that affect nuclear safety.
nuclear safety.
Page 19
ATTACHMENT 2 CHANGE MATRIX 09/05/97 QUALfTY PROGRAM DESCRIPT?ON fCPC 2Al REV!SION 19a hem Revision 18 Rosemien 19e Roemen for Change Basis for Condessen 74 QPD MANUAL, APPENDIX B (Page 72)
QPD MANUAL, APPENDtX B (Page 71)
Change in t:tle of senior manager at No effect on m. f _ - vnth 10CFR50, B6.e B6 e Beg Rock Pbint.
Appendix B.
Repore of speoal revurws and Reports of specal rewews and investigations as requested by the Site investigotions as requested by the Site Vice Pressdent/Ptant Genersi Manager or Vece President / Site General Manager or NPAD.
NPAD.
75 QPD MANUAL, APPENDIX B (Page 72)
QPD MANUAL, APPENDIX B (Page 71)
Change in title of sensor manager at No effect on compliance with 10CFR50, B6 k B6.k Beg Rock Point. (Note that tNs item Appendix B.
was a regurenwnt in Beg Rock's Revew of any acodontal, unplanned or Rewow of any acendental, unplanned or operating Technscal Specsfications that uncontrolled radioactive release uncor-trolled redsoactive release including was ggg included in the Palisades encluding the preparation of reports the preparation of reports covenne Technscal Spooficatens prior to their covenng evaluation, recommendations evaluation, recommendetsons and relocation to triis Program 3.
and esposition of the corrective action disposition of the corrective action to to prevent recurrence and the prevent recummco and the forwarding of forwardeng of these reports to the Plant these reports to the Site General General Manager and to the Manager, Manager and to the Manager, Nuclear Nuclear Performance Assessment Performance Assessment Department Department (Big Rock Point only).
(Beg Rock Point ontyi.
76 QPD MANUAL, APPENDtX B (Page 72)
QPD MANUAL, APPENDIX B (Page 71)
Change retams allowance for Beg Rock 10CFR50. Apperdix B. does not proude B6 last paragraph B6 last paragraph SRC to use toutine renew, as was explicut regurements for function of oneste allowed by operating Tech Specs.
safety rewow. However, Plant Techncal PRC review of the above items may be PRC/SRC renew of the above items may Also, restores item f. For Palisanes Spooricatsons did promde these performed by routing, subrect to the be performed by routing. subsect to the revew by S!DR staff, which was regurements.
regurements of B7. below. The regurements of 87. below. The wworertently Orrutted from Remoson Palisades PRC may delegate rewew of Palisades PRC may delegate review of I B.
item a. to Safety /Dessgn Review staff, item a. and f. to SafetysDessen Renew as desenbed in 89. below.
staff, as described in 89. below.
77 QPD MANUAL, APPENDtX B (Page 72)
QPD MANUAL, APPENDIX B (Page 71)
Change retaans regurements for Beg No effect on compliance with 10CFR50, 87 B7 Rock SRC.
Appendix B.
The PRC sha8t:
The PRC/SRC shall:
78 QPD MANUAL, APPENDIX B (Page 72)
OPD MANUAL, APPENDIX B (Page 71)
Change in title of sensor manager at 10CFR50 Appendia B, does not prowde 87.a B7.a Big Rock Point.
explicst regurempts for function of onsste safety renew. However, P". ant Techrscal Recommend in wnting to the Site voce N.~....-..J in wnting to the Site Vice 6& &.dd prende these President / Plant General Manager Pressdent/ Site General Manager approval regurements.
approval or disapproval of items or desapproval of items considered under considered under B6.s. through j.
B6.a. through j. above.
above.
Page 20
ATTACHMENT 2 CHANGE MATRfX 09/05/97 QUAUTY PROGRAM DESCRPTION iCFi -2Al PEV!S!ON 13a item Revision 18 Rev6sson 19e Reeson for C%
Basis fer Conclusion 79 QPD MANUAL APPENDIX B (Page 72)
QPD MANUAL, APPENOlX B (Page 71)
Change is trile of sermor manager at No effect on -4 enth 10CFR50, 87.c B 7.c Big Rock Pbent and inclusson of Big AppendemB.
Rock SRC Provide wntten notdcation withLi 24 Provide wntten notifcatim within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Voce Pres. dent -
hours to the Senior Vice Pressdect -
Nuclear, Fossil, and Hydro Operations Nuclear, Fossit, and Hydro Operations and to the Nuclear Performance and to the Nuclear Performance Assessment Department of any Assessment Department of any l
das-m. 5 sits between the PRC and desagreements between the PRC/SRC l
the Srte Voce Pressdent/ Plant General and the Site Vsco Pressdent/ Site Generaf Manager; however, the Site Voce Manager; however, the Site Vee President / Plant General Manager shaC Pressderrt/ Site General Manager shat have responsstritty for the resoluten of Save responsibiEty for the resolution of such disagreements.
such disagreements.
80 QPD MAWAL APPENDIX B (Page 72)
QPD MANUAL, APPENDtX B (Page 72)
Cha9ge retsins same regurements for 10CFR50. Appendia B. does not provide 87 paragraph 6 PaEsades Regurements 87 paragraph 6 Palisadas Regurements Paissades. but reduces Big Rock explicrt requiremerus for functon of onsste numbers to conform to the new SRC safety review However. Plant Technical The PRC Charman may wm 4 to The PPC/SRC Charman may recommend quarum regurements.
Speedicatens did prmnde these the Sete Vice Pressdent/ Plant General to the Site Vice Pressdent/ Site General Manager approval of those items Manager approval of those items reguremer ts.
identafsed in 86. above based on a identif;ed in B6. above based on a routmg review provided the foRowing roudng review provided the fo8owing conditsons are met: (1) at least five condetens are met:
PRC members includsng the Charman and no more than 2 aftsmates, shan For Palisades:
l review the item, concur with determmation as to whether or not the (1) at least five PRC members item constitutes an t.i...a
" safety encluding the Chairman and no more question, and provide written comments than 2 afternates, shas review the on the item; (2) a5 comments shaR be item, concur with deten9snation as to resotved to the satisfaction of the whether or not the item constrtutes an reviewers providng the cc...
- a. and unreviewed safety question, and (3) if the PRC Charrman determenes that prmnde written comments on the item; the comments are svh d, the item (2) aR comments shaR be resotved to (includeg comments and resolutions) the satisfaction of the reviewers shan be recaculated to a2 ;;.a ai. for provideng the comments; and (3) if the additional comments.
PRC Charman determmes that the comments are sigraficant, the item (including comments and resolutions) sha5 be recrculated to a5 se.-.
for addrtional comments.
l Page 21
ATTACHMENT 2 CHANGE MATRfX 09/D5/97 QUALTTY PROGRAM DESCRIPTON FCPC-2A1 REVTSON 19a hem Revis6on 18 Meweeson 19e Roemen for Change Semis for CoM 81 QPD MANUAL. APPENDIX B (Page 72)
OPD MANUAL APPENDIX B (Page 72)
See above.
See above.
B7 paragraph 6 Big Rock Point 87 paragraph 6 Beg Rock Point requirements requrements For Bio Rock Point (1) at least three SRC members, melud ng the Chairman and not more than one aftomate, shaN review the item, concur with determmation as to whether or not the item constnutes an w..a..,.3 safety questrm, and prowde wntten comments on the item; (2) as comments sheB be retoived to the satisfaction of the reviewers prmndmg the comments; and (3) if the SRC Charman determenes that the comments are 6.hs, the item (includog comments and resolutions) sher be recirculated to as a.,...
82 QPD MANUAL APPENDtX B (Page 731 QPD MANUAL APPENDIX B (Page 72)
See above.
See above.
87 last paragraph B7 last paraqraph The item shes be rowewed at a PRC The item shaR be revsewed at a meeting in the event that: (1)
PRC/SRC meetog in the event that I
Comments are riot resolved; or (2) the Comments are not resolved; or (2) the Site Vice President / Plant General Site Vece Pressdent/ Site General Manager Manager everndes the ovemdes the recommendations of the recommendations of the f7tC: or (3) a PRC; or (3) a proposed change to the proposed change tn the Technscar Technical Specsfications wwolves a Specifications involves a safety Emit, a safety limrt, a timrting safety system limrting safety system settmg or a settmg or a limiting condrtion for limrtog condition for operation; or (4) w
.&m. or (4) the item was reportable the item was re;nortable to the NRC.
to the NRC.
83 QPD MANUAL, APPENDtX B (Page 73)
QPD MANUAL, Af'PENDtX B (Page 72)
Change establishes regurement for Beg tuCFR50. Appendix B. does not prowde B8 B8 Rock SRC.
expisot recuremer ts for function of onsrte safety review. However, Plant Te:hnscal The PRC shes masntain wntten mmutes The PRC/SRC shaE mentain wntten Specsfications did prowde these of each PRC meeting and shas provide manutes of war N PRC rneeting and sha8 regurements.
copes for independent Safety Renew.
prowde copes fr -Independent Safety Review.
Page 22
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ATTACHME.1T 3
- CONSUMERS ENERGY BIG ROCK POINT PLANT DOCKET 50155 LICENSE DPR 6 PALISADES PLANT DOCKET 50 255 LICENSE DPR 20 CURRENT APPROVED AND ISSUED VERSION
. CPC 2A, REVISION 18 l
83 PAGES d
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.J June 6,1997
SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS ENERGY PROGRAM FOR OPERATIONAL NUCLEAR POWER l
PLANTS As President and Chief Executive Officer of Consumers Energy, I have the ultimate management authority for the Consumarn Enarav Quality Pronram Damerlotion for Ocarational Nuctaar Power Plants. The Quality Program Description complies with the quality assurance requirements contained in~ Appendix B of 10 CFR 50i"Qualir, Assurance Criterla~ for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the ad /tlonel guidance contained in ANSI N1.8.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of applicability imposed b) N18.7. The Quality Program Description for Operational Nuclear Power Plants outlines the act;oris that are implemented during the operational phase including fueling, testing, operation, refueling, procurement, maintenance, repair, and modification design and constmetion 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 Techn. ology,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.
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Dageli Rev 18 Date! June 6,1997 l
QUAllTY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS REVISION 18 i
APPROVED BY:
$ SO
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Elteeetive Vice eside and Chief Operating Officer Electric
' Da'te David W. Joos 0
-_ A 30 97 l Sr. Vice P' resident, N' clear, Foseil, and Hydro Operations Date u
Robert A. Fenech M/M99 Vice Preside'nt, Electric TranMelon and Distribution Date' Carl L. English C C% V.
~
' Owf7 Vice President. Information Technolopgend tions Services Dato Kenneth Emery SI3ofe7 Vice President and Secretary
' Date Thomas A. McNish
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Page ili Rev 18 Datet June 6,1997 QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANT 4 CONTENTS Section Title
,E>.
Statement of Responsibility and Authority l
Approval Page il Contents lii 1.0 O RG A N IZ ATIO N...........................................
1 2.0 QU ALITY PRO G RAM........................................ 10 3.0 D E S IG N C O N T RO L.......................................... 14 4.0 PROCUREMENT DOCUMENT CONTROL........................... 17 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS..................... 19 6.0 DOCU M ENT C O NTROL....................................... 22 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES....... 24 8.0 IDENTIFICATION AND CONTROL OF lTEMS........................ 26 9.0 CONTROL OF SPECIAL PROCESSES..'........................... 27 10.0 I N S PE C TI O N.............................................. 28 11.0 T E ST C O NT R O L....................'....................... 31 12.0 CONTROL OF ME'dSURING dND TEST EQUIPMENT... _................ 33
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13.0 H ANDLING,' STORAGE AND SHIPPING,........................... 35 14.0 INSPECTION, TEST AND OPERATING STATUS...................... 36 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS............. 37 10.0 C O RR EC TIV E AC TIO N....................................... 39 17.0 Q U ALITY R E C O R D S......................................... 40 18.0 AUDITS.................................................
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A PPE N D I X A
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A PP E N D I X B........................................................... 71
- A PPE N D I X C........................................................... 74 A PPE N D l X D........................................................... 77 l
I A PPE N D l X E........................................................... 78 i
FIGUME i
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Date: June 6,199 5 i
l 1.0 ORGANIZATION p
1.1 REQUIREMENTS.
l Consumers Energy is responsible for establishing and implementing the Quality Program, as l
- 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 3
7 contractors and consultants, Consumers Energy retains overall responsibility.
l l
This section of the Quality Program Description (OPD) identifles the Consumers Energy l
organizations responsible for activities effecting the quality of safety related nuclear power 4
r plant structures, systems and components and describes the authority and duties assigned to i
l.
them, it address' J responsibilities for attaining quality objectives; for establishing and main.
telning the Quality Program; and for assessing the performance of activities effecting 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 (NPAD) functions (audits, surveillances, and l
independent safety reviews) are performed by personnel within formally designated or.
l ganlaational units that report to the Manager, Nuclear Performance Assessment or members of other orgenlaations as selected by the Manager, Nuclear Performance Assessment. The reporting level of the Nuclear Performance Assessment organization affords sufficient authority and orgenlaational freedom, including sufficient independence from the cost and schedule impacts of Nuclear Performance Assessment organisation actions, to enable people
{
in that organization to identify quality problems) to initiate, recommend, or provide solutions; i
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 OPD:
4 Parnaranh Excentionalinternratations 1.2.1 2a -
1,2.2 2g-1.2.2.c 2,2b,2c 1.2 IMPt.EMENTATION
~
1.2.1 Raurce of Authority
- The President and Chief Executive Officer (see Figure 1, Company Organization Chart) of Consumers Energy is responsible for safe operation of Consumers Energy nuclear power l-l plants. Authority and responsibility for establishing and implementing the Quality Program for plant operations, maintenance and modifications is delegated through the Executive Vice L
President and Chief Operating Officer. Electric to the Senior Vice President. Nuclear, Fossil, and Hydro 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.
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l 1.2.2 Reanonsibility for Attainina Qualitv Obiectiven at the Nuctaar Planta l
The Senior Vice President Nuclear, Fossil, and Hydro Operations (NFHO) is responsible to the Executive Vice President and Chief Operating Officer Electric for operation and maintenance l
of Consumers Energy nuclear power plants. Managers who report to the Vice President, NFHO, are responsible for directing the performance of activities that affect safe plant operation and/or safety related functions of structures, systems and components of the l
operating nuclear power plants in accordance with Quality Program requirements, The Palisades Plant Site Vice Presiderit (see Figure 1)is responsible to the Senior Vice s.
President. NFHO for operation and maintenance of the nuclear power plant in such a msnner as to achieve compliance with Plant licenses, applicable regulations and the l
Osality Program. The Site Vice President delegates to appropriate managers and staff personnst in his organization responsibility for carrying out applicable controls required by the Quality Program.-Ouality Program activities performed on the authority of the Site Vice President include:
Qualification of plant operating,inspectionimaintenance and enginesting personnel, including certification of inspection personnel.
Preparation, review and approval of procedures and instructions.
Modifying components, including procurement, installation, inspection and testing activities.
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 111 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 systw.ti Maintaining a Master List for plant owned PL M&TE." -
Performing start up and operational testing, such as procritical 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.R18 e
Page 3 R:v18 Date: June 6,1997 Plant site inspection program, including inspection of maintenance, testing and fuel handlic;.
Assuring that nonconforming items are identified, segregated and dispositiened.
l Procurement of nuclear fuel and associated services, including source verification at fuel L
supplier f acilities, fuelinspection upon delivery and review of fuel supplier quality related documentation Reactor engineering such as accident transient and physics analysis of reloads, reactor core t,nd 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 improvenient Establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program Indoctrination and tr.ining.
Conducting the inservice inspection program in accordance with technical specifications and State of Michigan ruiss.'
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Performing reviewsito' advise'the Site Vice President:on matters related to nuclear safety, l
as specified in Appendix B, Plant Review Committee.
Accomplishing plant licen1ing activities including maintainir.g licens ng documents up to-date, interfacing with the NRC, accomplishing and/or tracking licensing commitments and coordinating inWrnal 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 de' ign and configu~ ration control authority for corhpliance of plant s
modifications and design changes to saisting plant design criteria. This includes prepar-ing, reviewing arid approving changes to plant engineering / design documents.
. u. a Performing the engineering, procurement, construction, inspection and testing associated with generating plant modification projects as assigned.
Providing, as requested, technical expertise and review capability to Nuclear Plants in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil structural engineering and application of codes and standards.
Preparation review and a; proval 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 pows: supply f acilities of the transmission no;viork and onsite power supply.
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- Rey 18 Date: June 6,1997
- l Procurement, including preparation, reviews arid approval cf purchase requests for spares, replacement items, consumables, and materials, items ant 4 vices and submittal of purchase requests to Purchasing. Planning and execution of ' em e source surveil.
lance or inspection, receiving inspection, and review of supplier W, related documentation, as well as vendor surveys for urgent procuremerw..
Providing for storage and protection of purchased materials and items and items awaiting disposition implementation af ter 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 I
retrievability. This includes collecting, storing, maintaining, distributing and controlling plant engineering / design documents, b.
The Big Rocli Poin~t Plant General Manager (see Figure 1) is responsible to the Senior Vice
~
President NFHO for operation and maintenance of the nuclear power plant in such a l.
manner as to achieve compliance with Plant licenses, applicable regulations and the Quality Program. The Plant General Manager delegetes to appropriate managers and j
- staff personnel in his organization responsibility for carrying out applicable controls required by the Quality Program Quality Program activities performed on the authority
-l of the Plant General Manager include:
Qualification of plant operating, inspectioWand maintenance giosonnel, iriciuding certification of inspection personnel.
Preparation, review and approval of plant proceducee and instruc+5ns.
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 l
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 eartring that _suchse cannot result in operation outside Technical Specifications limits.
Maintaining Echelon ill calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL M&TE) and Health Physics PL M&TE (HPPL M3 ATE).
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 procritical and criticality tests, low-pnwer, powar ascension and plant tests, and surveillance testing.
CPC 2A.R18 i
Page 5 Rev 18 Date: June 6,1997
- Maintaining equipment status control.
Maintaining required controls over chemical standards and reagents.
Conducting a water chemistry program in accordance with technical specifications.
Stopping unsatisf actory work to control further processing, delivery or installation of nonconforming materials or items.
Plant site inspection program, including inspection of maintenance, testing and fuel handling.
Preparation, review, and approval of Q-list updates.
Assuring that nonconforming items are identified, segregated and dispositioned.
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 Guality Program indoctrination and training.
Development and utilization of nuclear plant probabilistic safety assessment models to l
evaluate safety and plant relia ~ bilityTthproFement.
Procutement, 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 surveil.
lance of 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 riisposition implementation.after removal from, service, assuring preservation of identification.
f Accomplishing plant licensing activities including maintaining kicensing documents up to-date, interf acing with th_e NRC, ac' omplishing and/or; tracking licensing enmmitments and c
coordinating internal action on NRC bulletins, generic letters, etc.
Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability.
Operating experience reviews including NRC Information Notices.
Performing the engineering, construction, inspection and testing associated with generating plant modification projects as assigned.
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Pag 3 6 Rev 18 l-Date: Junee,1997 Conducting the inservice inspection program in accordance with teeAnir;al specifications and State of Michigan rules.
Developing, maintaining and implementing security, fire protection and emergency plans.
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- Performing reviews to advise the Plant General Manager on matters related to nuclear 4
safety, as specified in Appendix B' Plant Moview Committee.
4 l-1.2.3 Rannonsibilities of the Nuetaar Performance A..... mar't Daoartment i-The Manager, Nuclear Performance Assessment Department, (see Figure 1) is responsible
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l to the Senior Vice President, NFHO, for:
j 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 surveys and evaluation including review /spproval of supplier QA programs, and maintenance of the Nuclear Approved Suppliers Ust.
5 h
' Preparation, review, approval and implementation of departmental procedures governing l
nuclear assessment activities...
2 Assessment of nuclear safety performance as described in the Technical. Specifications.
Assuring that assessments are done by personnel not directly responsible for the work being performed.
Recommending to the Site Vice President, the Plertt.Genere! Manager, of the Senior Vice President NFHO that a plant be shut down~if such action appears necessery.
Assessment programs (plant sites and Corporate Office), including follow up on corrective action for audit findings.
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l Review of'perforSnance trends ' associated hith' nuclear plant activities including corrective SClions.
Analysis of new and or changed regdiatory direc' tion,' cod'es and standards to determine their effect on the Quality Program.
Maintenance of the Quality Program Description for Operational Nuclear Power Plants.
Reporting audit findings relative to follow-up on corrective actions and the effectiveness l
- of the Quality Program to Consumers Energy Management.
Maintenance / operation, processing and status reporting of the corrective action system (Palisades only).
l Facilitation of Self-Assessment and Quality Verification Programs (Palisades only).
. CPC 2A.R18
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R:v18 Dato: June 6,1997 in order to implement these responsibilities, the Manager, 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 of the safe operation of Consumsrs Energy nuclear plants. A Stop Work order that would result in plant shutdown is given l
as a recommendation NRC licensed operating staff are responsible for determining and carrying out the safest course of actions.
I-The Manager, Nuclear Performance Assessment has no other primary riuties or respon-
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sibilities 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 Mt agement to obtain resolution of quality problems.
1.2.4 Ramnannihilities of the Enuinment Servican Danartment l
. The Manager, Equipment Services provides electrical, rotating and stationary equipment
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expertise, including developing and qualifying procedures for welding and heat treating. -
1.2.5 Paaaannihilitv for Attainina anality Oblactiven Outalda Noelame. Famall and Hvdra Onatatlana
-l Certain functio'ns th'at constitute part of the Nuclear Quality Program are performed by
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Consumers Energy organizational units outside the Nuclear, Fossil and Hydro Operations Department. 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 Vice a.
President, Electric Transmission and Distribution to the Executive Vice President and Chief Operating Offic,er Electric for. determining settings for electrical protective systems and relay control schemes, and for design, review and recommending changes to electrical protective schemes and associated settings.
b.
The Executive Manager, Fuels & Power Transactions is responsible to the Executive Vice President and Chief. Operating Qfficer - Electric for maintaining the Records Management System including required retention, protection and retrievability._ This inciuoes collect-ing, 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.1The accuracy, quality, and correctness of Big Rock documents in the Records Management System are the responsibility of Big Rock Point.
c.
The Manager, Production Services (see Figure 1) is responsible through the Vice President Electric Transmission and Distribution to the Executive Vice President and Chief Operating Officer - Electric for operating the Skill Centers including the training, and qualifying of personnel and equipment for welding operations, d.
The Corporate Records Administrator (see Figure 1) is responsible through the Vice l-President and Secretary for microfilming of specified quality records and plant engineering / design documents.
CPC 2A.R18 l
Page8 Rav18 Date: June 6,1997 l
e.
The Manager, Environmental and Technical Services (E&TS) is responsible, through the Vice President, Information Technology and Operations Services to the President and Chief Executive Officer for:
Maintaining the Company's Echelon h talibration facility for calibrating reference and secondary standards and general usage kortable and laboratory measuring and test equipment.
Controlling the calibration recall system for Portable and Laboratory M&TE owned by E&TS, and other departments, as requested.
Maintaining a Master PL M&TE List for E&TS PL-M&TE and fo' other departments, as requested.
l Providing a PL M&TE inventory List for Nuclear plants.
l Providing chemistry support to Nuclear plants, as requested.
Preparing, reviewing, approving a': obtaining additional reviews and approvals if required, of purchase requests for services, equipment and consumables, and submitting such requests to purchasing for procurement action.
Conducting performance tests on materials, equipment and systems when requested.
Performing nondestructive examination, and controlling / maintaining NDE equipment.
Providing qualified NDE procedures and equipment and NDE personnel.
Providing chemicsl and metallurgical analytical services.
Providing necessary corrective action processing and status reporting for assigned corrective action documents.
l f.
The Manager, Electric-Services is responsible, through the Vice President, Electric Transmission and Distribution to the Executive Vice President and Chief Operating Officer
- Electric for testing and maintaining electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associated settings.
CPC-2A.R18 a
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Energy and Chairman -
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Vice Chaerman - CMS President & CEO -
y g yg, Consumem W Chastman Consumers Enerav I
I Esecutive Vice Vice President Proendent & COO Informesson Technology Electric
& Operations Sennces Vice Prosident &
Secretary i
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Vice Proendent Bectdc Senior Vice Proendent E.secunwe Manecer Manager Tr_. -
Nucaser, Feest, & Hydre Fuels & Power Environmental &
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Tectwdcal Services C
thstresumen Manager Corporate Records
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M Poseedes Senaces Admedstrator Meneger
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Figure 1 - Company Organizational Chart for Operational Nuclear Power Plants N____
Page 10 RCv18 Date: June 6,1997 2.0 -
QUALITY PROGRAM l 2.1 REQUIREMENTS l
Policies that define and establish the Consumers Energy 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 compone%s 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.
Quakty Program status, scope, adequacy and compliance with 10 CFR 50, Appendix B are
-l regularly reviewed by Consumers Energy 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 QPD:-
Parnaraoh Excentions/Interoratationa l
2.2.3 21 a, 21.b 2.2.5 19a l
2.2.6 1,19,21a,21b 2.2.9 21, 4a, Sa, 5bi 6a, 7b; 10s,11a,12a,12b,12c,12d,13a,17e 2.2.10 2e, 2f 2.'2 IMPLEMENTATION l 2.2.1 The President of Consumers EnergyTas 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 provisionk of' applicable legislation and regulations pertaining to quality assurance for nuclear power' plants as defined by 10 CFR 50; Appendix B. The statement makes this Quality Program Descriptio~rt 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.
l 2.2.2 The Quality Program at Consumers Energy consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION).
2.2.3 The affectivity and applicability of this Quality Program Description are as follows:
For Big Rock Point and Palisades, the Quality Program Description became effective on a.
April 1,1982, with full implementation on January 1,1983.
CPC.2A.R18
- Pag') 11 R3v 18 Date: June 6,1997 b.
The Quality Program described in this Quality Program Description is intended to apply for the life of Consumers Energy's nuclear power plants.
-l The Quality Program applies to activities affecting the quality of safety related structures, c.
systems, components and related consumables during plant operation, maintenance, L
testing and all modifications. Those activities having a direct impact on safety related items shall b. :ontrolled. Safety.related structures, systems, components and related i'
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. 20e and No. 20b in Part 2 of Appendix A to this Quality Program Description.
l l
2.2.4 This Quality Program Descr.iption, organized to present the Consumers Energy Quality Program l
for Operational Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states Consumers Energy requirements for each of the criteria and describes how the controls l
pertinent to each are carried out. Any changes made to this Quality Program Description that 7
do not reduce the commitments previously accepted by the NRC must be submitted to the l
NRC at least annually as specified by 10 CFR 50.71.e. Any changes made to this Quality l
Program Description that do reduce the commitments previously accepted by the NRC must -
be submitted to the NRC and receive NRC approvat priot.to implementation in accordance with the requirements of 10 CFR 50.54..
- ~ __. A a.:
~ 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 -
C%cuments used for implementing the provisions of the Quality Program Description include a following:
- -a.
Administrative procedures.specify-ths. standard.ma*ada af. accomplishing operational phase activities. Because the Quality ?rogram is an integral part of the operational phase activities, the methods for implementing-Quality Program controls are integrated into
. these documents.
b.
-When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50,
~
~ Appendix 8 and the contract, andire approved by Consumers Energy prior to the start of l
_ _ __ orke w
- c.
Applicable elements of the operations Quality Prcgram are applied to emergency plans, security plans, radiation and fire protection plans for Consumers Energy nuclear power
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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 apoly to activities
_affecting the quality of safety-related structures, systems, components and related consumables.
Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits. ' Appendix A also describes necessary excep-l tions and clarifications to the requirements of those documents. The scope of the program and the extent to which its controls are applied are established as follows:
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Page 12 R;v 18 Date: June 6,1997 l
Consumers Energy uses the criteria specified in Regulatory Guides 1.26 and 1.29 in a.
engineering 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.
The extent to which controls specified in the Quality Program are applied to items is c.
determined for each item considering its relative importance to safety. Such determina-tions 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. '
Systems or structures on which work is to be performed are in the proper condition for e.
the task, f.
Authorized current instructions / procedures for the work are available for use.
g, hems and facilities that could t4 damaged by the work'have been protected, as required.
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h.
Provisions have been made for special controls, processes, tests and verification methods.
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2.2.8 Development, control and use of computer progr'ams affecting nuclear power plant design and l
operation at Consumers Energy are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).
2.2.9 Responsibility and authority for planning and implementing indoctrination end training are l
specifically designated in the Consumers Energy organization (see Section 1.0, ORGANIZATION),
a.
The training and indoctrination program provides for ongoing training and periodic ref amiliarization with the Quality Program for Operational Nuclear Power Plants.
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'3.0" DESIGN CONTROL
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- REQUIREMENTS -
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Modifications to safety related structures, systems and components are accomplished in
- accordance with approved designs' Activities to develop such designs are controlled. -
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- Depending on the type of modificatioti, these activities include design and field engineering; i
the performance of phyr'C seismic, stress,' thermal, hydraulic, radiation and Safety Analysis Repcrt (SAR) accident an.iyses; the development and control of associated computer :
programs; studies of material compatibility; accessibility for inservice inspection and -
I maintenance; and determination of quality standards. The controls apply to preparation and review of design documents, including the correct translation of applicable regulatory
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requirements and design bases into design, procurement and procedural documents.
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The following exceptions / interpretations in Appendix A, Part 2, are f.elevant to implementulon l-of the requirements of this section of the OPD:
l i.
Paragranh Excentions/Internratations
[
3.1 9a,13b 3.2.9 15a I
3.2.10-13d i
3.2 IMPLEMENTATION -
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_ l
- Authority and responsibility for modification activities is under the cognizance of the Nuclear 3.2.1 l
Plants as described in Section 1.0, ORGANIZATION This authority and responsibility includes F
the preparation, review, approval and venfication 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.
1 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 requirements of applicable codes and stedards or on known, successful use under similar conditions. This includes standaru sommercial materials, parts -
. and processes. ' Alternatively, materials, parts and processes may be qualified for use through qualification testing (see item 3.2.8). The adequacy of the selected materials, parts and processes is assured through the required design verifications of approvals.-
3.2.4 l Exceptthns and waivers to or deviations from the engineering (quality) s' tandards (i.e., the
- required dimensions, material properties, features and other characteristics specified for modifications) are required by procedure and by contract, when applicable, to be documented and controlled. (See, also, Section 15 concerning the approval of " repair" or _*use as is' dispositions of nonconformances.).
'3.2.5 When modifications involve design interf aces between internal or extemal 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 CPC-2A.R18
Page 15 Rev 18 Date: June 6,1997 ensure that structures, systems and components are compatible geometrically, functionally and with processes and environment. Lines of communication are cstablished 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 interf aces are made by the Consumers Energy organization having res;sonsibility for engineering direction l
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 Plant Engineering personnel to l
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 quditative acceptance criteria and the requirements for docementing inspection and test results.
3.2.8 The extent of and methods for design verification are documented. The extent of d ssign verification performed is a function of the importance of the item to safety, design r.omplexity, 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 tiiat 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 ratesting 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.
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.
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 CPC 2A.R18 r
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Page 16 Gev 18 Date: June 6,1997 directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that:
(1) He is the only technically qualified individual available, and (2) He has not specified a singular design approach, ruled out certain design considerations 4
or established the design inputs for the particular design aspect being verified, and (3) His review is either:
a.
Approved in advance by the supervisor's management, with documentation of the approval included ;n the design package, or b.
Controlled by a procedure which provides specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentati>n that the supervisor performed the design verification.
Independent audits by Nuclear Performance Assessment cover the frequency, effectiveness, 4
and technical adequacy of the use of supervisors as derign verifiers to guard against abuse.
3.2.10 When designs must be released for use before they he', t i een fully completed or before they have been verified, the incomplete c; unverified parts of the design and the hold point to which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety related function. Justification for such early release is' documented.
3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their use is specified.
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 epproved changes is transmitted tn all affected organizations.
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CPC 2A.R18 4-r
Paga 17 Rev 18 Date: June 6,1997 4.0-PROCUREMENT DOCUMENT CONTROL 4.1 REQUIREMENTS l
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, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraoraoh Exceotions/Interoretations 4.2.1 17c,17d 4.2.3 21,17a,17b 4.2.5 17d 4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement planning and for preparation, review and approval of procurement documents are delineated in Section 1.0, ORGANIZATION.
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.
4.2.2 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 af. plication to suppliers. As applicable, procurement documents include:
a.
Scope of work to be performed.
b.
Technical requiremerits, 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 do umented Quality heqram, subject to Consumers Energy review l
and written concurrence prior to the start of work.
CPC 2A.R18.
Page 18 Rev 18 Date: June 6,1997 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.
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 l
identification of documents requiring Consumers Energy approval.
4.2.4 Trained, qualified personnel perform and document reviews of procurement request packages to assure that:
Quality requirements (see 4.2.3 of th's Section) are correctly stated, inspectable, and a.
controllable, b.
Adequate acceptance and rejection criteria are included.
The procurement documents have been prepared, reviewed, and approved per the c.
Quality Program requirements.
4.2.5 Changes to the technical or quality requirements in procurement documents are controlled in a i
manner commensurate with that used for the original requirements. 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 original procurement request packages.
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Page 19 Rev 18 Date: June 6,19g7-5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 REQUIREMENTS
.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 satisfactorily completed.
The following exceptions / interpretations in Appendix A - Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraaraoh Excentions/Internratations 5.1 9a,13b 5.2.8 2 r, 2 s, 8 e - _, __. _.
5.2.14 6b
' 5.2 IMPt.EMENTATION 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 instructions,' procedures and drawings necessary to accomplish the activity are prepared and Implemented, instructions, procedures and drawings incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and/or qualitative (such as workmanship standards) acceptance criteria sufficient to determine that the activity has been satisfactorily accomplished.
Temporary procedures may be issued to provide management instructions which have short-term applicability. Temporary procedures include a designation of the time period during wNch they may be used.
- The procedures used by Consumers Energy to controlits activ les include the following:
-l 1.
Administrative Procedurser. "_
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2.
System procedures that describe the operation of the plant;.
3.
Start up procedures that provide for starting the reactor from hot or cold condition and recovering from reactor trips.
. _ =
4,
_ Shutdown procedures that provide for controlled reactor shutdown or shutdown following reactor trips.
5.
Power operation and load changing procedures that provide for steady state power -
operation and load changing, including response to unanticipated load changes.
CPC-2A.R18
Pago 20 Rev 18 Date: June 6,1997 6.
Process monitoring procedures that pcovide for monitoring plant system performance and 4
which, as appropriate, identify limits fcr significant process parameters.
I 7.
Fuel handling procedures that provide for activities such as:
a.
Refueling c.
Fuel accountability l_
d.
Receipt and shipment of fuel e.
Nuclear safety measures j
8.
Maintenance procedures that provide for:
l a.
Preparation for maintenance b.
Performance of maintenance c.
Post mairJenance and operat ility checks and tests d.
Use of supt orting maintenance documents <
9.
Radiation contrel procedures that provide for:
a.
implementst!on of the radiation control program including the acquisition of radiation data b.
Identification of equipment for performing radiation surveys c.
Measurement, evaluation and assessment of radiation hazards
- 10. Calibration and test procedures that provide for: -
a.
Periodic calibration and tes ing of safety.related instrumentation and control systems b.
Calibration of portable measuring and test equipment used in activities affecting safety
- 11. Chemical-radiochemical control procedures that provide for activities including:
a.
Sampling and analyses b.
Maintenance of coolant quality c.
Control of deleterious agents CPC 2A.R18
Page *1 R;v e.
Date: June 6,1997 d.
Control, treatment and management of radioactive wastes The control of radioactive calibration sources o.
- 12. Emergency procedures that provide guidance for:
Operations during potential emergencies so that a trained operator will know in a.
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
- 13. Emergency Plan implementing' Procedures l
- 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 Consumers Energy and its suppliers l
d.
Control of onsite quality related modification activities that assure the Quality l
Program is implemented and its effectiveness is assessed and reported CPC-2A.R18
Page 22 RIv18 Date: June 6,1997 6.0 DOCUMENT CONTROL l 6.1 REQUIREMENTS Documents controlling safety-related activities within the scope defined in Section 2.0, OUALITY PROGRAM are issued and changed according to established procedures.
Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for 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 samt, organizations that performed the original review and approval or by other qualified, responsible organizations specifically designated in accordance wl;:, the procedures governing these documents.
Personnel authorized to approve procedures specified by plant Technical Specifications are limited to:
1.
For Palisades, an appropriate senior department manager, based on the activities addressed in the specific procedure, predesignated in writing by the Site Vice President; or l
2.
For Big Rock Point, the Plant General Manager.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Parnaraoh 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.
Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test and plant maintenance and operation which implement the Quality Program.
CPC-2A.R18
Page 23 RCv 18 Date: June 6,1997 Final Safety Analysie 1eport/ Final Hazards Safety Report e.
d f.
Reports of noncot ances g.
Plant Technical Specifications J
6.2.3 The review, approval, issue and change of the above documents are controlled by:
Establishment of criteria to ensure that adequate technical and quality requirements are a.
Incorporated.
b.
Identification of the organizations responsible for review, approval, issue and revision.
Review of changes to documents by the organizations designated in accordance with the c.
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procedure governing the review and approval' f specific types of documents, including o
quality aspects.
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 responsible for maintaining current copies of the lists.
6.2.6 Accurate as built drawings (record drawings) and related documentation are prepared in a timely manner.
e 4
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Page 24 Rev 18 Date: June 6,1997 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES l 7.1 REQUIREMENTS Activities that implement approved procurement requests for safety related material, equipment and services are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant site prior to reliance on equipment, material or services for nuclear safety.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Parnaraoh Excentions/Interoretations 7.1 21 l
7.2.2 16d 7.2.3 7b,17e 7.2.5 2m, 7e,17f 7.2.6 2m, 9b,13c,13d,17f 7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in Section 1.0, ORGANIZATION.
l-7.2.2 Consumers Energy qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. To remain l
qualified, suppliers involved in active procurements are evaluated continuously and are audited triennially, if an audit is acquired from an external source, the audit is evaluated prior to its use.
Supplier e, slucion and triennial audits are not necessary when the items or services supplied are all of ti e follwing:
a.
Relativeif simple 6nd standard in design, manufacture and test, and b.
Adaptable to $tandard or automated inspections or tests of the end product to verifV quality characts % tics after delivery, and c.
Such that receiving inspce: tion does not require operations that could adversely affect the integrity, function or cleanass of the item.
In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service.
7.2.3 Supplier activities that affect quality are verified in accordance with written procedures.
These procedures provide the method of verifying (such as audit, surveillance or inspection)
CPC 2A.R18
Page35 Rev 18 Date: June 6.1997 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.
a.
- Specifications and codes referenced in procurement documents for spare or replacement items are at least equivalent to those for the originalitems of 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 engineering evaluation performed by qualified individuals.
The evaluation assures there is no adverse effect on intoffsces, hterchangeability, 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 documentation 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 requirements.
The acceptability of these documents is evaluated during source and/or receipt inspection.
7.2.7 Supplier's certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure that they are valid. The re' 'ts of these evaluations are documented.
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Page 26
- Rov 18 Date: June 6,1997 8.0 IDENTIFICATION AND CONTROL OF ITEMS l 8.1
._ REQUIREMENTS
. Safety related materials, parts and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paragraoh Excentions/Internratatione 8.2.2 7d,7g 8.2.3 -
7a 8.2 IMPLEMENTATION 8.2.1 Controls are established that provide for the identification and control of materials (including consum ales), parts and components, (including partially f abricated assemblies). -
Responsibility for the identification and control of items is described in Section 1.0, ORGANIZATION.
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8.2.2 Items are identified by physically marking the item, its storage area or its container or by
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maintaining records traceable to the item. The method of identification is such that the quality of the item is not degrad-!-
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 f abrication, assembly, or installation.
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4 CPC 2A.R18
_Page 37 Rev 18 Date: June 6,1997 -
1 i-9.0
~ CONTROL OF SPECIAL PROCESSES '
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9.1 REQUIREMENTS -
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. Special processes affecting safety related structures, systems, and components are controlled 4
- and are accomplished by qualified personnel using qualified procedures and equipment in i
accordance with applicable codes, standards, specifications, criteria, and other special require-t m onts.
[
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation j
of the requirements of this section of the OPD:
i Paraaraoh Excentions/Internratations i
9.2.1 6c,13e 1
9.2 IMPt.EMENTATION -
d
,u l
i
-9.2.1 Processes subject to special process controls at Consumers Energy are those for which full verification or characterization by direct inspection is impossible or impractical. Such processes include welding, hea't t'reating, chemical cleaning, application'of protective' coatings,-
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co.s fete placement, and nondestrua.tive examination.
[
9.2.2 Organizational responsibility for implementation of special proceseos and for qualification of procedures, personnel, and equipment used to perform special processes is indicated in j-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
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- 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 intervais -
requires recertification.
9.2.5.
For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and specifications.
9.2.6
. Qualification records are maintained in accordance with Quality Program Description Section 17.
9.2.7 The Nuclear Performance Assessment Department audits / assesses special process activities, l
Including qualification activities to assure they are satisfactorily performed.
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Page 28 Rev 18 Date: June 6,1997 10.0 INSPECTION l 10.1 REQUIREMENTS Activities affecting the quality of safety.related structures, systems, and components are inspected to verify their conformance with requirements, inspections are accomplished by independent virif cation or process monitoring as necessary Verification points are used as necessary to ent,ure 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:
Paragraoh Exceotions/Interoretations 10.2.2 2p,2q 10.2.3 2j, 6a 10.2.7 2j,6a 10.2.10 2j 10.2 IMPLEMENTATION 1 G.2.1 Organizational responsibilities are as described in Section,1,0, ORGANI,ZATION.
10.2.2 Inspections are applied to procurement, maintenar ce, 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.
Specify measunng an'd'te'st equipmerit of the necessary accuracy for performing e.
inspection.
f.
Provida 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.
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Page 29 RW 18 Date: June 6,1997 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 Site Vice President / Plant General Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility.
Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are dacumented 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 personnel responsible for performing the inspection.
f.
- Acceptance and rejection criteria.
g.
Hecording of the inspection results and the identification of the inspLtor.
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.
Inuependent verifications are performed, and work is released for further processing or use, by assigned verification personnel. Independent verification points may be waived only b/ the or.
g3nization that performs the insnaction 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.
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.
CPC-2A.R18
Page 30 Rev 18 Date: June 6,1997 10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:
Qualifications of the independent verifier are equal to or better than the minimum a.
qualifications for persons who can be authorized to perform the task: and b.
The work is within the skills of Consumers Energy personnel and/or is addressed by Consumers Energy procedures, If work involves breaching a pressure retalning 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.
l The verificatidn is performed by iniiiviciuais oiher'than the person (s) perfe..e.g or directly
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supervising the work.
l 10.2.8 For independentverification, when acceptance criteria are not met, corrected areas are to be l
reverified. Results of independent verification are documented and retained for the purposes of performance trending and analysis.
10.2.9 The independent verifier has the authority to stop work if inspection criteria are not met.
l Resolution of disagreements between the verifier and worker is resolved by piant management.
10.2.10 Contractors may be used as independent verifiers in accordance with Section 10,2.7 provided:
l.
a.
The work is performed using the Consumers Energy 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.
1. -.
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Page 31 R;v 18 Date: June 6,1997 11.0 TEST CONTROL 11.1
' REQUIREMENTS l
Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems, and components will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification (as applicable), acceptance, pre operational, start up, surveillance, and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions are specified and met. Test results are documented and evaluated.
The following exceptions / interpretations in Appendix A Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Excentions/Internretations l
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 ;n 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.
Pre-operational tests to assure proper and safe operation of systems and equipment prior c.
to start-up tests or operations.
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d.
Start up tests, including p'rectitical, criticaiity, 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 cperation 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.R18 l
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d Page 32 Mov 18 i
Date: June 6, Igg 7 b.
Test prerequisites such as calibrated instrumentation, adequate test equipment, and l
instrumentation including accuracy requirements, completeness 48 he item to be tested, t
suitable and controlled environmental conditions, and provisions for data collection and storage.
l c.
Instructions for performing the test.
d.
Mandatory inspection hold pointe for witness by the appropriate authority.
e.
Acceptance and rejection criteria.
Methods of documenting or recording test dets and results.
g.
Assuring that test prerequisites have been met.
h.
Verification of completion of modification activities.
Test procedures and instructions are reviewed for technical content and quality aspects, by 4
the giant engineering orgenlaation, or the offsite technical orgenlaation, as applicable When acceptance criteria are not met, corrected areas are to be rotested.
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Page 33 RIV18 Date: June C,1997 12.0 CONTROL OF MEASUFilNG AND TEST EQUIPMENT 12.1 REQUIREMENTS l
Measuring and testing equipment used in activities affecting the quality of safety related systems, components and structures are properly identified, controlled, calibrated, and adjusted at specified intervals to maintain accuracy withm necessery limits.
The following exceptions /interpretatinns in Appendix A, Part ?, vre relevant to implementation of the requirements of this section of the QPD:
Paraorneh Excentions/Interoratations 12.2.3 2o, 9c 12.2.4 20, 9c 12.2.5 10c 12.2.8 10b 12.2 IMPLEMF.NTATION 12.2.1 The authority and wponsibility of personnel establishing, implementing and assuring effectivener ut enlibration programs is described in Section 1.0, ORGANIZATION.
12.2.2 Procedures are established for measuring and 16st coulpment utilized in the measurement, inspection and mon 4oring 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 uniously identified and is traceable to its cellbration source.
12.2.4 Consumers Energy u)es a system of labels to be attached to measuring and test equipment t l
display the next calibration due date. Where !abels cannot be attached, a control system is used that identifies to potential use.s any equipment beyond the calibration due date.
12.2.5 Measuring and test coulpment (M&TE) and installed plant instrumentatiorils calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measuremvm, Calibration of M&TE la against standalds that have r" accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and the basis of acceptance is documented and authorized by responsible management.
Calibration standards used for installed plant instrumentation shall norrnally have greater accuracy tnan the instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.
12.2.6 Calibrating standards have greater accuramr than standards being calibrated. Calibrating standards with the same accuracy may be used if it can be shown to be adequate for the CPC 2A.R18
Page 34 R:V 18 Date: June 6,1997 i
requirements and the basis of acceptance is documented and authorized by responsible management.
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 cahbration.
1?.2.8 When measuring and 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 evolustions are documented. Metests or reinspections are performed on aaspect items.
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Page 35 R:V 18 Date: June 6,1997 13.0 HANOJfG, STOA AGE AND SHIPPING 13.1 REQUNMENTS l
Activities with the potential for causing contamination or deterioration that could advarsely affect the ability of a safety related item to perform its intended safety functions, and activities necessary to ptavent undetected or uncorrectable damage are identified and con.
trolled. These activities include cleaning, packaging, preserving, handling, shipping, and storing, Controls are effected through the use of appropriate procedures and instructions implemented by suitably trained personriel.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of thl section of the OPD:
Parantanh Excentionalinternratations 13.2.2 7a, 7c, 7d, 7f, 70, 7h 13.2 IMPLEMENTATION
~
13.2.1 The authority and responsibility of personnelirnplementing and essuring the effectiveness of material cleaning, handling storing, pack aging, preserving, and shipping activales is described in Section 1.0, ORGANIZATION..
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13.2.2 Procedures are used to control the cleaning, handling, storing, pack aging, preserving, and shipping of materials, components and systerns in accordance with design and procurement requirements. These procedures inciude, but are not limited to, the fol lowing functions:
a.
Cleaning, to assure that required cleanliness levels are achieved and maintained.
b.
Packaging and preservation, to provide edequate protection against damage or l
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.
I CPC 2A.R18
Page 36 Rev 18 Date: June 6,1997 14.0 INSPECTION, TEST AND OPERATING STATUS l 14.1 REQUIREMENTS 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 individualitems is clearly indicated by markings and/or logging under strict procedural controls to prevent inadsortent 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 OPD:
Enfanfanh Fremotions/Internratations 14.1 2r 14.2.5 21 14.2 IMPLEMENTATION 14.2.1 Organizational responsibilities ate 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 togs, markings, labels, etc, are controlled by procedures.
14.2.4 The sequence of Inspections, tests and other opor ations 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,R18
Pago 37 Rev 18 Date: June 6,1997 15.0 NONCONForWP MATERIALS, PARTS OR COMPONENTS 15.1 REQUIREMENTS l
Safety related materials, parts, or components that do not conform to requirements are controIIed in order to prevent their inadvertent use Nonconforming items are identified, documented, segregated when p ?ctical, and dispositioned. Affected organizations are notified of nonconformancos The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paracraoh Excentient/Interotetations 15.1 2i 15.2 IMPLEMENTATION 15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which render the quellty unacceptable or indeterminate, are identified as nonconforming and any further use is controlled. Nonconformances are documented and dispositioned, and notification is made to affected organizations. Personnel authorized to disposition, conditionally release, and close out nonconformances are designated. The authority and responsibility for the irnplementation of activities related to the processing and control of nonconforming materials, parts, or components are described in Section 1.0, ORGANIZATION.
a.
Nonconforming items are identified by marking, tagging, or segregating or by documented administrative controls. Documentation describes the nonconformance, the disposition of 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 originalinspect on and test requirements or alternatives that have been documented as acceptable and concurred with by the originalinspection planning authority, d.
Items that have the disposition of " repair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as built condition.
15.2.2 Dispositions of conditionally released items are closed out before the items are relied upon to perform safety related functions.
15,2.3 Prior to the initiation of preoperational testing on an item, all nonconformances are corrected or dispositioned and evaluated for impact upon the item or the testing program.
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J Page 38 Rev 18 Date: June 6,1997 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.
1 CPC 2A.R18
i page 39 Rev 18 Date: June 6.1997 16.0 CORRECTIVE ACTION 16.1 REQUIREMENTS l
Conditions adverse to quality of safety related structures, systems, components, or activhles, such as failures, malfunctions, deficiencies, deviations, defective meterial, and equipment and nonconformances are identified promptly and corrected as soon as practical.
For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preck.de repetition, in these cases, the condition, cause and corrective action taken is documented and reported to appropriate levels of management for review and assessment.
16.2 IMPt.EMENTATION 16.2.1 The responsibility and authority for the control of corrective action are described in Section 1.0, ORGANIZATION.
16.2.2 Controls are established to assure that conditions adverse to quality are identified and documented and that appropriate remedial action is taken.
~ -
16.2.3 For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded. Corrective action includes determining the cause and extent of the condition, and taking appropriate action to preclude similar problems in the future. The controls also assure that corrective action is implemented in a timely manner.
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Page 40 Rev 18 i
Date: June 6,1997
)
17.0 QUALITY RECORDS l 17.1 REQUIREMENTS Records that fumish evidence of activities affecting the quality of safety related structures, hystems and components are maintained. They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paranraoh Excentionslinternratations 17,1 14b 17.2.5 14c-17.2.8 14a,14c 17.2 IMPLEMENTATION 17.2.1 Responelbilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION.
17.2.2 Documents thit furnish evidence'of activities affecting ' quality'are generated and controlled in accordance with the procedures that govern those activities. Upon completion, these documents are considered records. These records include; a.
Results of reviews, inspections, surveillances, tests, audits, and material analyses b.
Qualification of personnel, procedures, and equipment c.
Operating logs d.
Maintenance and modification procedures and related inspection results o.
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 procedutos, and reports 17.2.3 Inspection and test records contain the following where applicable:
a.
A description of the type of observation b,
The date and results of the inspection or test CPC 2A.R18
Pag 3 41 Rev 18 Date: June 6,1997
(
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 cahets.
17.2.6 Only authorized personnel may issue corrections or supplements to records.
17.2.7 Traceability betivein the record and the item or activity to whlch it applies is provided.
~
17.2.8 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.
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Page 42 Rev 18 Datet June 6,1997 18.0 AUDITS l 18.1 REQUIREMENTS A comprehensive system of audits is carried out to provide independent assessment of performance and offectiveness of the Quality Program to achieve nuclear safety, including those elements of the program implemented by suppliers and contractors. Audits are per-formed in_ accordance with written procedures or checklists by 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.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Parantanh Excentlann/interntatatlana 18,2.2 3a,3b,16a,'16b s
18.2.3 16c 18.2.g 2e 18.2-IMPLEMENTATION a
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 Appndix D, Audit Frequencies.
18.2.3 Audits f 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 audits are supplemented by special audits when significant changes are made in the Quality Program, when it is suspected that quality is in jeopardy or when an independent assessment of program offeetiveness 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.R18 -
a Page 43 Qev 18 i
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- Date: June 6,1997 18.2.8' Personnel selected for auditir.g assignments have experience or are given training i
commensurate with the needs of the audit and have no direct responsibilities in the areas j
- audited, i
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 i
Program in the area audited. The reports are distnbuted to the responsible management of j
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. Sude fol.
i low up includes re audits when necessary. For Vendor Audits, such follow up shall be 1
performed by the organization performing the audit.
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4 CPC 2A.R18
Page 44 Rev 18 Date: June 6,1997 QPD MANUAL APPENDIX A. PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS l The Consumers Energy 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 8 to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
2, 10 CFR, Part 50.55a. Codes and Standards.
3.
Regulatory Guide 1.8. (9/80 Draft). Personnel Qualification and Training Endorses ANSI /ANS 3.1 -(12/79 Oraft) (application limited as described in exceptions 4a and 5a of Appendix A, Part 2).
4.
Regulatory Guide 1.26. (2/76, Rev 3) Quality Group Classification, and Standards for Water.,
Steam, and Radioactive Weste-Containing Components of Nuclear Power Plants.
5.
Regulatory Guide 1.29 (9/78, Rev. 3). Seismic Design Classificatiott 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.
8Property "ANSI code" (as page type) with input value "ANSI N18.7 1976.</br></br>8" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.37. (3/16/73). Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants. Endorses ANSI N45.2.1 1973.
9.
Regulatory Guide 1.38. (5/77, Rev 2) Quality Assurance Requirements for Packaging, Shipping, l
Receiving, Storage, and Handling of' Items for water Cooled Nuclear Power Plants Endorses ANSI N45.2.2 1972.
- 10. Regulatory Guide 1.39 - (9/77, Rev 2) Housekeeping Requirements for water Cooled Nucleal 4
Power Plants. Endorses ANSI N45.2.3 1973,
- 11. Regulatory Guide 1,58.(9/80. Rev ll. 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, i
- 13. Regulatory Gelde 1.74 - (2/74). Quality Assurance Requirements Terms and Definitions.
Endorses ANf.I N45.2.10 1973.
CPC 2A.R18 4
Page 45 Rev 18 Date: June 6,1997
- 14. Regulatory Guide 1.88 (10/76, Rev 2) Collection, 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 1975.
- 17. Regulatory Guide 1.123. (7/77, Rev 1). Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants.~ Endorses N45.2.13 1976.
- 18. Regulatory Guide 1.144.(9/80, Rev ll. Auditing of Quality Assurance Programs for Nuclear Power Plants. Endorses N45.2.12 1977.
- 19. Regulatory Gulds 1.146. (8/80). Qualification of Quality Assurance pro 9 tem Audit Personnel for Nuclear Power Plants. Endorses N45.2.23 1978.
- 20. Branch Technical Position AS89.5.1 (Rev 1) Guidelinee for Fire Protection for Nuclear Power Plants.
- 21. 10 CFR 50, Appendix M, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979, Sections ill G., lll J. and lli O.
22.
ANSI /ANS 3.1 1987, Selection, Qualification, and Training of Personnel fo. Juclear Power Plants (application limited as described in Appendix C of this document).
l A
CPC.2A.R18
Page 46 RV 18 Date: June 6.1997 QPD MANUAL APPENDIX A. PART 2 l
CONSUMERS ENERGY EXCEPTIONS TO OPERATING PHASE STANDE AND REGULATORY GUIDER 1.
Ganatal Raoultament Certain Regulatory Guides invoke or imply Regulatory Guides ind standards in addition to the standard each primarily endorses.
Certain ANSI Standards invoke or imply additional standards.
Excentlan/Internratation l
The Consumers Energy 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.
l Imposition of these Regulatory Guides on Consurws Energy seppliers and subtier suppliers will be on a case by case basis depending upon the item or service to be procured.
2.
N18.7 Ganatal Excentlan/interntetation l
Consumers Energy 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 Assessme.nLDepartment staff. Procedures will be established to specify how NPAD will acquire necessary expertise to carry out its review responsibliities in accordance with Appendix C, Independent Safety Review..
2a.
tillLZ, Sec 3.4.2 Ranuirement
'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.R18
Page 47 Rev 18 Date: June 6,1997 Escantion/Intercratation Since Consumers Energy has more than one nuclear unit and more than one organization providing l
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 Raoultament
" Personnel assigned responsibility for independent revlows shall be specified in both number and technical disciplines and shall collectively have the experien:o and competence required to review problems in the following areas:..."
Excention/internratation The Nuclear Performance Assessment Department will not have members specified by number or by technical disciplines and its members may not have the experience end competence required to review problems in all areas listed in this section; however, the Nuclear Performance Assessment Department will function as described in Appendix C, independent Safety Review, and will acquire the services of personnel having such experience and competence as necessary.
2c.
til.LZ, Sec'4.3.4 Raoutrament "The following subjects shall be reviewed by the independent review body:"
Excentionlinternratation Subjects requiring review will be as specified in Appendix C, independent Safety Review.
2d, ti1LZ, Sec 4.3.4(3)
Ranuirement Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewid by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.
Exceotion/interoratation 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,R18
Pagede R:V 18 Date: June 6,1997 2e, hu.LI, Sec 4.5 Staustament Written reports of audits specified in ANSI N18.7 shall be reviewed by the independent toview body and by appropriate members of Management including those having responsibility in the area audited.
Excantlan/internratation 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.
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.
huL1, Sec 4.5 Ranultamant Periodic review of the audit program shall.be performed by the independent review body or by a management representative at least samlannually to assure that audits are being accomplished in accordance_withloquitements of technical specificatione and of this standard.
t Encantinnlinteraratation.
Audits of operational nuclear safety related facility activities are performed under the cognisance of the Nuclear Performance Assessment Department as described in Appendix C, independent Safety Review.
2g. - hdLZ,'Sec 5.2.1 888Wilaat01 "The responsibilities and authorities of the plant operating personnel shall be delineated."
Encantlan/internratation On site personnel n'o't directly associated with operating activities, as defined in ANSI N18.7,
~~
Section 2.2, are not considered to be operating personnel.
CPC 2A.R18
Page 49 R:v18 Datet June e,1997 2h.
MILL Sec 5.2.2 Raouirement
- Temporary changes, which clearly do not chenje the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators license on the Unit affected."
Exeantion/Intaroratation Consumers Energy considers that this requirement applies only to procedures identified in Plant l
Technical Specifications and to Security and Emergency Plans implementing pro. edures.
1 Temporary changes to these procedures may be made provided a.
The intent of the original procedure is not altered; b.
The change is approved by two members for designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator License; and c.
The change is documented, subsequently reviewed by the PRC within 30 days of issuance and approved by:
1.
Appropriate' senior Palisades department manager predesignated by the Site Vice President; or 2.
The Big Rock Point Plant General Manager.
l Determination of the appropriate senior Palisades department manager is based on the activities addressed in the specific procedure, and will be predesignated in writing by the Palisades Plant Site Vice President.
l 21.
MILL Sec 5.2.6 Raouirement "In cases where required documentary evidence is not available,-the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or materialis in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems'to fulfill their intended safety functions."
Fucention/Internratation Consumers Energy initiates appropriate corrective action when it is discovered that documentary l
evidence does not exist for a test or inspection which is required to verify equipment acceptability. This action includes a technical evaluation of the equipment's operability status.
CPC 2A.R18
Page 50 Pev 18 Datet June 6,1997 2j.
N1]LL Sec 5.2.7 Raouirement 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, N45.2.41972 (IEEE 3361972) (6l; 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, N45.2.5197417); American Nat'onal Standard Qualifications of Inspection Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.61973 (51; American National Standard Supplementary Quality Assurance Requirements for Installation, inspection and Testing of Mechanical Equipment and Systems for Construction Phase of Nuclear Power Plants, N45.2.81975 [8); American National Standard Quality Assurance Requirements for the Design of Nuclear Power Plants, N45.2.11197419); and American National Standard Quality Assurance for Protective Coating Applied to Nuclear Facilities N101.41972 (10l, Considerable care is required in assessing which operational phase activities are comparable in nature and extent to activities normally associated with design and construction, f,xcention/ Clarification Work that is within the skills of Consumers Energy personnel and is covered by Consumers Energy procedures may be inspcted by independent verifiers qualified in accordance with Section 10.2.3 and 10.2.7 and 10.2.10, rather than ANSI N45.2.6.
2k.
N1]LZ, Sec 5.2.8 Raouirement "A surveillance testing and inspection program...shallinclude the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections."
Excentionllntaroretation -
Separate _ master _ schedules may exist for different programs such as ISI, Pump and Valve Testing, and Technical Specification Surveillance Testing.
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Page 51 Rev 18 Date: June 6,1997 l
21.
bl1L1, Sec 5.2.13.1 Ranuiramant "To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 1971.*
Imenatlan/interntatation To the extent necessary, procurement documents teaulte that'the supplier have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.
2m. bl1L1, Sec 5.2.13.2 Ranultament ANSI N58.7 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 insta'lation or use of such items, Excentlan/interntatation The required documentary evidence is available at the site prior to use, but not necessarily prior to installation. This allows installation to proceed while Gny missing documente are being obtained, but precludes dependence on the item for safety purposes.
2n.
tL1L1, Soc 5.2.15 Ranuira[nant 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.
Encantion/internratation Consumers Power has in place programmatic ~ procedure preparation, review and usage controls that ensure procedures are technically and administratively correct and make a biennial review program unnecessarily duplicative. These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusualincidents occur, when plant modifications are made, and when significant 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 Procedurer, Off Normal Procedures, Special Operating Procedures, Special Test Procedures, Fuel Handling Procedures, Emergency Plan Implementing Procedures, and others where use would be dictated by a particular event are reviewed at least every two years and revised as appropriate.
CPC 2A.R18
Page $2 i
Rev 18 Date: June 6,1997 in addition, procedures that have not been used or reviewed for two years are reviewed prior to use to determine il changes are necessary or desirable.
An assessment performed 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 OPD.
2o.
11111, Sec 5.2.16 Ranultament Records shall be mods ^*
m.,
e suilt,bly marked to indicate calibration status.
E ncantlan/internrar M Seeitem'Sc.
2p.
ti1LZ, So"c '
t?
Beault.aco.it For mr.aficanva wGvwfootke w,anence, inspections shall be conducted in a manner similar (fre
<rw. twe.99 rersunei p* arming such inspections) to that associated with construction phe sttml',e egent MetNn !.2.7) r LK *iM:!GuiMMki s t
Mi :Mnm <:a e:t sveitists activities which are within the skills of Consumers Energy m e, 3 ne.*
m :or.nci er is carried out using Consumers Energy procedures may be inspected by,;:s nunt vene qualified in accordance with Sections 10.2.3,10.2.7, and 10.2.10 of this prog.m. cos(A.'t.cn 2q.
ti1LZ,So. * * /
Raoulramant 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.
Encantion!!nternratation l
Consumers Energy uses the terminology " independent verification points" as equivalent to hold points.
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Page 53 Rev 18 Date: June 6,1997 2r.
bl.1LI, Sec 5.3.5(3)
Raoultament Instructions shall be included, or referenced (in maintenance procedures), for returning the equipment to its normal operating status.
EveLilan/intatoratattog At Consumers Energy, equipment is returned to its normal operating status,i.e., declared l
operable, by licensed Operations Department personnel, not Maintenance personnel. Operations personnel verify and document equipment operability through second levelline up verification or appropriate functional testing.
4 BL11J., Sec 5.3.5(4)
Ranultament 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 maintona s procedure, they shall receive the same level of review and approval as operating proceduroa.
Excantion/internratation m
Such documents are reviewed by appropriately qualified personnel prior to use to ensure that, when used as Instructions, they provide proper and adequate information to ensure the required quality of work. Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures.
3a.
MG L33.SecC4a Ranuiramani 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.
EveantIAn/intaroratation 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.
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I Page 54 Rev 18 Date: June 6,1997 3b.
MG 1.33. Sec C4b Raouirement The conformance of f acility operations to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
Excention/internratation Consistent with guidance presented in NRC letters date Mer:5 29,1983 (RLSpessard to l
JMTaylor) and January 30,1984 (JGPartlow to RI.5pessard), Consumers Energy interprets the commitment to audit Technical Specification /lle,ense conditions contained in 18.2.2 of this OPD, and in Appendix 0, Audit Frequencies, as foows:
j' Consumers Energy 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 Condittuns 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.
!!actrical 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 aud a period for any of the above elements may be reduced depending on Technical Specification com;liance history.
4a, ANS 3.1. General Encantion/intaroratation The commitment to ANS 3.1 f12/79, draft) is limited to the requirements thm nowy to tne training -
and qualifit.uon of persons performing independent quality assurance functiens, except for Lead Auditors. Lead auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI 45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.
CPC 2A.R18
~
PJge 55 Rev 18 Date: June 6.1997 Sa.
RG 1.8, C.3.1. General Excaotion/interDratation The commitment to Regulatory Guide 1.8 (9/80, draf t) 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 (8/80)/ ANSI N45.2.231978. Other personnel are trained and qualified as designated in plant Technical Specifications.
6b.
RG 1.8. C1.2.2 Ranuiramant "When an individualis hired to temporarily function as a plant employee, such as for contracted services, evidence of previous education, 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 trainir.g, including plant specific training.
As a minimum, each individual should receive General Employee Training."
fxcantion/internratation Consumers Energy understands that this recuirement applies both to Consumers Energy l
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.
Consumers Energy employees so assigned possess the required quellfications as a prerequisite to l
the assignment and the review is waived. The qualifications of contract personnvl are taviewed and arrangements made for any necessary r 'ning. Temporarily assigned personnel requiring s
unescorted access receive the site general (,ntation as embodied in General Employee Training.
Se, N4511. Sec 2.4 Ranuirement 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.
Evenotion/Intaroratation Consumers Energy certifies its inspectors in accordance with Paragraph 10.2.7 of CPC 2A unless l
the work is comparable in nature and extent to original construction (See item 2j).
CPC 2A.R18
Pago 56 MeV 18 i
Date: June 6.-1997 6b.
N45.2.1. Sec 3.1 l
f Ranultamant N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items i
be so classified.
Excantion/internratation insteed of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activities is addressed on a case by case basis.
Cleanness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material. As a minimum, cleanness inspections are performed prior to system clos' re. Such inspections are documented.
l Sc.
ti&LL1, Sec 5 -
f StendtBIDent
~
' Fitted and tack welded joints (which will not be immediately aceled by welding) shall be wrapped j
with polyethylene or other nonhelogensted plastic film until the welds can be completed."
Emmantlannatararatatlan l
Consumers Energy sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film le subject to damage and does not always provide adequate protection.
7s.
R4L210eneral Ranultamant N45.2.2 establishes requirements and criteria for classifying safetydeleted items into protection levels.
Excentlan/internratation Instead f 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.
CPC 2A.R18
Paga 57 Movit Date: June 6,1997 7b.
NAL2.2, Sec 2.4 Ranuirement
...Offsite inspection, examination of testing shall be audited and mon!;ored by personnel who are qualified in accordance with N45.2.6.*
Encantlan/internratation Offsite inspection, examination, or testing activities are audited or inspected by persons qualified and certified in accordance with ANSI N45.2.231970, 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.
7c.
NdL2,2, Sec 3.4.1 arb Appendix A,3.4.1(4) and (5)
SAGhikamant
- (4)...However, preservatives for inaccessible inside surfaces containing reactor coolant water shall be indicated to facilitate touch up.
(5) The name of the preservative used shall be the water flushable type."
Encantinnlintaroratation Based on comparison of these statements to ANSI /ASME NOA 21983, Consumers Energy
)
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.
1 (5) The name of the preservative used shall be provided to facilitate touch up."
g..-
7d.
N&L2.2, Sec 3.9 ind Appendix A 3.9 Ranuirement m.
- g. "The item and the outside of containers shall be marked."
. (Further criteria for marking and tagging are given in the appendix.)
Encantion/Internratation These requirements were on@.ially written for items packaged and shipped to construction projects. Full compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, increase the probability of damage to the item. The requirements are implemented to the extent necessary to assure traceability and integrity of the item.
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Page 58 Rev 18 Date: June 6,1997 l 7e.
N4!L2.2. Sec 5.2.2 Raoultament "The inspections shall be performed in an area equivalent to the level r' storage."
Exeantion/Intatorstation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item. However, such inspections are performed in a menner and in an environment.which do not endanger the required quality of the item.
7f.
N45.2.2. Sec 6.2.4 Ranultament
~
"The use or storage of food, drinks, and salt tablet dispensers in any storage area shall not be permitted."
Excantionlinternratation Packaged food for emergency or extended overtime use may be stored in meterial stock rooms.
The packaging astures that materials are not contaminated. Food will not be "used" in these areas.
79 N45.2.2. Sec 6.3.4 Ranuiramant "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."
Excention/Intaroratation See N45.2.2, Section 3.9 (Exception 7d.).
7h.
84.5n sec 6.4.1 Raoultament
" 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."
Ereantion/interoratation The requirement implies that allinspections and examinations of items in storage are to be performed on the same schedule. Instead,'.no inspections and examinations are performed and
-documented in accordance with material.torage procedures which identify the characteristics to be inspected and include the required frequencies. These procedures are based on technical considerations which ree.ognize that inspections and frequencies needed very from item to item.
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Page 59 Rev 18 Date: June 6,1997 8a.
N45 21 See 2.1 Raouirement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.
Excaotion/interoret at!on Instead of the five level zone designation system referenced in ANSI N45.2.3, Cnntumors Energy l
bases its controls over housekeeping activities on a considerativ i of vihat 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 inRructions make use of standard Janitorial and work practices to the extent possible.
However, in preparing these procedures, consideration is also given to the recommend 9tions of Section 2.1 of ANSI N45.2.3.
9a.
N45.2.4. Son 2.2 Ranuiramant Section 2.2 establishes prerequisites which must be met before the installation, inspection, and testing of instrumentation and electrical equipment may proceed. These prerequisites include personnel qualification, control of design, conforming and protected materials, and availability of specified documents.
Excaotion/interoratation 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 sad testing, the prerequisite conditions will be schleved as necessary.
9b.
N45 2 4. Sec 2.2(5)
Raouirement Section 2.2(5) of ANSI N45.2.4 lista documents which are to be available at the construction site.
Excention/Clarifleation All of the documents listed are no'. necessarily required c?. the plant site for installation and testing. Consumers Energy assures that they are available to the site as necessary.
l CPC 2A.R18
Page 60 RCv 18 Date: June 6,1997 9c.
N45.2.4. Sec 6.2.1 l
Raouirement
- ltems requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed the cahbration,"
E meantionlinteroret ation 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 Raouirement
" 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 lli capability."
Excantin,llnternratation m.
This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activit'y in the areas of concrete and structural steel which do not generally
'l occur at an operating plant. At Consume's Energy, persons having engineering managerial responsibility for inspections and tests' may be certified to Level lil, or may meet other qualification criteria established for the position. including, but not limited to,' nuclear power and management experience. For major modifications involving significant concrete or structural steel svork, the services of a properly qualified Level tilindividual will be obtained in at least an advisory capacity.
within the scope of N45.2.5 10b. N45.2.5. Sec 2.5.2
+
Raoultament "When discrepancies, malfunctions, or inaccuracies in inspection and testing equipment are'found during calibretion, all items inspected with that equipment since the last previous calibration shall be considered unacceptable until an evaluation has been made by the respord!e authority and appropriate action taken."
Excentionlinternretation l
Onnsumers Energy uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section a.t 2. The N18.7 requirements are more applicable to an operating plant.
- CPC 2A.R18
Page 61 Rev 18 Date: June 6,1997 10c. N45.2.5. Sec 5.4 Ranuirement
" Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more often if deemed necessary, imp 9ct torque wrenches used for inspection must be calibrated at least twice daily."
Excention/Intercretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 lla. N45.2.8. Sea 1.2 Raoulrament
~
"The requirements of this standard apply to personnel who perform inspections, examinations, and tests during f abrication prior to and during receipt of items at the construction site, during I
construction, during preoperational and start up testing, and during operational phases of nuclear power plants."
ExcentlanIlnternratation See Exception / Interpretation 2) for those inspectors who must be certified to this standard.
Others are qualif@d to Paragraph 10.2.7 of CPC 2A.
Qualificaticn 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 funct9n.
12a. RG 1.SB.;Sec C.1 Raoutramant
+r "However, for qualification of personnel (1) who approve preoperational, start up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start up and operational tests, the guidelines contained in Regulatory Guide 1.8, Personnel Selection and Training, should be followed in lieu of the Guidelines of ANSI N45.2.6 -
1978Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..*
CPC-2A.R18
Page 62 Rov 18 Date: June 6,1997 t
Encantion!!ntatore,tation l
Consumers Energy endorses this position, as also stated in lla, abovr. except that offsite support organizations involved in testing may apply ANSI N45.2.6. Some of these departments have already developed their qualification programs based on ANSI N45.2.6, and provide services l
throughout the operations phase of Consumers Energy Nuclear Plants.
12b. RG 1.58. Sec C.5 Raouirement "In addition, the individual should be capable of reviewing and approving inspection, examination an( Nating procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives."
Excention/Interoretation While a Level lliindividual should be capable of r~iewing and approving inspection, examination and testing procedures and of evaluating the aceq:cacy of such procedures to accomplish the l
Inspection, examination and test objectives, this is not construed by Consumers Energy as requiring personnel who review, approve or evaluate such procedures to be certified as Level ill personnel.,
12.c. RG 1.58. Sec C.6 Raoutrement "Since only one set of, recommendations provided for the education and experience of personnel, a commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be followed."
Excentionlinteroretation The education and experience recommendations given in ANSI N45.2.6, Section 3.5 will be treated as such, since our qualification and certification program is based upon these recommendations, and more significantly, upon satisfactory completion of capability testing prior to certification, it is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.
12.d RG 1.58. Sec C,10 Reauirement "Use of the measures outlined in these actions to establish that an individual has the required r,ualificat!ons in lieu of required education and experience should result in documented evidence (i.e., procedure and record of written test) demonstrating that the individualindeed r;oes have comparable or equivalent competence to that which would be gained from having the required education and experience."
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Page 63 Rev 18 Date: June 6,1997 Encantion/Interoratation 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 4
Raoutramant Section 2.7 requires that personnel performing inspection and test activities be que'ified according to ANSI N45.2.6.
Evenotionlinteroratation See Exception / interpretation 2j, lla, and 12a. Test personnel who are part of tne plant staff need not be ce'rtified't6'N45.2.6, provided they meet applicable qualification critoria of plant Technical Specifications.
~
13b. N45.2.B. Sec 2.9 Ranuirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing 7f' mechanical equipment may proceed. These prerequisites include personnel and procedure qualification, control of design, material selection and f abrication, and availability of specified" documents.
~
Excentionlinteroratation During the operations phase, this requirement is considered to be applicable to modifications of mechanical equipment..For routine or pericdic inspection and testing, the prerequisites will be achieved as necessary.
13c N45.2.9. Sec 2.9e Raouirement 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.
Excention!!ntaroratation All of the documents listed are not necessarily required ni the plant site for installation and testing. Consumers Energy assures that they are available 12 tne site as necessary.
l CPC-2A.R18 i
Pag 3 64 Rev 18 Date: June 6,1997 13d. N45.2.R. Sec 2.90 Raouirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.
Exceotion/Interoratation 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 Raoulrement
" 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/Interoratation 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 modificatiort activities.
14a. N45.2.9. Sec 5.4, item 2 Raouirement l
Records shall not be stored loosely. They snall be firmly attached in binders or placed in folders or envelopes'for storage on'sheMng in containers. Steel cabinets are preferred.
Excention/Interoratation Records are suitably stored in~ste'el filelabine'ts or,on shelving in containers. Methods other than
~~
binders, folders or envelopes (for exarnple, dividers. or eloctronic' media) may be used to organize the records for storage.
146. N45.2.9. Sec 6.2 Raouirement "A list shall be maintained designating those personnel who shall have access to the files."
CPC 2A.R18
Page 65 R3v 18 Date: June 6,1997 Excaotion/interoratation 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. IL71J11, C2 Raouiramant '
'Two methods of protection of quality as:urance records from the hazards of fire are described in Subdivision 5.6 of ANSt,N45.2.91974. NFPA No 2321975...also contains provisions for records protection equipment and records handling technioues 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...."
Evraction/Interoratation Consumers Ersigy adheres to ANSI N45.2.91974, Subdivision 5.6 for the facility for permanent l
~
storage.o,f_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 2321975 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).
~
15s. RG 1.84. C2 Reauirement "Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design...."
Excention/Interoretation Consumers Energy follows the requirements of ANSI N45.2.111974, Section G.1, and the l
guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of indivHually approved in advance in each case (see Section 3.2.9, herein). This approach is necessary to allow small organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively, accomplish their assigned tasks.
16a. RG 1.144. Sec C2a(1)
Raouirement This section requires that for operational phase activities, RG 1.33 " Quality Assurance Program Requirements (Operations)" are to be followed. One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and occur in facility CPC 2A.R18
Pag 3 66 Rsv 18 Date: June 6,1997 equipment, structures, systems, or method of operation are to be audited at least once per six months.
Eveantion/internratation See item 3a for the exception to this requirement.
16b. RG 1.144. Sec C3a(2)
Ranuirement 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.
Exeantionlinternratation
- Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.
16c. RG 1.144. Sec C3b(1)
Raauirement
~
This section identifies procurement contracts which are exempted frum being audited.
~
Eveantion/Internratation l-In addition to the exemptions of RG 1.144, Consumers Energy considers that Authorized Inspection Agencies, National Institute of Standards and Technology or other State and Federal l
. Agencies which may provide services to Consumers Energy are not required to be audited.
16d, RG 1.144 Sec C 3.b[2), second paragraph Raouirement A documented evaluation of the supplier should be performed annually Where applicable, this evaluation should take into ac' ount (1) revioWr of supplieV furnished' documents such as c
certificates of conformance, non-conformance notices, and corrective actions, (2) results of previous source verifications, audits and receiving inspections, (3) operating experience of identical or similar products furnished by the same suppliet, and (4) results of audits from other sources (e.g., customer, ASME or NRC Audits).
Excention/Internratation Consumers Energy will review the information described in the second paragraph of section C 3.b(2) of Regulatory Guide 1.144, Revision 1,1980, as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary CPC-2A.R18 l
Page 67 Rev 18 Date: June 6,1997 (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.
17a. N45.2.13. Sec 3.2.2 Raouirement 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/Interoratation For replacement parts and materials, Consumers EnerCy follows ANSI N18.7, Section 5.2.13, l
Subitem 1, which states: "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."
17b. N45.2.13, Sec 3.2.3 Renukament
" Procurement do:uments 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."
Excention/Interoratation Refer to item 21.
17c, N45.2.13. Sec 3.3(a)
- Raouirama'rit" Reviews of procurement documents shall be performed prior to release for bid and contract award.
Excentionlinteroratation Documents may be released for bid or contract award before completing the necessary reviews.
However, these reviews are completed before the item or service is put into service or before work has progressed beyond the point where it would be impractical to reverse the action taken.
17d. N45.2.13. Sec 3.3(b)
Raouirement s
CPC 2A.R18
2 Pag 3 68 Rev 18 Date: June 6,1997
" Changes made in the procurement documents as a result of the bid evaluations or precontract negotletions shall be incorporated into the procurement documents. The review of such changes and their effects shall be completed prior to contract award."
Excentionlintaroratation This tequirement 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 1 through 5.) The timing of reviews will be the same as for review of the original procurement document.
.17e. N45.2.13. Sec 7.5 Raouirement
" Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as appilcable."
Exemotion/Internratation l
Consumers Energy qualifies audit personnel according to N45.2.23. Thus; personnel performing source verif' cation audits may not be certified according to N45.2.6. Personnel performing inspection as part of source verification will be certified to N46.2.6 or qualified in accordance 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 Raouirement "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."
Excentionlintaroratation Refer to item 2m.
17g. N45.2.13, Sec 10.3.4 (as modified by RG 1.123, C6e)
Raouirement
" Post installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."
Excentionllnteroretation
.l In exercising its ultimate responsibility for its quality program, Consumers Energy establishes post-installation test requirements, giving due consideration to supplier recommendations.
l CPC 2A.R18
Pags 69 Rav18 Date: June 6,1997 18a.. ANSI N45.2.231978; Section 2.3.4 Raouirement The prospective lead auditor shall have participated in a minimum of five (5) quality assurance
~
audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of,vhich shall be a nuclear quality assuratice audit within the year prior to his qualification.
Excention/Internratation The prospective lead auditor shel demonstrate his ability to properly implement the :.udit process defined by this Standard and Consemers Energy program / procedure, to effectively lead an audit team, and to effectively organize and eport results, including participation in at least one nuclear quality assurance audit within the year preceding date of certification.
19a. RG 1.78, General l
Raouirement RG 1,26 establishes a system for classifying pressure bounc;.'y ras into four quality groups, which are then correlated with ASME 8&PV Code and ANSI St* dards requironients. (However, RG 1.26 does not indicate which of the four quality groups are safety related, and which are not.)
Excention/Intaroratation RG 1.26 e 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 21a, is used to determine what systems and equipment are included in the Quality Program.
20s. Branch Technical Position ASB9.5.1 and 10 CFR 50 Annandix R.
l Sectiona Ill G. til J.. and ill O.. General Excention/Interoratation Fire protection measures, equipment'and the individual plant Fire Protection Plans are in 1
compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 AppendP R except for the specific exemptions approved by the NRC.
21a. - RG 1.29. Sec C, Regulatory Position l
Raouirement The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category 1 and should be designed to withstand the SSE.
Excentionlinteroratation Both Consumers Energy nuclear plants (Big Rock Point and Felisados) were designed, constructed l
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, respec-
' CPC 2A.R18
Pago 70 Rev 18 Date: June 6,1997 tively, 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 Consumers Energy primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 21b, below).
l 21b. RG 1.29. General Raouirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B.
Excention/Interoratation The pertinent quality requirements for these systems, structures and components will be determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.
l l 22.
ANSI /ANS 3.1 -1987 Excentionlinteroratation The commitment to ANSl/ANS 3.1 1987 is limited to requirements that apply to persons performing the independent safety review function as specified in Appendix C to this QPD.
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Pag 3 71 RV 18 Date: June 6,1997 QPD MANUAL APPENDIX B PLANT REVIEW COMMITTEE (PRC) i 81.
FUNCTION The Plant Review Committee (PRC) shall funtNon to advise the Site Vice President / Plant General l
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 N18.1 1971. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Site Vice President.
l 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 mit.imum qualifications described in Sections 4.2 and 4.4 of ANSI N18.1 1971 for comparable positior.s. The Pr,C shallinclude representatives from the Operations, Chemistry / Health Physics, Mainton. ace, Engineering, and Safety and Licensing Departments. The members shall be designated in administrative procedures by the Plant l
Manager who is the Chairman of the PRC. The Plant Manager shall also designate an Alternate Chairman in writing.
83.
ALTERNATES Altemate members of the PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis. No more than two alternates shall participate as voting members at any one time in PRC activitios.
84.
MEETING FREQUENCY The PRC shall meet at least once per calendar month with special meetings as required.
B5, QUORUM A quorum of the Palisades PRC shall consist of the Chairman or altemate 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.
86.
RESPONSIBILITIES 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 Site Vice President / Plant l
General 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.
CPC 2A.R18 rv-
Pago 73 Rev 18 Date: June 6 1997 b.
All proposed changes to Operating License and Technical Specifications, Results of investigations of all violations of the Technical Specifications. (A report shall be c.
prepared covering evaluation and recommendations to prevent trcurrence and be forwarded to the Vice President NFHO and to the Manager, Nuclear Performance Assessment Department (NPAD)),
d.
Plant operations to detect potential safety hazards.
l e.
Reports of special reviews and investigations as requested by the Site Vice President / Plant General 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 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 l
General 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 s, to Safety / Design Review staff, as described in 89, below.
87.
AUTHORITY The PRC shall:
a.
Recommend in writing to the Site Vice President / Plant General Manager approval or disapproval of items considered under B6.a. through J. above,
~
b.
Render determinations in writing with regard to whether or not each item considered under l
B6.a. b, c, f (Palisades o ly) and h above constitutes an unreviewed safety 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 Senior Vice President Nuclear, Fossil, and Hydro Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC and the Site Vice President / Plant General Manager; however, the Site Vice President / Plant General Manager shall have responsibility for the resolution of such disagreements.
l The PRC Chairman may recommend to the Site Vice President / Plant General Manager approval of those items identified in B6. above based on a routing review provided the following conditions CPC-2A.R18 i
Page 73 Rev 18 Date: June 6,1997 t
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 Site Vice President / Plant General Manager overrides the recommendations of the PRC: or l
(3) a proposed change to the Technical Specifications involves a safety limit, a limiting safety system setting or a limiting r:ondition 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.
B9.
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 function shall be an experienced technical staff l
meeting the quaillications of Technical Specifications.
89.2 The Safety / Design Review staff may provide nuclear safety review as delegated by Palisades PRC l
for:
a.
Procedures, programs and changes thereto identified in the Technical Specifications and any additional procedures and changes thereto identified by the Site Vice President as significant l
to neclear 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.
B9.3 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 B9.2a.
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 under B9.2.
B9.4' Reports of Safety / Design Review activities pursuant to B9 shall be submitted monthly to PRC.
i CPC 2A.R18
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Page 74 Re(18 Date: June 6,1997 QPD MANUAL APPENDtX C INDEPErJDENT SAFETY REVIEW The following exceptions / interpretations in Appendix A. Part 2, are relevant to implementation of the requirements of this section of the OPD:
Annandir C Excentions/Intaroratations 2c, 2d, 2e, 2 f, 21 C1, FUNCTION The Independent Safety Review Group (ISRG) shall function to provide independent review of activities in the areas of; s.
Nuclear power plant operation b,
Nuclear engineering c.
Chemistry and radiochemistry -
d.
Metallurgy e.
Nondestructive testing f,
Instrumentation and control 4
g, Radiological safety h.
Mechanical and electrical engineering 1.
Administrative controls and quality assurance prsctices j,
Emergency Planning k.
Training C2.
COMPOSITION l
The ISRG shallinclude the Manager, NPAD, who reports to the Vice President NFHD, 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 ANSl/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 ISRG to review particular issues, the ISRG sh'll a
have the authority to utilize consultants or othe qualified organizations for expert advice, C4, RESPONSIBILITIES CPC-2A.R18
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. m C4.1 REVIEW l
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The ISRG shall review:
' ' =
5 The safety evaluations for 1) changes to proceeures, equipment or systems, and 2) tests for a.
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.
c.
Proposed 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, e.
Violations of codes, regulations, orders, Technical Specifications, license requirements,' or of -
internal procedures or instructions having nuclear safety significance.
= f.
Significant operating abnormalities or deviations from normal and expected pedormance of unit equipment that affects nuclear safety.,,,.
g.
. All reportable events having nuclear safety, significance.T ', ',,
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b.
All recognized indications of an unanticipated deficiency In some aspect of design or:
operation of structures, systems, or components that could affect nuclear safety, l.
Reports and meeting minutes of the Plant Review'Committ'ee.
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Fire Protection Program and implementing Procedure Changes (Palisades only).
k.
Reports of audits performed as specified in Appendix D.-
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 Perforrrance 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.
CS AUTHORITY The ISRG sh'all report to and advice the Vice-President, NFHO, of significant findings associated l
with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.
C6 RECORDS Records of ISRG activities shall be maintained. Reports shall be prepared and distributed as indicated below:
- CPC-2A.R18.
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Page 76 Rev 18 1
Date: June 6,1997 The results of reviews performed pursuant to C4 above shall be reported to the Vice-a.
l President, NFHO, at least monthly.
i b.
A report assessing each plant's overall nuclear safety performance shall be provided to senior
_l Consumers Energy management annually.
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Pag 3 77 :
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Date: June 6,1997 QPD MANUAL 4
APPENDIX D l-AUDIT FREQUENCIER D 1.
AUQlIA
- Audits of operational nuclear safety related activities are performed by the NPAD staff under the j.
cognizance of Nuclear Performance Specialists. These audits encompass:
i The conformance of plant operation to provisions contained within the Technical s.
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.
4 The performance of acti '.aes required by the Quality Program Description for Operational c.
F Nuclear Power Plants (C's' 2Al to meet the criteria of 10 CFR 50, Appendix B at least once per 24 months.-
7-
]
d.
The Site Emergency Plan con implementing procedures at least once per 12 months.
The Site Security Plan and iniplementing procedures (as required by the Site Security Plan) at j
e.
least once per 12 months.
E f.
Any other area of plant operation considered appropriate by NPAD or the Vice President -
NFHO.
l g.
The 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 en outside fire protection firm.
l.
An inspection and audit of the fire protection and loss prevention program to be performed
(:_
L
- by an outside qualified fire consultant at intervals no greater than 3 years. -
J.
Radiological environmental monitoring program and the results thereof at least once per 12 months.
i k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
1.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
l Audit reports encompassed by D1. above shall be forwarded to the Manager, NPAD, and j.
Management positions responsible for the areas audited within thirty (30) days after completion of the audit.
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Rev 18-Date: June 6,1997 k
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QPD MANUAL APPENDIX E RECORQ Ig5TENTION i-
- 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 rninimum period indicated:
i-E2, The following records shall be retained for at least five years:
l-
~ a.
Records and logs of f acility operation covering time interval at each power level, i
l b.
Records and logs of principal maintenance activities, inspections, repair and replacement of t-principalitems of equipment related to nuclear safety.
l c.
All reportable events as defined in 10 CFR 50.72 and 50.73.
l:
d.
Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications, t
Records of changes made to the procedures required}y Plant Technical Specifications.
e.
f.
Records of radioactive shipments.
l g.
' Records of sealed source leak tests'and results.
- 7 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 4
equipment described in the Palisades Final Safety Analysis Report or Big Rock Point Final y
Hazards Summary Report.
b.
Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories, t
c.-- - Records of quarterly radiation exposure for allindividuals entering radiation control areas.
l ll d.
Records of gaseous and liquid radioactive material released to the envirens.
h e.
Records of transient or operational cycles for those f acility components designed for a limited
[
number of transients or cycles.
~
f.
Records of inservice inspections performed pursuant to Plant Technical Specifications.
g.
Records of Quality Assurance activities required by the Quality Program Description.
h.-
Records of reviews performed for changes made to procedures or equipment or reviews of i.
tests and experiments oursuant to 10 CFR 50.59.-
4 i
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Page 79 Rev 18 Date: June 6,1997 1.
Records of meetings of the PRC and reviews performed by NPAD according to Appendix B and C.
j.
Records of mon'nly f acility radiation and contamination surveys..
k.
Records of secondary water sampling and quality (Palisades only).
1.
Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specifications. This shallinclude the date at which the service life com.Mnces and associated installation and maintenance records (Palisades only),
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, 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 (Palisados only).
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1 ATTACHMENT 4 l
CONSUMERS ENERGY BIG ROCK POINT PLANT DOCKET 50-155 LICENSE DPR-6 PAllSADES PLANT DOCKET 50 255 LICENSE DPR 20 PROPOSED REVISION OF CPC-2A, REVISION 19a 0
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' August 22,1997 4
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SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE
' CONSUMERS ENERGY PROGRAM FOR NUCLEAR POWER PLANTS -
- As President and Chief Executive' Officer. Electric of Consumers Energy, I have the ultimate
. l management authority for the Consumera Enarav Nalltv Proaram Descrintion for Nuclear E
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 o
1 contained in ANSI N18.7, and.to the ANSI N45.2 Series of Standards and corresponding 1
a
[.
Regulatory Guides within the enntext of applicability imposed by N18.7. The Quality Program Description for Nuclear Power Plants outlines the actions that are implemented for important activities including fueling, testing, operation, refueling, procurement, maintenance, repair,'
modification design and construction, and decommissioning of the safety-related portions of the nuclear power plants.
I have delegated responsibility _ for establishing, maintaining and implementing the Qeality Program Description to the. Senior Vice President, Nuclear, Fossil end Hydro Operations. l
. l
}
have delegated selected 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.
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i Pcga il Rev 19e Date: Draf t i
QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS REVISION 19 f
APPROVED BY:
Senior Vice President, Nuclear, Fossif, and Hydro Operations Date Robert /.. Fenech 1
Vice President, Electric Transmission and Distribution Date Carl L. English 4
Vice President, Information Technology and Operations Services Date Kenneth C. Emery Vice President and Secretary Date
' Thomas A. McNish CPC2R19A.WPD
m __..
P:93 lii R:V 193 Date: Draft QUALITY PROGRAM DESCRIPTION FOR NUCLEAR POWER PLANTS CONTENTS Section Title Paae Statement of Responsibility and Authority I
Approval Page il Contents lii 1.0 ORGANIZATION
............................................ 1 2.0 Q U ALITY PR O G RAM........................................ 10 3.0 D ESIG N CO NTRO L.......................................... 14 4.0 PROCUREMENT DOCUMENT CONTROL
.......................... 17 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS.................... 19 6.0 DO C U M ENT CO NTRO L....................................... 22 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES....... 24 8.0 IDENTIFICATION AND CONTROL OF ITEMS........................ 26 9.0 CONTROL OF SPECIAL PROCESSES 27 10.0 I N S P E CTIO N...................................,.......... 28 11,O' TEST CONTROL
........................................... 31 12.0 CONTROL OF MEASUR!NG AND TEST EQUIPMENT.................. 33 13.0 HANDLING, STORAGE AND SHIPPING............................ 35 14.0 INSPECTION, TEST AND OPERATING STATUS...................... 36 15.0 =
NONCONFORMING MATERIALS, PARTS OR COMPONENTS............. 37
-16.0 CO RRECTIVE ACTIO N....................................... 38 17.0 QU ALITY R EC O R D S......................................... 39 18.0 AUDITS.................................................
41
- CPC2R19A.WPD
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9 Pageiv R:v 19e
. Date: Draft c
1 APPENDlX A...................
..........................-............. 43 1
A PPE N D IX 8 '.................................................. -........ - 7 0
.i A PP E N D I X C.......................................................... 74 APPE N DI X D............................................-............... 77-
' APPENDIX E
........................................................... 78 FIGURE 1 Consumers Energy Corporate Organization..............,................. 9 J
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- CPC2R19A.WFD
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Date: Draft 1.0 -
ORGANIZATION 1.1 REQUIREMENTS Consumers Energy is responsible for establishing and implementing the Quality Program, as described herein, for 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, Consumers Energy retains overall responsibility.
This section of the Quality Program Description (QPD) identifies the Consumers Energy organizations responsible for activities affecting the quality of safety-related nuclear power plant structures, systems and components and describes the authority and duties assigned to them, it addresses responsibilities for attaining quality objectives; for establishing and main-taining 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 (NPAD) functions (audits, surveillances, and independent safety reviews) are performed by personnel within formally designated or-ganizational units that report to the Manager, Nuclear Performance Assessment or members of other organizations as selected by the Manager, Nuclear Performance Assessment. The reporting level of the Nuclear Performance Assessment organization affords sufficient authori y and organizational freedom, including sufficient independence from the cost and t
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.
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 1.2.1 2a 1.2.2 2g 1.2.2.c 2,2b,2c 1.2 IMPLEMENTATION 1.2.1 ~
Sc cce of Authority The President and Chief Executive Officer Electric (see Figure 1, Company Organization Chart) of Consumers Energy is responsible for safe operation and decommissioning of
' Consumers Energy nuclear power plants. Authority and responsibility for establishing and implementing the Quality Program for plant operations, maintenance, modifications and decommissioning is delegated to the Senior Vice President - Nuclear, Fossil, and Hydro Operations. This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer - Electric. Other quality-l related functions are provided by other organizations as described herein.
CPC2R19A.WPD
P:g2 2 R:V 192 Date: Draf t 1.2.2 Resoonsibility for Attainino Quahtv Oblectives at the Nuclear Plants The Senior V'ce President - Nuclear, Fossil, and Hydro Operations (NFHO) is responsible to the President and Chief Executive Officer Electric for operation, maintenance, and decommissioning of Consumers Energy nuclear power plants. Managers who report to the Vice President, NFHO. m, responsible for directing the performance of activities that affect safe plant operation and/or safety-related functions of structures, systems and components of the nuclear power plants in accordance with Quality Program requirements, e.
The Palisades Plant Site Vice President (see Figure 1) is responsible to the Senior Vice President, NFHO 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 Site Vice President 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 Site Vice President include:
Qualification of plant operating, inspection, maintenance and engineering personnel, including certification of inspection personnel.
Preparation, review and approval of procedures and instructions.
Modifying components, including procurement, installation, inspection and testing activities.
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 lli 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.
CPC2R19A.WPD
P:g2 3 RIv193 Date: Draf t Plant site inspection program, including insper: tion 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 tho inservice inspection program in accordance with technical specifications and State of Michigan rules.
Performing reviews to advise the Site Vice President on matters related to nuclear safety, as specified in Appendix B, Plant Review Committee.
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 -f NRC reportabil'ty 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 prepar-ing, 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.
Providing, as requested, technical expertise and review capability to Nuclear Plants in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil structural engineering and application of codes and standards.
Preparation, review and approvtl of means that identify safety related plant structures, systems and components, and activities to which this QPD apply, as described in Section 2.0, Performing analytical studies to appraiso 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.
CPC2R19A.WPD l
Page 4 R:V 19a Date: Draf t Procurement, including preparation, reviews and approval of purchase requests for spares, replacement items, c,onsumables, and materials, items and services and submittal of purchase requests to Purchasing. Planning and execution of vendor source survell-lance 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 matcrials and items and Itoms awaiting dispositlun implementation af ter removal from service, assunng preservation of identification.
)
Developing, rnalntaining and implementing security and fire protection plans.
Maintaining the Records Management System including required retention, protection and retrievability. This includes tollecting, storing, maintaining, distributing and controlling plant engineering / design documents.
b.
The Big Rock Point Site General Manager (see Figure 1) is responsible to the Senior Vice Pres' dent NFHO for operation, maintenance, and decommiroloning of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable regula.
l tions and the Quality Program. The Site Or;neral 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 4
l authority of the Site 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.
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 l
activities when assigned by the Site General Manager.
Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment t'elng calibrated, and assuring that such use cannot result in opermion outside Technical Specifications limits.
Maintaining Echelon ill calibration facilities for Portable and I.aboratory Measuring and Test Equipment (PL M&TE) and Health Physics PL M&TE (HPPL M&TE),
Calibrattori/ maintenance of installed plant instrumentation.
Maintaining a calibration recall system.
Maintaining a Master List for plant owned PL M&TE.
l Performing necessary surveillance testing.
Maintaining equipment status control.
CPC2R19A.WPD
Page5 R:V 19e Date: Draf t
)
Maintaining required controlr over chemical standards and reagents.
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.
Plant site inspection program, including Inspection of maintenance, testing and fuel l
handling.
Preparation, review, and approval of means that identify safety related plant structures, systems and components, and activities to which this OPD apply, as described in Section 2.0, depending on plant conditions during dismantlement.
Assuring that nonconforming items are identified, segregated and dispositioned.
Nuclear engineering such as accident transient and physics analysis of spent fuel storage configurations.
Establishing, implementing and documenting the training of operating and technical l
support personnel, including Quality Program Indoctrination and training.
I 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 vendar source survell.
lance 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 af ter removal from service, assuring preservation of identlfication.
Accomplishing plant licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or trackhs licensing commitments and coordint' ting Internal action on NRC bulletins, generic letters, etc.
Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability.
Operating experience reviews including NRC Information Notices.
Performing the engineering, construction, inspection and testing associated with plant modification projects as assigned.
l Developing, maintaining and implementing security, fire protection and emergency plans.
Performing reviews to advise the Site General Manager on matters related to nuclear safety, as specified in Appendix B, Plant Review Committee / Safety Review Committee.
CPC2R19A.WPD s
l PCgo 0 i
l Rev 19a Date: Draf t 1.2.3 Reanonsibilities of the Nuclear Performance Assessment Denartment i
The Manager, Nuclear Perform mco Assessment Department, (see Figure 1) is responsible to the Senior Vice President, NFHO, for:
l Assessment of the effectiveness of the Nuclear Quality Program.
Performance of the offsite safety review functions for the nuclear power plants as described in Appendix C, Independent Safety Review.
Supplier surveys and evaluation including review / approval of supplier QA programs, and I
maintenance of the Nuclear Approved Suppliors List.
l Preparation, revlow, approval and implementation of departmental procodures governing nuclear assessment activities.
Assessment of nuclear safety performance as described in the Technical Specifications.
Assuring that assessments are done by personnel not directly responsible for the work being performed.
Recommending to the Site Vice President or the Senior Vice President NFHO that a plant be shut down if such action appears necessary.
Assessment programs (plent sites and Corporate Office), including follow up on corrective action for audit findings.
Review of performance trends associated with nuclear plant activities including corrective actions.
Analysis of new and/or changed regulatory direction, codes and standards to determine their effect on the Quality Program.
l Maintenance of the Quality Program Description for Nuclear Power Plants.
Reporting audit findings relative to follow up on corrective actions and the effectiveness of the Quality Program to Consumers Energy Management.
Maintenance / operation, processing and status reporting of the corrective action system (Palisades only).
Facilitation of Self Assessment and Quality Verificat!on Programs (Palisades only).
In order to implement these responsibilities, the Manager, NPAD, is provided with "Stop Work" authority whereby he can suspend any quality related activity or process which may, in nis opinion, adversely affect public safety or the safe operation of Consumers Energy 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.
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_- - -- ~.~.- --.
Page 7 Rev 19a Date: Dra f t The Manager, Nuclear Performance Assessment has no other primary duties or esponsibilities unrelated to Nuclear Performance Assessment that would prevent his attentior to Nuclear Performance Assessment matters,is sufficiently free from schedule and cost ferossures to give eppropriate weight to quality considerations in his deelslons and tecommendations, and has direct accear to high enough levels of Management to obtain resolution of quality problems.
1.2.4 Rannonalbilities of tha,Eaulomant Servican Department The Manager, Equipment Services provides electrical, rotating and stationary equipment expertise, including developing and qualifying procedures for welding and heat treating.
1.2.5 Sanoonsibility for Attainino cuality oblactiven outalda Nuclear. ransit. and Hvdro ocarations Certain functions that constitute part of the Nuclear Quality Program are performed by Consumers Energy organizational units outside the Nuclear, Fossil and Hydro Operations Department. Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization responrJble for that activity (i.e.,
the design authority),
s.
The Manager, Electric System Operations (see Figure 1) is responsible through the Vice President, Electric Transmission and Distribution to the President and Chief Executive Officer Electric for determining settings for electrical peotective systems and relay control schemes, for design, review and recommyJing changes to electrical protective schemes and associated settings.
b.
The Executive Manager, Fuels & Power Transactions is responsible to the Vice President and Chief Executive Officer Electric for maintaining the Records Management 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 Pig Rock Point, c.
The Corporate Records Administrator (see Figure 1) la responsible through the Vice President and Secretary for microfilming of specified quality records and plant engineering /derign documents, d.
The Manager, Environmental and Technical Services (E&TS) is responsible, through the Vice President, Information Technology and Operations Services to the President and Chlef
' Executive Officer Electric for l
Maintaining the Company's Echelon ll calibration facility frst calibrating reference and secondary standards and general usage portable and laboratory measuring and test equipment.
Controlling the calibration recall system for Portable and Laboratory M&TE owned by E&TS, and other departments, as requested, Maintaining a Master PL M&TE List for E&TS PL M&TE and for other departments, as requested.
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________m T
PCgo 8 Rav 19e I
Date: Draf t Providing a PL M&TE inventory Liet for Nuclear plants.
Providing chemistry support to Nuclear plants, as requested.
l Preparing, reviewing, approving and obtaining additional reviews and approvals if required, of purchase requests for services, equipment and consumables, and submitting such requests to purchasing for procurement action.
3 Conducting performance tests on materials, equipment and systems when requested, j
Performing nondestructive examination, and controlling / maintaining NDE equlpment.
Providing quellfied NDE procedures and equipment and NDE personnel.
l Providing chemical and metallurgical analytical services.
)
Providing necessary corrective action processing and status reporting for assigned corrective action documents.
e.
The Manager, Electric Services is responsible, through the Vice President, Electric l
Transmission and Distribution to the Executive Vice President and Chief Executive Officer.
Electric for testing and maintaining electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and 6pplication of associated settings. The Manager Electric Services is also respons'ble for operating the Skill Centers including the training, and qualifying of personnel and equipment for welding oporations.
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Page 9 Rev.19a Date: Draf t
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Page 10 R;v19a Date: Draf t 2.0 QUALITY PROGRAM 2.1 REQUIREMENTS l
Policles that define and establish the Consumers Energy Quality Program for 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 Dosenption and will be carried out for the life of each plant. Plant life is defined as the period covcred by a valid license under 10 CFR 50.
Quality controls apply to activities affecting the quality of safety related structures, systems and components, to an extent based on th;importance of those structures, systems, or components to safety. Such activitles 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 Consumers Energy Management through reports, tnectings 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 requirenients of this section of the OPD:
Parnacaoh Excentionslinteroretations 2.2.3 21 a, 21.b 2.2.5 19a 2.2.6 1,19,21a,21b 2.2.9 2J, 4a, Sa, 5b, 6a, 7b,10a,11 a,12a,12b,12c,12d,13a,17e 2.2.10 2e, 2f 2.2 IMPLEMENTATION l 2.2.1 The President and Chlef Executive Officer Electric, 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, Appendix 8. The staternent 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 of f activeness.
2.2.2 The Quality Program at Consumers Energy consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (seo Section 1.0, ORGANIZATION).
2.2.3 The affectivity and applicability of this Quality Program Description are as follows:
a.
For Big Rock Point and Palisades, the Quality Program Description became effective on April 1,1982, with full implementation on January 1,1983.
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P:ge 11 R';v 19e Date: Draf t b.-
The Quality Program described in this Quality Program Description is Intended to apply for the life of Consumers Energy's nuclear power plants.
The Quality Program applies to activities affecting the quality of safety related structures, c.
systems, components and related consumables during plant operation, maintenance, testing, modifications, and decommissioning Those activities having a direct impact on l
i safety related items shall be controlled. Safety related structures, systems, components and related consumables are identified in accordance with the critoria of Regulatory Guide 1,29 as clarlflod by items No. 21s and No. 21b in Part 2 of Appendix A to thin Quality Program Description. Identification may be via *0 Usts," electronic data bases.
or other controlled means. For Big Rock Point, this identification is maintained current with plant conditions during dismantlement.
t 2.2.4 This Quality Program Description, organized to present the Consumers Energy Quality Program for Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states l
Consumers Energy requirements for each of the criteria and describes how the controls pertinent to each are carried out. Any changen made to this Quality Program Description that do not reduce the c9mmitments previously act..pted by the NRC must be submitted to the NRC at least annually as specified by 10 CFR 50.71.e. Any changes made to this Quality Program Description that do reduce the committnents previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation in accordance with the requirements of 10 CFR 50.64.
The prograrn 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.
2.2.6 Documents used for implementing the provisions of the Quality Program Description include the following:
Administrative procedures specify the standard methods of accomplishing plant activi-a.
ties. Because the Quality Program is an Integral part of these activities, the methods for implementing Quality Program controls are integrated into these documents, b.
When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50, Appendix B and the contract, and are approved by Consumers Energy prior to the start of
- work, c.
Applicable elements of the Out.lity Program are applied to emergency plans, security plans, radiation and fire protection plans for Consumers Energy nuclear power plants.
These plans describe quality controls applicable to associated equipment and activities.
2.2.0 Provisions of the Quality Program for Nuclear Power Plants apply to activities affecting the l
quality of safety related structures, systems, components and related consumables, Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits. Appendix A also describes necessary excep-tions and clarifications to the requirements of those documents. The scope of the program and the extent to which its controls are applied are established as follows:
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R:v192 l
Date: Draf t I
Consumers Energy uses the criteria specified in Regulatory Guides 1.26 and 1.29 in a.
engineering 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 reisted or non safety related. Identification may be via *0-Lists, electronic data bases or other controlled means. This information is available for inquiry by individuals involved in plant activltles. The classification of structures, systems and consumables is also identified, documented, and controlled. For Big Rock Point, this identification is maintained current with plant conditions during dismantlement, The extent to which controls specified in the Quality Program are applied to items is
{
c.
determined for each item considering its relative importance to safety. Such determina-i tions are based on data in such documents as the plant safety analysis, plant TecFnical l
Specifications and the UFSAR/UFHSR (See Appendix A).
2.2.7 Activities affecting the quality of safety related items are accomplished under controlled conditions. Preparations for such nctivities 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 en acceptable status, Systems or structures on which work is to be performed are in the proper condition for e.
the task, f.
Authorized current instructions / procedures for the work are available for use, g.
Items and f acilities 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 Consumers Energy are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).
2.2.9 Responsibility and authority for planning and implementing indoctrination and training are specifically designated in the Consumers Energy organization (see Section 1.0, ORGANIZATION).
The training and Indoctrination program provides for ongoing training and periodic a.
l ref amillarization with the Quality Program for Nuclear Power Plants.
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PCge 13 Rev 19e Date: Draf t b.
Personnel who perform inspection and examination functions are quellfled in accordance with requirements of Regulatory Guide 1.58, SNT TC 1 A, or the ASME Code, or Section 10.2.3 of this Quality Program Description, as appilcable, Personnel who lead audits are qualified in accordance with Regulatory Guide 1.146.
c.
Others are either qualified to ANSI N45.2.23 or have detailed expertise in the area being
- audited, d.
Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with applicable codes, standards and regulatory guides, The training / qualification program for personnelleading audits includes provisions for e.
retralning, reevaluation and racertification to ensure that proficiency is maintained.
f.
Training and qualification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the personnelinvolved are performing activities to which the training / qualification is relevant, g.
Personnel responsible for performing activities that affect quality are instructed as to the requirements identified in applicable quality related manuals, instructions and procedures.
2.2.10 Status and adequacy of the quality program are regularly assessed by Consumers Energy Management. The following activities constitute formal elements of that assessment:
a.
Audit reports, including follow up on corrective action accomplishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).
b.
NPAD ISRG assesses the nuclear safety performance as described in Appendix C.
Conclusions and recommendations are reported to the Senior Vice President, Nuclear, Fossil, and Hydro Operations.
Corrective actions in response to recommendations are tracked in the regular esivtive action tracking system (see Section 16,0, CORRECTIVE ACTION),
CPC2R19A.WPD
Pago 14 Rev 19a Date: Draf t 3.0 DESIGN CONTROL 3.1 REQUIREMENTS 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 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 OPD:
Parnaraoh Exceotions/Interoretations 3.1 9a,13b 3.2.9 15a 3.2.10 13d 3.2 IMPLEMENTATION 3.2.1 Authority and responsibility for modification activities is under the cognizance of the Nuclear Plants 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 criterla; c) Drawings and specifications; and d)
Engineering analyses and associated computer programs.
3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect 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 requirements of applicable codes and standards or on known, successful use under similar conditions. This includes standard commercial materials, parts and processes. Alternatively, materials, parts and proceues may be qualified for use through qualification testing (see item 3.2.8). The adequacy of the selected materials, parts and processes is assured through the required design verifications or approvals.
3.2.4 Exceptions and waivers to oc deviations fro' the engineuing (qual!!y) standards (i.e., the required dimensionti, material properties, features and other characteristir s specified for modifications) are required by procedure and by contract, when appFcable, to be documented and controlled. (See, also, Section 15 concerning the approval of " repair" or 'use as is" dispositions of nonconformances.)
3.2.5 When modifications involve design interf aces 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 CPC2R19A.WPD
Pag) 16 Rev 19a Date: Draf t 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 interf aces are made by the Consumers Energy organization having responsibility for engineering direction of the design effort.
3.2.0 Checks are performed and documented to verify the dimensional accuracy and completeness of design drawings and specifications (i.e., the products of a design processh 3.2.7 Modification design document packages are reviewed by Plant Engineering 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 previous'y 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 evnluating stanaardized 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 po'forre an essential safety function cannot otherwise be adequately substantiated. This testing is performed before plant equipment installation where possible, but always beforo reliance upon the item to perform a safety-re9ted function. Qualification testing is performed under conditions that simulate the most advelse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented. Results are evaluated to assure that test requiretrents have been satisfied. Modifications shown to be necessary through testing are made, bnd 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 deterrr.ine when a formal group review is required and when review by an Individual is sufficient.
Unless otherwise stated, the verification of design addresses allinformation conveyed bt the design document. When the verification is limited to certain areas or features, the scope or extent and any limitations on the verification are document 0d.
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 dircctly responsible for the design. T6 r designer's Irnmediate supervisor may perform the verification, provided thct:
CPC2R19A.WPD
PCge 16 Rav 19a Date: Draf t (1) He is the only technically qualified individual available, and (2) He has not specified a singular design approach, ruled out certain design considerations or established the design inputs for the particular design aspect being verified, and (3) His review is alther:
a.
Approved in advance by the supervisor's management, with documentation of the approval included in the design package, or b.
Controlled by a procedure which provides specific limitations regar 1ng the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification, independent audits by Nuclear Performance Assessment cover the frequency, of fectiveness, and technical adequacy of the use of supervisors as design verifiers to guard egainst 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 proseed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety related function. Justification for such early release is documented.
3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their use is specified.
3.2.12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that t. Sed for the original deslyn. Such changes are evaluated for impact.
Those that affect fit, form, or function are reviewed and ipproved by the same, or equivalent, organizations that approved the original design. Information on approveo changes is transmitted to all af fected organizations.
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Page 17 Rev 19a Cate: Draf t 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 REQUIREMENTS 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 pro 0 ram requirements to the extent necessary to assure adequate quality.
The followlog exceptions / interpretations in Appendix A, Part 2, are relevant to implementation i
of the requirements of this section of the OPD:
i Parnaraoh Excentions/Interoretations 4.2.1 17c,17d 4.2.3 21,17a,17b 4.2.5 17d l
l 4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement plannin0 and for preparation, review and approval of procurement documents are delineated In Section 1.0, ORGANIZATION.
Procurement request packages are reviewed and approved prior to subrnittal to the Purchasin0 and Materials Department. Review includes verification that the necessary quality regt:Iremente are specified, The responsible project engineer performs bid evaluations.
i 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 member and revision and date, with any required procedures such as special process instructions identified in such a way as to indicato 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 inspecticns.
A requirement for a documented Quality Program, subject to Consumers Energy review c.
ar.d written concurrence prior to the start of work.
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P:ga 18 R:v19a Date: Draf t f.
A requirement for the supplier to invoke applicable quality requirements on subtler suppliers, g.
Provisions for access to supplier and subtler suppliers' f acilities and records for inspections, surveillances and audits.
h.
Identification of documentation to be provided by the supplier, identification of documents to be compatible with the records system, the schedule of submittels and identification of documents requiring Consumers Energy approval.
4.2.4 Trained, qualified personnel perform and document reviews of procurement request packeges to assure that:
a.
Quality requirements (see 4.2.3 of this Section) are correctly stated, inspectable, and controllable, b.
Acequate acceptance and rejection criteria are included, c.
The procurement documents have been prepared, reviewed, and approved per the Quality Progrem rexlrements.
4.2.5 Changes to the technical or quality requirements in procurement documents are controlled in a manner commensurate with that used for the original requirements. Those that could affect fit, form, function or the necessary assurance of quality are reviewed and approved by the same, or equivalent, organizations that approved the original procurement request packages.
1 CPC2R19A.WPD
P:g) 19 Rev 19a Date: Draf t 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 REQUIREMENTS Activities affecting the quality of safety related structures, systems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances which include acceptance criteria for determining if an activity has been satisfactorily completed.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requltements of this section of the OPD:
Parauraoh Exceotions/Interoretations 5.1 9a,13b 5.2.8 2r, 2s, 8a 5.2.14 Bb 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 Instructions, procodores and drawings necessary to accomplish the activity are prepared and implemented.
Instructions, procedures and drawings incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and/or qualitative (such as workmanship standards) acceptance criteria sufficient to determine that the activity has been satisfactorily accomplished.
Temporary procedures may be issued to provide management instructions which have short-term applicability. Temporary procedures include a designation of the time perloo during which they may be used.
The procedures used by Consumers Energy to controlits activities include the following:
1.
Administrative Procedures.
2.
System procedures that describe the operation of the plant.
3.
Start up procedures that provide for starting the reactor from hot or cold condition and recovering from reactor trips (Palisades only).
l 4.
Shutdown procedures that provide for controlled reactor shutdown or shutdown fo!!owing reactor trips (Palisades only).
l S.
Power operation and load changing procedures that provide for steady state power operation and load changing, including response to unanticipated load changes (Palisades only).
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P:g) 20 Rev 19a Date: Draft 6.
Process monitoring procedures that provide for monitoring plant system performance and wh?ch, as appropriate, identify lirnits for significant process parameters.
7.
Fuel handling procedures that provide for activities such as:
l a.
Core alterations (Palisades only) l b.
Refueling (Palisades only) c.
Fuel accountability d.
Receipt and shipment of fuel e.
Nuclear safety measures l
f.
Fuel movement 8.
Maintenance procedures that pre side for:
a.
Preparation for maintenr.ce b.
Performance of maintenance c.
Post maintenance and operability checks and tests d.
Use of supporting maintenance documents 9.
Radiation control procedures that provide for:
a.
Implementation of the radiation control program including the acquisition of radiation data b.
Identification of equipment for performing radiation surveys c.
Measurement, evaluation and assessment of radiation hazards 10, Calibration and test procedures that provide for:
a.
Periodic calibration and testing of safety related instrumentation and control systems b.
Calibration of portable measuring and test equipment used in activities affecting safety
- 11. Chemical radiochemical control procedures that provide for activities including:
a.
Sampling and analyses b.
Maintenance of coolant quality c.
Control of deleterious agents CPC2R19A.WPD
P:ge 21 R:v19a Date: Draft d.
Control, treatment and management of radioactive wastes e.
The control of radioactive calibration sources
- 12. Emergency proceduras that provide guidance for:
a.
Operations during potential emergencles so that a trained operator will know 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
- 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 coriditions 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 Consumers Energy and its suppliers d.
Control of onsite quality related modification activities that assure the Quality Program is implemented and its effectiveness is assessed and reported
- 16. Decomrnissioning procedures that provide for controlled dismantlement of the plant and restoration of the plant site.
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6.9 DOCUMENT CONTROL 6.1 REQUIREMENTS 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, 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 la 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.
l Personnel authorized to approve procedures specified by Plant or Permanently Defueled Technical Epocifications are limited to an appropriate senior department manager, based on the activities addressed in the specific procedure, predesignated in writing by the Site l
Vice President / Site General Manager.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraornoh Excentlons/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.
lastructions and procedures for activities such as fabrication, construction, modification, l
Installation, inspection, test, plant maintenance and operation, and decommissioning which implement the Quality Program.
l e.
Updated Final Safety Analysis Report / Updated Final Hazards Safety Report f.
Reports of nonconformances l
g.
Plant Technical Specifications (Palisades)
CPC2R19A.WPD
,-m
P:gle 23
)
Rev iga Date: Draft i
h.
Permanently Defueled Technical Specifications (Big Rock Point) l 6.2.3 The review, approval, issue and change of the above documents are controlled by:
Establishment of criteria to ensure that adequate technical and quality requirements are a.
incorporated, b.
Identification of the orgenlaations responsible for review, approval, issue and revision, Review of changes to documents by the organizations designated in accordance with the c.
~
procedure governing the review and approval of specific types of documents, including quality aspects.
6.2.4 Controlled documents are issued and distributed so that:
The documents are available at the work location prior to commencing work a.
-b-Obsolete or superseded documents are removed from work areas and replaced by 1
applicable revisions in a timely reanner 6.2.5 Master lists or equlvalent controls are used to identify the current revision of instructhins, procedures, specifications, drawings and procurement documents. When master lists cre used they are updated and distributed to designated personnel who are responsible for maintaining current copies of the lists.
6.2.6 Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.
(-
CPC2R19A.WPD
P:g) 24 Rev 19s Date: Draf t 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT A' > SERVICES 7.1 REQUIREMENTS Activities that implement approved procurement requt s for safety related material, l
equipment and services are controlled to assure confol.,iance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination t,nd acceptance of items and documents upon delivery, and periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant site prior to tellence on equipment, material or services for nuclear safety.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation l
of the requirements of this section of the OPD:
Earagraoh Excaotlons/Interoratations 7.1 21 7.2.2 16d 7.2.3 7b,17e 7.2.5 2m, 7e,17f 7.2.6 2m, 9b,13c,13d,17f 7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in Section 1.0, ORGANIZATirN.
7.2.2 Consumers Energy qJalifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents. To remain -
quellfled, suppliers involved in active procurements are evaluated continuously and are audited triennially. If an audit is acquired from an external soerce, the audit is evaluated prior to its use.
Supplier evaluation and triennial audits are not necessary when the items or services supplied are all of the following:
Relatively simple and standard in design, manufacture and test, and a.
b.
Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics af ter delivery, and Such that receiving inspection does not require operations that could adversely affect the c.
integrity, function or cleanness of the item.
In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service.
7.2.3 Supplier activities that affect quality are verified in accordance with written procedures.
These procedures provide the method of verifying (such as audit, surveillance or inspection) and documenting that the characteristics or processes meet the requirements of the
.CPC2R19A.WPD
Page 25 R:V 192 Date: Draf t 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, a.
Specifications and codes referenced in procurement documents for spare or replacement items are at least equivalent to those for the originalitems or to properly reviewed and approved revisions.
b.
Parts intended as spares or replacements for 'off.the shelf" ltems, or other items for which quellty requirements were not originally specified, are evaluated for performance at least equivalent to the original, c.
\\ If..' 1uality requirements for the original items cannot be determined, requirements a id contMs are established by engineering evaluation performed by qualified Individuals.
T se evalustan assures there is no adverse effect on Interf aces, interchangeability, s' %d. fit,.orm, function, or compliance with applicable regulatory or code requirements.
Evaluatn.,.i results are documented.
d.
Any additional or modified design criteria, imposed af ter 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 verifled by source surveillance or inspection and that required supplier furnished documentation is available, items inspected are identified as to their acceptr.nce status prior to their storage or release for Installation.
7.2.6 Suppliers are required to furnish the following records:
a.
Applicable drawings and related engineering documentation that identify the purchased item and the specific procurement 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 requirements.
The acceptability of these documents is evaluated during source and/or receipt inspection.
7.2.7 Suppiler'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.
CPC2R19A,WPD
P:ge 26 R:V 19a Date: Draf t 8.0 IDENTIFICATION AND CONTROL OF ITEMS 8.1 REQUIREMENTS Safety-related materials, parts and components (items) are identified and controlled to prevent i
their inadvertent use. Identification of items is maintained either on the items, their storage I
i 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 regulrements of this section of the OPD:
I Paraornoh Exceotions/Interotetationn l
8.2.2 7d,79 8.2.3 7a I
8.2 IMPLEMENTATION 8 't.1 Controls are established that provide for the identification and control of materials (including I
consumables), parts and components, (including partially f abricated assemblies).
Responsibility for the identification and control of items is described in Section 1.0, ORGANIZATION, 8.2.2 Items are identified by physically marking the item, its storage area or its container or by maintaining records traceable to the item. The method of identification is such that the quality of the item is not degraded.
8.2.3 ltems are traceable to applicable drawings, specificatlons, 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.
CPC2R19A.WPD
Paga 27 R:v19a Date: Draf t 9.0 CONTROL OF SPECIAL PROCESSES 9.1 REOUIREMENTS Special processes af fecting safety related structures, systems, and components are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special require +
ments.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraornoh Excentionn/Interoretationa 9.2.1 Oc,13e U.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at Consumers Ener0y are those for which full verification or characterization le/ 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 OrDanizational responsibility for implementation of special processes and for quellfication 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 adeqescy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.
9.2.4 Special process personnel qualification is determined by Individuals authorized to administer the pertinent examinations. Certification is based on examination results. Personnel qualification is kept current by performance of the special process (es) and/or reexamination at time intervals specified by applicable codes, specifications, and standards. Unsatisfactory performance or, where applicable, failure to perform within the designated time Intervals requires recertification.
9.2.5 For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and specifications.
9.2.0 Ovalification records are maintained in accordance with Quality Program Description Section 17.
0.2.7 The Nuclear Performance Assessment Department audits / assesses special process activities, including qualification activities to assure they are satisf actorily performed.
CPC2R19A.WPD
.____.______..__._._._.__..._--m_.
PCge 28 Rev 19e Date: Draf t i
10.0 INSPECTION j
10.1 REQUIREMENTS Activities affecting the quality of safety related structures, systems, and components are inspected to verify their conformance with requ'rements, inspections are accompIlshed by independent verification or process monitoring av necessary. Verification points are used as a
necessary to ensure that inspections are accomplahed 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 OPD:
Parmaraoh Excentions/interoratations 4
10.2.2 2p,2q i
10.2.3 2j, 6a 10.2.7 2), 6a 10.2.10 2) i 10.2 IMPLEMENTATION I
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, l
Inservice inspection and doct,mmissioning to verify that items and activities conform to specified requirements. Work authorizing documents (e.g ; procedures, instructions, i
' maintenance work orders) are reviewed in accordance with established criteria to do the j
following as necessary:
s.
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, CPC2R19A.WPD -
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Rav19a Date: Draf t 10.2.3 Training and qualification programs for personnel who perform ihspections, including nondestructive examination, are established, implemented, and documented in accordance with Section 2.0, OUALITY PROGRAM, and plant or offsite procedures. These programs meet the requirements of applicable codes and standards. The Site Vice President / Site General l
Manager is responsible for review and concurrence with plant training and qualification prograrns that are under his direct responsibility.
Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are documented in E&TS procedures.
Training and quellfication programs for Electric Services personnel who perform inspections are documented in Electric Services 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 concurrod with by the organization that performs the inspection planning. They (procedures, etc) provide for the following as appropriate:
Identification of applicable revisions of required Instructions, drawings and specifications, a.
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 eccuracy, e,
identification of personnel 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 walved only by the or-ganization 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.
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.
CPC2R19A.WPD
PCge 30 Rov 190 Date: Draf t 10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:
a.
Qualifications of the independent verifier are equal to or better than the minimum qualifications for persons who can be authorized to perform the task; and b.
The work is within the skills of Consumers Energy personnel and/o'is addressed by Consumers Energy procedures, c.
If work involves breaching a pressure retaining item, the quality of the work can be demonstrated through a functional test.
When a, b, and c are not met, inspections will be carried out by individuals certified in accc,rdance with ANSI N45.2.6.
The verification is performed by individuals other than the person (s) performing or directly supervising the work.
10.2.8 For Independent verification, when acceptance criteria are not met, corrected areas are to be reverifled. Results of independent verification are documented and retained for the purposes of performance trending and analysis.
10.2.9 The independent verifier has the authority to stop work if Inspection criteria are not met.
Resolution of disagreements between the verifier and worker is resolved by plant management.
10.2.10 Contractors may be used as independerit verifiers in accordance with Section 10.2.7 provided:
a.
The work is performed using the Consumers Energy Quality Program and procedures, b.
Individuals are trained and quellfled in accordance with Section 10.2.3.
Otherwise, contractors must be certified to ANSI N45.2.6 to perform inspections.
CPC2R19A.WPD
Page 31 R;v193 Date: Draf t 11.0 TEST CONTROL 11.1 REQUIREMENTS Testing is performed in accordance with estab!!shed programs to demonstrate that safety-related structures, systems, and components will perform satisf actorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification (as applicable), acceptance, pre operational, start up, surveillance, and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions are specified and met. Test results are documented and evaluated.
The following exceptiona/ interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraornoh Excentions/Interoretations 11.2.2 2k,179 l
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:
Qualification tests, as applicable, to verify design adequacy in accordance with Section a.
3.0, DESIGN CONTROL.
b.
Acceptance tests of equipment and components to assure their proper operation prior to delivery or to pre-operational tests, Pre-operational tests to assure proper and safe operation of systems and equipment prior c.
to start up tests or operations (Palisades Only).
l d.
itart up tests, including precritical, criticality, low-power, and power ascension tests, eformed af ter refueling to assure proper and safe operation of systems and equipment alisades Only),
Surveillance tests to assure continuing proper and safe operation of systems and e.
equipment.
f.
Maintenance tests after preventive or corrective maintenance.
11.2.3 Test procedures and instructions include provisions for the following, as applicable:
The requirements and acceptance limits contained in applicable design and procurement a.
documents.
CPC2R19A.WPD
Page 32 RDv19a Date: Draf t b.
Test prerequisites such as calibrated instrumentation, adequate "est equipment, and I
instrumentation including accuracy requirements, completeness of the item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storaga.
1 c.
Instructions for performing the test.
d.
Mandatory inspection hold points for witnests by the appropriate authority.
e.
Acceptance and rejection criteria, f.
Mcu,ods of documenting or recording test data and results.
g.
Assuring that test prerequisites have been met, h.
Verification of completion of modificatic,n activities.
Test procedures and instructions are reviewnd for technical content and quality espects, by the plant engineering organization, or the offsite technical organization, as applicable When acceptance criteria are not met, corrected areas are to be retested.
l l
CPC2R19A.WPO
. Pag) 33 =
R:v 19e Date: Draft 12.0'
- CONTROL OF MEASURING AND TEST EQUIPMENT
-12.1 REQUIREMENTS-Measuring and testing equipment used in activities affecting the quality of safety-related systems, components and structures are properly identif'ad, controlled, calibrated, and adjusted at specified intervals to maintain accuracy within necessary limits.
The following exceptions /into.pretations in Appendix A, Part 2, are relevant to implementation.
ll l
of the requirements of this section of the OPD:
Parmaraoh he=ations/Internratatlana 12.2.3 2o,9c 12.2.4 2o,9c 12.2.5 10c 12.2.8 10b
-12.2
-IMPLEMENTATION 12.2.1-The authority and responsibility of personnel establishing, implementing and assuring effectiveness of calibration programs is described in Section 1.0, ORGANIZATION.
I 12.2.2 Procedures are established for measuring and test equipment utiliz3d 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.
l 12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration source.
12.2.4-Consumers Energy uses a system of labels to be attached to measuring and test equipment to display the next calibration due date. Where labels nnnot 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 en accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an
. accuracy that assures the equipment being calibrated will be within required tolerance and the basis of acceptance is documented arvi 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 basis for this acceptance is documented and is approved by responsible management.
- 12.2.6 Calibrating standards have greater accuracy than standards being calibrated. Calibrating standards with the same accurecy may be used if it can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible management.
CPC2R19A.WPD 2
P:g] 34 R:V 19a Date: Draft 12.2.7 Reference and transfer standards are traceable to nationally recognizod standards; where national standards do not exist, provisions are established to document the basis for calibration.
12.2.8 When measuring and testing oquipment 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 f
validity of the results obtained since the most recent calibration. The results of evaluations j
are documented. Retests or reinspections are performed on suspect items.
l.
i CPC2R19A.WPD
Pago 35 Rev 19a Date: Draft 13.0 HANDLING, STORAGE AND SHIPPING 13.1 REQUIREMENTS Activities with the potential for causing contamination or deterioration that could adversely affect the ability of a safety-related item to perform its intended sefety functions, and activities necessary to prevent undetected or uncorrectable damage are identified and con-trolled. These activities include cleaning, packaging, preserving, handling, shipping, and storing Controls are effected through the use of appropriate procedures and instructions implemented by suitably trained personnel.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Parearaph Excentions/Interoretations 13.2.2 7a, 7c, 7d, 7f, 7g, 7h 13.2 IMPLEMENTATION 13.2.1
-The authority and responsibility of personnelimplementing and assuring the effectiveness of material cleaning, handling, storing, packaging, preserving, and shipping activities is described in Section 1,0, ORGANIZATION.
13.2.2 Procedures are used to control the cleaning, handling, storing, pack ag:ng, preserving, and shipping of materials, ::omponents and systems in accordance with design and procurement requirements. These procedures include, but are not limited to, the following functions:
a.
Cleaning, to assure that required cleanliness levels are 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 minirnite 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.
CPC2R19A.WPD
Page 36 Rev 19a Date: Draft 14,0 INSPf0 TION, TEST AND OPERATING STATUS 14.1 REQUIREMENTS 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.
L The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation i
of the requirements of this section of the OPD:
' Paraoraoh Excentions/Internre.tations 14.1 2r 14.2.5 21 i
14.2 IMPLEMENTATION a
14.2.1 Organizational responsibilit'N are as described in Section 1 A ORGANIZATION.
14.2.2 For modification activities, including item fabrication, installation and test, procurement documents, service contracts, and procedures specify the degree of control required for the indication of 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, etc, are controlled by procedures.
14.2.4 The sequence of inspections, tests and other operations important to safety are controlled by.
procedures. Changes in the approved sequence are subject to the same review and approval as the original, or as specified in administrative procedures if the original 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.
CPC2R19A.WPD
Page 37 R:v19a Date: Draf t 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTG 15.1 REQUIREMENTS 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 The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Paraornoh Excentions/Interoretations l
15.1 21 1
15.2 IMPLEMENTATION l
15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which render tha quality unacceptable or indeterminate, are identified as nonconforming and any further use is controlled. Nonconformances are documented and dispositioned, and notification is made to affected organizations. Personnel authorized to disposition, i
conditionally release, and close cut nonconformances are designated. The authority ard 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 a.
documented administrative controls. Documentation describes the nonconformance, the disposition of the nonconformanco 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, Items that have be6n repaired or reworked are inspected and tested in accordance with c.
the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the originalinspction planning authority, d.
Items that have the disposition of " repair" or "use as is" require documentation lustifying acceptability. The changes are recorded to denote the as-built conditior'.
15.2.2 Dispositions of conditionstly released items are closed out before the items are relied upon to perforni safety related functions.
15.2.3 Prior to the initiation of preoperational testing on an iter"., all nonconformances are corrected or dispositioned and evaluated for impact upon the item or the testing program.
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.
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R:v19e Date: Draft -
16.0 CORRECTIVE ACTION
-16.1 REQUIREMENTS' t
1 Conditions adverse to quality of safety-related structures, systems, components, or activities, j'
such as failures, malfunctions, deficiencies, deviations, defective material, and equipmint and nonconformances are identified promptly and corrected as soon as practical, i
For significant conditions adverse to quality, the cause of the condition is determined and e
l'-
corrective action is taken to preclude repetition. In these cases, the condition, cause and correctivt action taken is documented and reported to appropriate levels of management fr,r i
review and assessment.
16.2 IMPLEMENTATION j'
E 16.2.1' The responsibility and authority for the control of corrective action are described in Ser.tlon.
i 1.0- ORGANIZATION.
L 16.2.2 Controls are established to assure that conditions adverse to quality are identified.snd
[-
documented and that appropriate remedial action is taken.
4 16.2.3 -- For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded. Corrective action includes determining the cause and extent of the
[^
. controls also assure that corrective action is implemented in a timely manner.
condition, e.d taking appropriate action to preclude similar problems in the future. The 4
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P:g3 39 Rev 19a Date: Draft 17.0-QUALITY RECORDS 17.1 REQUIREMENTS 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 ide itifiable and retrievable.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Paraaraoh Excentions/Internretations 17.1 14b 17.2.5 14c 17.2.8 14a,14c
-17.2 IMPLEMENTATION 17.2.1 Responsibilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION.
17.2.2-Documents that furnish evidence of activities affecting quality are generated and controlled in accordance with the procedures that govern those activities. Upon completion, these documents are considered records. These records include:
a.
Results of reviews, inspections,'surveillances, tests, audits, and material analyses b.
Qualification of personnel, procedures, and equipment c.
Operating logs -
d.
Maintenance and modification procedures and related inspection results e.
Reportable occurrences f.
Records required by Appendix E l
- g.
Nonconformance reports h.
Corrective action reports i.
Other documentation such as drawings, specifications, procurement documents, calibration procedures, and reports 17.2.3 Inspection and test records contain the following where applicable:
a.
A description of the type of observation b.
The date and results of the inspection or test
' CPC2R19A.WPD
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4 1
Pags 40 Rev 193
)
Date: Draft i
i c.
Information related to conditiona adverse to quality d.
Inspector or data recorder identification 4
e.
Evidence as to the acceptability of the results q
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 j
fire-resistant file cabinets.
]'
17.2.6 Only authorized personnel may issue corrections or supplements to records.
17.2.7 Traceability between the record and the item or activity to which it applies is provided.
17.2.8 Records are stored in remote, dual facilities to prevent damage, deterioration, or loss due to natural or unnatural causes. Records that can only be stored as originals, such as radiographs and some strip charts are retained in a four-hour flie rated facility.
a d
i r
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1 4
3 l
CPC2R19A.WPD
P;g3 41 R:v19a Date: Draf t 18.0 AUDITS 18.1 REQUIREMENTS 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 implement 9d by suppliers and contractors. Audits are per-formed 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.
The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD:
Parnaraoh Exceotions/Interotetations 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 *arly enough to assure effective quality during design, procurement, manufacturing, construction, installation, inspection, and testing.
18.2.4 Principal contractors are required to audit their suppliers based on performance and on a schedule based on the status and safety 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 audits are supplemented by special audits when significant changes are made in the Quality Program, when it is suspected that quality is in jeopardy or when an independent assessment of program effectiveness is considered necessary.
18.2.0 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.
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P gs 42 R2v 19a Date: Draft 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 l
audited.
18.2.9 Audit data are analyzed by the Nuclear Performance Assessment Department. The resulting 4
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.
4 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. S'nh fol-low-up includes re-audits when necessary. For Vendor Audits, such follow-up shall bt j.
performed by the organization performing the audit.
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Page 43 Rav 19a Date: Draf t QPD MANUAL APPENDIX A. PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Energy Quality Program complies with w aegulatory 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 - (12/70 Draf t) (application limited as described in exceptions 4a and 5a of Appendix A, Part
' 2).
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 -
7Property "ANSI code" (as page type) with input value "ANSI N45.2.4 -</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.33 - (2/78, Rev 2) - Quality Assurance Program Requirements (Operation) -
Endorses ANSI N18.7 - 1976.
8Property "ANSI code" (as page type) with input value "ANSI N18.7 - 1976.</br></br>8" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.37 - (3/16/73) - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.1 - 1973.
9.
Regulatory Guide 1.38 - (5/77, Rev 2) - Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of items for water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.2 - 1972.
- 10. Regulatory Guide 1.39 - (9/77, Rev 2) - Housekeeping Requirements for water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.
11.
Regulatory Guide 1,58-(9/80, Rev 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.
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P:gs 44 Riv 19a Date: Draf t
- 14. Regulatory Guide 1.88 -(10/76, Rev 2) Collection, Storage, and Maintenance of Nuclear Power Plan, 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.
I
- 16. Regulatory Guide 1.116 - (5/77) - Quality Assurance Requirements for Installation, inspection, and Testing of Mechanical Equipment and Systems Endorses ANSI N45.2.8 1975.
3
- 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 prog am Audit Personnel for Nuclear Power PL its - Endorses N45.2.25 -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 l
January 1,1979, Sections ill G., Ill J. and ill O. (Not applicable to Big Rock Point)
- 22. ANSI /ANS 3.1 1987, Selection, Qualification, and Training of Personnel for Nuclear Power Plants (application limited as described in Appendix C of this document).
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Pago 45 RIv'9a Date: Draft QPD MANUAL APPENDIX A. PART 2 CONSUMERS ENERGY EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES 1.
Ganeral Reautrement Certain Regulatory Guides invoka or imply Regulatory Guides and standards in addition to the
+
standard each primarily endorses.
J Certain ANSI Standards invoke or imply additional standards.
Excention/Interoretation i '
The Consumers Energy commitment refers to the Ragulatory Guides and ANSI Standards specifically identified in Appendix A, Part 1. Additional Regulatory Guides, ANSI Standards, and similar documents implied or referenced in those specifically identified are not part of this commitment, imposition of these Regulatory Guides on Consumers Energy suppliers and subtler 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 Energy 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.
81tLZ, Sec 3.4.2 Recairement "The Plant Manager shall have overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."
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Excention/interoretation -
Since Consumers Energy 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.
t' instead, responsibilities are as designated within the Quality Program Description.
l 2b.
N18.7. Sec 4.3.1 Requirement
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" Personnel assigned responsibility for_ independent reviews shall be specified in both number and technical disciplines and shall ccliectively have the experience and competence required to review 4
j problems in the following areas:..."
j Excention/interoretation 4
L The Nuclear Performance Assessment Department will not have members specified by number or i
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 3 -
Department will function as described in Appendix C, independent Safety Review, and will acqu re the services of personnel having such exponence and competence as necessary.
1 2c.
N18.7. Sec 4.3.4 1
Raouirement l
"The following subjects shall be reviewed by the independent review body;"
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Excention/interoratation
{
Subjects requiring review will be as specified in Appendix C, independent Safety Review.
2d.
RI.lLZ, Sec 4.3.4(3)
Raouirement Changes in the Technical Specifications or license amendments relating to nuclear safety are to be L
reviewed by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.
c
' Ercention/Interoratation The Nuclear Performance Assessmeat Department will not review Technical Specification Changes af ter NRC approval prior to implementation. The basis for this position is that all Technical' Specification changes are reviewed prior to submittet to the NRC.
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Date: Draf t 2e, N18.7. Sec 4.5 -
Reauirement Written reports of audits specified in ANSI N18.7 shall be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited.
Excention/Interoretation The Nuclear Performance Assessment Department shall review or arrange for reviews of those a
i audits over which it has cognizance, in accordance with Appendix C, Independent Safety Review.
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.
t[tlL2, Sec 4.5
- Reauirement Periodic review of the audit program shall be performed by the indepenovnt review body or 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.
s Excention/Interoretation Audits of nuclear safety related facility activities are performed under the cognizance of the l
Nuclear Performance Assessment Department as described in Appendix C, independent Safety Review.
2g.
N18.7. Sec 5.2.1 Reauirement "The responsibilities and authorities of the plant operating personnel shall be delineated."
i Excentionlinteroretation On-site personnel not directly associated with operating activales, as defined in ANSI N18.7, Section 2.2, are not considered to be operating personnel.
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Paga 48 R;v19a Date: Draf t 2h.
N18.7. Sec 5.2.2 Raouirement
" Temporary changes, which clearly do not change the intent of the approved procedure, shall as a i
minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators license on the unit affected."
Excention/Interoretation Consumers Energy considers that this requirement applies only to procedures identified in Plant Technical Specifications and to Security and Emergency Plans implementing procedures.
Temporary changes to these procedures may be made provided:
a.
The intent of the original procedure is not altered; b.
The change is approved by two members (or designated alternates) of the PRC/SRC, at least one of whom holds a Senior Reactor Operator License (Palisades) or is a Certified Fuel Handler (Big Rock Point); and The change is documented, subsequently reviewed by the Palisades PRC within 30 days of c.
issuance, or by the Big Rock Point SRC at its next regular meeting, and approved by an
_ appropriate
- senior department manager predesignated by the Site Vice President / Site General Manager.
Datermination of the appropriate senior department manager is based on the activities addressed in the specific procedure, and will be predesignated in writing by the Palisades l
Plant Site Vice President / Big Rock Point Site General Manager.
21.
N18.7. Sec 5.2.6 Raouirement "In cases where required documentary evidence is not available, the associated equipment or
- materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions."
Excention/Interoretation Consumers Energy initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which is required to verify equipment acceptability. This action includes a technical evaluation of the equipment's operability status.
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Pago.49 =
R0v.19a Date: Draft,
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E1LZ, Sec 5.2.7 Banuiremet The following standards contain useful guidance concerning design and construction-related
- activities associated with rnodifications 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 Star.dard installation, inspection.
. and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power Generation Station, N45.2.41972 (IEEE 3361972) [61; American National Standard Supplementary Quality Assurance Requirements for Installation, inspection end Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants,-
N45.2.51974 [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, N45.2.81975 [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 Protective Coating Applied to Nuclear Facilities N101.41972 (10). Considerable care is required in assessing which operational phase activities are comparable in nature and extent to activities normally associated with design and construction.
Exceotion/ Clarification Work that is within the skills of Consumers Energy personnel and is covered by Consumers Energy procedures may be inspected by independent verifiers qualified 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 Recuirement "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." -
ggggg+lon/Internratation Separate master schedules may exist for different programs such as ISI, Pump and Valve Testing, and Technical Specification Surveillance Testing.
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Page 50 Riv 19a Date: Draf t 21.
N18.7. Sec 5.2.13.1 Reaulrement "To the extent necessary, procurement documents shall require suppliers to provide a qurJity assurance program consistent with the pertinent requirements of ANSI N45.2 - 1971."
Exceotion/Interoretation To the extent necessary, procurement doc anent6 require that the supplier have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.
2m. N18.7. Soc 5.2.13.2 Reaulrement ANSI N18.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall 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 wh"e any missing documents are being obtained, but precludes dependence on the item for safety purposes.
2n.
N18.7. Sec 5.2.15 Reouirement Plant procedures shall be reviewed by an individual know!adgeable in the a ca affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable.
Exceotion/Interoretation Consumers Power has in place programmatic procedura preparation, review and usage controls that ensure procedures are technically and administratively correct and make a biennial review program unnecessarily duplicative. These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusualincidents occur, when plant modifications are made, and when significant deficiencies are ider.tified, in addition, procedures may be reviewed because industry experience reviews or self-assessments identify deficiencies or opportunity for improvement. Revisions are made as necesssry.
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 would be dictated by a particular event are reviewed at least every two years and revised as appropriate.
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Paga 51 R;v 192 Date: Draf t i
in addition, procedures that have not been used or reviewed for two years are reviewed prior to
- use to determine if changes are necessary.or desirable.
An assessment performed at least every two years includes examination of selected plant procedures to determine procedure acceptability and verify that the procedure review and revision l
controls are effectively implemented. Identified deficiencies are corrected in accordance with Section 16.0 of this QPD.
20.
N18.7. Sec 5.2.16 Reaulrament Records shall be made and equipment suitably marked to indicate calibration status.
Excention/Interoretation See 1:em 9c.
2p.
N18.7. Sec 5.2.17 Raoulrement For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and persennel performing such inspections) to that associated with construction phase activities (see also Section 5.2.7)
Excention/Intororetation Maintenance and modification activities which are within the skills of Consumers Energy maintenance personnel and are carried out using Consumers Energy procedures may be inspected
.l by independent verifiers qualified 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 mandatcry inspection hold points are required, the specific hold points shall be indicated in appropriate documents. Information concerning inspection shall be obtained from the related 61 sign drawings, specifications, and/or other controlled documents.
Excention/Interotetation Consumers Energy uses the terminology " independent verification points" as equivalent to hold points.
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Pag 3 52 Rev 19a Date: Draft 2r.
N18.7. Sec 5.3.5(3)
Recuirement instructions shall be included, or referer:ced (in maintenance procedures), for returning the equipment to its normal operating status.
Excention/Interoretation At Consumers Energy, equipment is returned to its normal operating status, i.e., declared operable, by licensed Operations Department personnel, not Maintenance personnel. Operations personnel verify an'J document equipment operability through second level line-up verification or appropriate functional testing.
2s.
N18.7. Sec 5.3.5(4) 1 Raouirement This section requires tt.st 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.
Excention/Interoretation Such documents are reviewed by appropriately qualified personnel prior to use to ensure that, when used as instructions, they provide proper and adequate information to ensure the required quality of work. Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures.
3a.
RG 1.33. Sec C4a Raouirement 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, E cention/In'.eroretation Performance trends are reviewed by the Nuclear Performance Assessment Specialists 1 addition, the corrective action system is audited in accordance with Appendix D, Audit Frequencie:
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Pag) 53 Rev 19a Date: Draft
. 3b.-
RG 1.33. Sec C4b Reaultament EThe conformance of facility operations to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
Eveantionllntaroretatior3
. Consistent with guidance presented in NRC letters dated March 29,1983 (RLSpessard to JMTaylor) and January 30,1984 (JGPartlow to RLSpessard), Consumers Energy interprets the commitment to audit Technical Specification / license conditions contained in 18.2.2 of this OPD, j
and in Appendix D, Audit Frequencies, as follows:
1 Consumers Energy 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 lino 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 abovo elements may be reduced depending on Technical Specification compliance history.
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ANS 3.1. General Excention/Internretation 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 (8/80)/ ANSI 45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.
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Page 54 Rev 19e Date: Draft 52.~
BG_LS, C.3.1, General J-Excention/internretation
~ The commitment to Regulatory Guide 1.8 (9/80, 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 (8/80)/ ANSI N45.2.231978. Other personnel are trained and qualified as designated in plant f
Technical Specifications.~
l Sb.
RG 1.8, C1.2.2 Reautrement 4
jWhen an individual is hired to temporarily function as a plant employee, such as for contracted -
.- services, evidence of previous education, experiencei 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 Consumers Energy understands tha this requirement applies both to Consumers Energy 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.
Consumers Energy employees so assigned possess the required qualifications as a prerequisite to the assignment and the review is waived. The qualifications of contract personnel are reviewed and arrangements made for any necessary training. Temporarily assigned personnel requiring unescorted access receive the site general orientation as embodied in General Employee Training.
6L _ N45.2.1. Sec 2.4 Reauirement E
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, l-Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants.
Excention/Internretation
- Consumers Energy certifies its inspectors in accordance with Paragraph 10.2.7 of CPC 2A unless the work is comparable in' nature and extent to original construction (See item 2J).
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Pago 55 Rov 19e Date: Draf t 6b.
N45.2.1. Sec 3.1 Raoulrament N45.2.1 establishes criteria for classifying items into " clean.1ess levels," and requires that items be so classified.
Excention/Interoretation Instead of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activities is addressed on a case-by-case basis.
Cleanness is maintained consistent with the work being performed, so as to prevent the Introduction of foreign material. As a minimum, cleanness inspections are performed prior to avstem closure. Such inspections are documented.
Sc.
N45.2.1. Sec 5 Raoulrament
" 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."
Excentienflnteroretation Consumers Energy sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection, i
7a.
N45.2.2. General Raouirement N45.2.2 establishes requirements and criteria for classifying safety-related items into protection levels.
Excention/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.
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7b.
N45.2.2. Sec 2.4 Raoulrament
"...Offsite inspection, examination or testing shall be audited and monitored by personnel who are quellfled in accordance with N45.2.6."
Excention/Interoretation Offsite inspection, examination, or testing activities are audited or inspected by persons qualified and certified in accordance with ANSI N45.2.23-1978, as endorsed by Reg Guide 1.146, or by personnel meeting the requirements of 10.2.7, respectively. Monitoring activities not involving audit or inspection may be conducted by persons trained and qualified to effectively carry out such tasks, but not necessarily certified to alther ANSI N45.2.23, N45.2.6 or Paragraph 10.2.7.
7c.
N45.2.2. Sec 3.4.1 and Appendix A,3.4.1(4) and (5)
Raoulrament
"(4)...However, preservatives for inaccessible inside surfaces containing reactor coolant water -
shall be indicated to facilitate touch up.
(5) The name of the preservative used shall be the water flushable type."
Excention/Interoretation Based on comparison of these statements to ANSl/ASME NOA-21983, Consumers Energy 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 f acilitate touch-up."
7d,. N45.2.2, Sec 3.9 and Appendix A 3.9 Raouirement "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 shipr d to construction projects. Full compliance is not always necessary in the case of iter, f.ippd to operating plants and may, in some cases, increase the probability of damage to the l'.m. The requirements are implemented to the extent necessary to assure traceability and intogrity of the item.
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P go 57 R:v19a Date: Draft 7e.
N45.2.2. Sec 5.2.2 Reautrement "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 environmental requiremen's 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 Reauirement "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall not be permitted."
Excention/Interoretation Packaged food for emergency or extended overtime use may be stored in material stock rooms.
The packaging assures that materials are not contaminated. Food will not be "used" in these areas.
7g.
N45.2.2. Sec 6.3.4 Reoulrement "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."
Exceotion/Interoretation See N45.2.2, Section 3.9 (Exception 7d,).
7h.
N45.2.2, Sec 6.4.1 Reauirement
" 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."
Exceotionlinteroretation The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule. Instead, the inspections and examinations are performed and documented in accordance with material storage procedures which identify the characteristics to be inspected and include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.
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P:ge 58 R:v19a Date: Draft Ba, N45.2.3. Sec 2.1 -
Reautrement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.
Excention/interoretation Instead of the five level zone designation system referenced in ANSI N45.2.3, Consumers Energy 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 instrue:lons 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, consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3.
92Property "ANSI code" (as page type) with input value "ANSI N45.2.3.</br></br>92" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
N45.2.4. Sec 2.2 Reauirement Section 2.2 establishes prerequisites which must be met before the installation, inspection, and testing of instrumentation and electrical equipment may proceed. These prerequisites include personnel qualification, control of design, conforming and protected materials, and availability of specified documents.
Excention/Interoretation 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.
9b.
N45.2.4. Sec 2.2(5)
Raouirement Section 2.2(5) of ANSI N45.2.4 lists documents which are to be available at the construction site.
Exception / Clarification All of the documents listed are not necessarCy required at the plant site for installation and testing. Consumers Energy astures that they are available to the site as necessary.
CPC2R10A.WPD
-- ~..-
~,.-. - _.... -. -.- -. -. - _. - _. _
~
w Page 59 R;v19e-Date: Draft i
1:
-- Sc.
R4L24, Sec 6.2.1 Requirement J
" Items.equiring calibration shall be tagged or labeled on completion, indicating date of calibration
- and identity of person that performed the calibration."
z Excention/Internretation
. 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 Raouirement
- 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 ll1 capability."
Exception /Internratation 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 Energy, persons having engineering managerial responsibility for inspections and tests' may.be certified to Level Ill, or may meet other
- qualification criteria established for the position, including, but not limited to, nuclear power and management experience. For major modifications involving significant concrete or structural steel work, the services of a p operly qualified Level 111 individual will be obtained !n 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, all items inspected with that equipment since the last previous calibration shall-1be considered unacceptable until an evaluation has been made by the responsible authority and appropriate action taken."
l Excention/Internratation i
Consumers Energy uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section
' 2.5 2. The N18.7 requirements are more applicable to an operating plant.
CPC2R19A.WPD
Page 60 R:v 19]
Date: Draf t l
10c. N45.2.5. Sec 5.4 ReaulremtD1
'Hond torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more of ten If deemed necessary, impect torque wrenches used for int.pection must be calibrated at least twice daily."
l l
ExcmdoDljnteroretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16. Calibration Intervals are based on use and calibration history rather than as per N45.2.5 lie. IL4NLfL Sec 1.2 Reauhement "The requirements of this standard apply to personnel who pr;tform inspections, examinations, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and start up testing, and during operational phases of nucteor power plants."
i Exceotion/Interotetatiqo l
See Exception /into pretation 2J for those inspectors who must be certified to this standard.
Others are qualifir J to Paragraph 10.2.7 of CPC 2A.
Qualification of niant personnel who are involved with testing associated with plant operation is I
provided in spe',:fic plant specifications, in addition, personnel participating in inspectiori or testing who take data or make observathns, 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 treined to the extent necessary to perform the assigned function.
12a. RG 1.58. Sec C.1 Reaulrement
- However, for qualification of p6rsonnel (1) who approve preoperational, start up and operational test procedures and test results a.id (2) who diiect or supervise the conduct of indivHual 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 -
1978Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.."
Excention!!ntemretation Consumers Energy endorses this position, as also stated in lla, above, except that offsite support organizations involved in testing may apply ANSI N45.2.6. Some of these departments have already developed their qualification programs based on ANSI N45,2.6, and provide services throughout the operations phase of Consumers Energy Nuclear Plants.
CPC2R19A.WPD m
Pag) 61 R:V19a Date: Draf t 12b. RG 1.58, Sec C.6 l
Raoulroment "In addition, the 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."
Excention/interoretation While a Lt, vel lit individual should be capable of reviewing and approving Inspection, examination and testing procedures and of evaluating the adquacy of such procedures to accomplish the inspection, ext Wation and test objectives, this is not construed by Consumers Energy as requiring personnel who review, approve or evaluate such procedures to be certifled as Level ill personnel.
12.c. RG 1.58. Sec C.6 Reautrement "Since only one set of recommendations is provided for the educat!on and experience of personnel, a commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be followed."
Excention/Interoretetlon The education and experlance recommendations given in ANSI N46.2.6, Section 3.6 will be treated be such, since our qualification and certification program is based upon those recomme dations, and more significantly, upon satisf actory completion of capability testing prior to certification. It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.
12.d RG 1.58, Sec C.10 Reaulrrment
'Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experience should result in documented evidence (i.e., procedure and recoid of written test) demonutrating that the individualindeed does have comparable or equivalent competence to that which would be ga!ned from having the required education and experiene:e.'
EKcention/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 at. documentation of oral tests and on-the-job pvrformance demonstrations.
CPC2R19A.WPD
Page 62 Rev 19a Date: Draf t 13a. N45.2.8. Sec 2.7 Raouirement Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.0, Excentlon/Interoretation See Exception / Interpretation 2J,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 criteria of plant Technical Specifications.
13b, N45.2.8. Sec 2.9 fhtoulrement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel and procedure quellfication, control of design, material selection and fabrication, and availability of specified documents.
Excention/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.
13c, N45.2.8. Sec 2.9e Reauirement Section 2.9s of N45.2.8 lists documents relating to the specific stage of installation activity which are to be available at the construction nite.
Excention/Interoretation All of the documents listed are not necessarily required al the plant site for installation and testing. Consumers Energy assures that they are available 12 the site as necessary, 13d N45.2.8. Sec 2.9e Reautrement 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. Hewever, the system is not declared operable until such changes are documented and approved.
CPC2R19A.WPD
Page 63 Rev 19a Date: Draf t 13e. N45.2.8. Sec 4.5.1 Raoulrement
' Installed systems and compJnents shall be cleaned, flushed, and conditioned according to the requirements of ANSI N45.2.1 Special atter'tlon shall be given tu the following requirements:...."
(Requirements are given for chemical co4ditioning, flushing and process controls.)
Excentlon/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 Raoulrement Records shall not be stored loosely. They shall be firmly attached in binders or placed in fo'ders or envelopes for storage on shelving in containers. Steel cabinets are preferred.
Exception /Interoretation Records are suitably stored in steel file esbinets or on shelving in containers. Methods other than binders, folders or envelopes (for exampi, dividers or electronic media) may be used to organize the records for storage.
14b. N45.2.9, Sec 6.2 Raouirement "A list shall bo maintained designating those personnel who shall have access to the files."
Excention/Interoretation Rules are established governing access to and control of files as provided for in ANSI N45.2.0, 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 Beauirement
- Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974. NFPA No 232 1975.. ilso 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...."
CPC2R19A.WPD
Pago 64 Rav 19.
Date: Draf t Evenotion/interoratation Consumers Energy adheres to ANSI N45.2.91974, Subdivision 5.8 for the f acility 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 2321975 for Class 1 records (usually NFPA Class C, I hour or Ut. Class 350).
15a. RG 1.84, C2 i
Raoultament i
"Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design...."
Exceotion/intaroratation Consumers Energy follows the requirements of ANSI N45.2.111974, Section 6.1, and the guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure insteed of Individually approved in advance in each case (see Section 3.2.9, herein). This approach is necessary to allow small organizational units (having limited numbers of technically qualified staf f, 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(1)
Raouiramant This section requires that for operational phase activities, RG 1.33 " Quality Assurance Program Requirements (Operations)* are to be followed. One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six
- months, f,geotion/Interoratation See item 3a for the exception to this requirement.
16b. fEi.1dM, Sec C3a(2)
Raoulrement Applicable elements of an organization's quality assurance program (for " design and construction phase activities") should be audited at least annually a /et least once within the life of the activity, whichsver is shorter.
Excention/intaroretation Since most modifications are straightforward, they are not audited individually, instead, selected controls over modifications are audited periodically.
CPC2R19A.WPD
PCge 65 Rev 19e Date: Draft 16c. RG 1.144, Sec C3b(1)
Raoulrament This section identifies procurement contracts which are exempted from being audited.
Encantion/intaroratation in addition to the exemptions of RG 1.144, Consumers Energy considers that Authorized inspection Agencies, National Institute of Standards and Technology or other State and Federal Agencies which may provide services to Consumers Energy are not regulred to be audited.
16d. RG 1.144. Sec C.3.b(2), second paragraph Raoulrament A documented evaluation of the supplier should be performed annually. Where applicable, this evaluation should take into account (1) review of supplier. furnished documents such as certificates of conformance, non-conformance notices, and corrective actions, (2) results of previous source verifications, audits and receiving inspections, (3) operating experience of identical or similar products furnished by the same supplier, and (4) results of audits from other sources (e.g., customer, ASME or NRC Audits).
Excention/Interotetation Consumers Energy will review the information described in the second paragraph of section C.3.b(2) of Regulatory Guide 1.144, Revision 1,1980, as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entitles as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.
17a. N45.2.13. Sec 3.2.2 Raouirement N45.2.13 requires that technical requirements be specified in procurement documents by reference to technical requirement documents. Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.11.
Excention/interoratation For replacement parts and materials. Consumers Energy follows ANSI N18,7, Section 5.2.13, Subitem 1, which states: "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."
CPC2R19A.WPD
Page 66 Rev 19a Date: 'Jraf t 17b. N45.2.13. Sec 3.2.3 Raoulrament
- Procurement documents shall require that the supplier have a documented quality assurance
(
program that imple.nonts portions all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards."
Excention/Interotetation Refer to item 21.
17c. N45.2.13. Sec 3.3(a)
RanuiremtD1 Reviews of procurement documents shall be performed prior to release for bid and contract award.
Evenotion/interoratation Documents may be released for bid or contract award before completing the necessary reviews.
However, these reviews are completed before the item or service la put into service or before work has progressed beyond the point where it would be Impractical to reverse the action taken.
17d. N45.2.13. Sec 3.3(b)
Raoulrament
" 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."
Excaction/interoratation 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 1 through 6.) The timing of reviews will be the same as for review of the original procurement document.
17e. N45.2.13. Sec 7.5 Raoulrament
" Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2,8 as applicable."
Excentionhntaroratation Consumers Energy qualifies audit personnel according to N45.2.23. Thus, pen.onnel performing source verification audito 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 accordance with CPC2F;19A.WPD
Pag 3 67 R:V19s Date: Draft 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 Reauirement "Where required by code, regulation or contract requirernent, 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/Interoretation Refer to item 2m.
17g. N45.2.13. Sec 10.3.4 (as modified by RG 1.123, C6e)
Raoulrement
" Post installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."
4 ExceoC n/Interoretation 3
In exercising its ultimate responsibility for its quality program, Consumers Energy establishes post-installation test requirements, giving due consideration to supplier recommendations.
18a. ANSI N45.2.231923, Section 2.3.4 Reaulrement The prospective lead auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality assurance audit within the year prior to his qualification.
Exceotion/Interoretation The prosocctive lead auditor shall demonstrate his ability to properly implement the audit process defined by this Standard and Consumers Energy program / procedure, to effectively lead an audit team, and to of factively organize and report results, including participation in at least one nuclear quality assurance audit within the year preceding date of certification.
19a. RG 1.28, General Reauirement RG 1.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety related, and which are not.)
CPC2R1SA.WPD
Page 68 Rov 19a Date: Draf t Exeantion/Internratatla
- RG 1.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety related determinations. Regulatory Guide 1.29, subject to Exception / interpretation 21a, is used to determine what systems and equipment are included in the Quality Program.
20a. Branch Technical Poaltion ASBD.5.1 and 10 CFR 60 Annandir R. Sections 111 G._111 J. and ill 0..
General Excention/Internratation Fire protection measures, equipment and the Individual plant Fire Protection Plans are in compliance with the NRC $afety Evaluation Reports and the required sections of 10 CFR 50 Appeadix R except for the specif!c exemptions approved by the NRC.
21a. RG 1.29. Sec C, Regulatory Position Raoulrament The Regulatory Position states that the identified structures, systems, and cc,mponents are to be designated Selsmic Category 1 and should be designed to withstand the SSE.
Fwcantlon/Interoratation Both Consumers Energy nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on criteria ave:lable prior to Revision 3 of this Regulatory Guide being issued.
l The specific design criteria and seismic designations are reflected in the UFHSR and UFSAR, 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 Consumers Energy primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 21b, below).
21b. RG 1.29, General Ranulrament Apply pertinent Quality Assurance requinim 3nts of 10 CFR 50, Appendix B.
4 Excention/interoratation
. The pertinent quality requirements for these systems, structures and components will be determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 60 applies.
CPC2R19A.WPD
Page 69 l
R:V193 Date: Draft j
-22.
ANSilANS 3.1 1987 l
Excention/intatoratation
[
The commitment to ANSl/ANS 3.1 1987 is limited to requirements that apply to persons performing the independent safety review function as specified in Appendix C to this OPD.
t
)
J 1
CPC2R19A.WPD 1
Page 70 Rev 19a Date: Draf t QPD MANUAL APPENDlX B PLANT REVIEW COMMITTEE (PRrl (PAllSADES)
SAFETY REVIEW COMMITTEE ISRC) (BIG ROCK POINTl i
B1.
FUNCTION The Plant Review Committee (PRC)/ Safety Review Committee (SRC) shall function to advise the Site Vice President / Site General Manager on all matters related to nuclear safety.
2 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 N18.1 1971. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in t
administrative procedures by the Site Vice President.
I The Big Rock Point SRC is composed of a Chairman and a minimum of four members from the Big Rock Point staff. The SRC members shall meet or exceed the mlnlmum qisalifications described in Sections 4.2 and 4.4 of ANSI N18.1 1971 for comparable positions. The members shall be l
designated in administrativo procedures by the Site General Manager. The Site General Manager shall also designate an Alternate Chairman in writing.
I B3.
ALTERNATES
_l Alternate members of the PRC/SRC shall be appointed in writing by the PRC/SRC Chairman to i
serve on a temporary basis. No more than two alternates shall participate as voting members at any one time in Palisades PRC activities, nor more than one alternate in Big Rock Point SRC activities.
B4.
MEETING FREQUENCY l
The Palisades PRC shall meet at least once per calender month with special meetings as required.
The Big Rock Point SRC shall meet at least monthly while fuelis stored in the spent fuel pool during the pre-dismantlement and dismantlement phases. During tne safe storage phase (no fuel in the spent fuel pool), SRC shall meet at least quarterly.
B5.
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 SRC shall consist of the Chairman or alternate Chairman and two members or alternates.
B6.
BESPONSIBILITIES l
The PRC/SRC shall be responsible for nuclear safety review of:
a.
All procedures and programs specified by the Technical Specifications and changes thereto, j
and any other procedures or changes thereto as determined by the Site Vice President / Site CPC2R19A.WPD s
PCgo 71 Rev 19a Date: Draf t General 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 f act nuclear safety, b.
All proposed changes to Operating License and Technical Specifications, Results of investigations of all violations of thu Technlcal Specifications. (A report shall be c.
prepared covering evaluation and recommendations to prevent recurrence and be forwarded to the Vice President NFHO and to the Manager, Nuclear Forformance Assessment 1
Department (NPAD)).
i d.
Plant operations to detect potentlat safety hazards.
Reports of special reviews and investigations as requested by the Site Vice President / Site l
e.
General Manager or NPAD.
f.
Site Emerpency Plan and implementing procedures.
g.
All reportable events as defined in 10 CFR 50.72 and 50.73.
I h.
Allitems identified under B9.3 below as significant to nuclear safety (Palisades oni ).
/
l.
Mnnthly reports from Safety / Design Review (Palisades only).
l 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 forwuding of these reports to the Site l
General Manager and to the Manager, Nuclear Performance Assessment Department (Big Rock Point only).
PRC/SRC review of the above items may be performed by routing, subject to the regul'ements of B7. below. The Palisades PRC may delegate review of items a. and f. to Safety / Design Review staff, as described in B9. below.
B7.
AUTHORITY The PRC/SRC shalt:
l Recommend in writing to the Site Vice President / Site General Manager approval or l
a.
disapproval of items considered under B6.a. through J. above, b.
Render determinations in writing with regard to whether or not each item considered under BB.a. b, c, f (Palisades only) and h above constitutes an unreviewed safety question, 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 Senior Vice President - Nuclear Fossil, c.
and Hydro Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC/SRC and the Site Vice President / Site General Manager; however, the Site Vice President / Site General Manager shall have responsibility for the resolution of such disagreements.
CPC2R19A.WPD
Page 72 Rev 19a Date: Draf t l
The PRC/SRC Chairman may recommend to the Site Vice President / Site General Manager approval of those items identified in B6. above based on a routing review provided the following conditions are met:
l For Palisadas:
(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.
For Bio Rock Polnt:
(1) at least three SRC members, including the Chairman and not more than one alternate, 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 SRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers.
l
. The item shall be reviewed at a PRC/SRC meeting in the event that: (1) Comments are not resolved; or (2) the Site Vice President / Site General Manager overrides the recommendations of the PRC/SRC; 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 l
The PRC/SRC shall maintain written minutes of each PRC/SRC meeting and shall provide copies for independent Safety Review.
B9, TECHNICAL SUPPORT FOR PALISADES PE The Safety / Design Review organization shall function to examine proposed changes in design or opera' ion and such other matters as the Palisades PRC may assiga to identify issues significant to nuclear safety and recommend nuclear safety improvements.
89.1 The Safety / Design staff responsible for the review function shall be an experienced technical staff meeting the qualifications of Technical Specifications.
B9.2 The Safety / Design Review staff may provide nuclear safety review as delegated by Palisades PRC for:
a.
Procedures, programs and changes thereto identified in the Technical Specnications and an/
additional procedures and changes thereto identified by the Site Vice President as significant to nuclear safety, b.
All proposed tests or experiments.
CPC2R19A.WPD
l Pcge 73 Rev 19a Date: Draf t All proposed changes or modifications to plant systems or equipment, c.
d.
The Site Emergency Plan and implementing procedures.
B9.3 The Safety / Design Review staff shall determine those issues significant to nuclear safety which require revit a by the Palisades Plant Review Committee from items considered under B9.2a.
through d. above. For those items not ieferred to PRC, Safety / Design Review shall recommend in writing to plant managemont approval or disapproval of items considered under B9.2.
89.4 Reports of Safety / Design Review activities pursuant to B9 shall be submitted rnonthly to PRC.
CPC2R19A.WPD
Pa9e 74 l
R:V19e-Date: Draft QPD MANUAL APPENDIX C INDEPENDENT RAFETY REVIEW The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD:
Annandix C Fweaationalinternratatlann 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,end control i
g.
Radiological safety h.
Mechanica' and electrical engineering 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 NFHO, 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 l'suffn.!ent expertise is not available within the ISRG to review particular issues, the ISRG shall have the t.uthority to utilize consultants or other qualified organizations for expert advice.
C/. RESPONSIBillYt%
CPC2R19A.WPD
P:g] 75 Rev 10a Date: Draf t C4.1 REVIEW The ISRG shall review:
)
The safety evaluations for: 1) changes to procedures, equipment or systems, and 2) tests or 3.
experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety question, b.
Proposed chnnges 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 in 10 c.
CFR 50.59.
d.
Proposed changes to Technical Specifications of the Operating Licensc.
Violations of codes, regulations, orders, Technicr8 Specifications, license requirements, or of e.
internal procedures or instructions having nuclear Jety significance, f.
Significant operating abnormall'ies or deviations from normal and expected performance of unit equipment that affects nuclear safety.
l g.
All reportable eventw 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 1.
Reports and meeting minutes of the Plant Review Committee / Safety Review Committee.
l j.
Fire Protection Program and implementing Procedure Changes (Palisades only).
k.
Reports cf audits performed as specified in Appendix D.
ISRG review of the subjects in C4 above shall be porformed 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.
C5 AUTHORITY The ISRG shall report to and advise the Vice-President, NFHO, of significant findings associated with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.
C6 BEL;QSs Records of ISRG activities shall be maintained. Reports shall be prepared and distributed as indicated below:
CPC2R19A.WPD f
P:g3 76 Rev 19a Date: Draf t The results of reviews performed pursuan'. to C4 above shall be reported to t' e Vice-a.
President, NFHO, at least monthly, b.
A report assessing each plant's overall nuclear saft./ performance shall be provided to senior j
Consumers Energy management annually.
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CPC2H19A.WPD y'
Pag 3 77 R:v19a Date: Draf t I
QPD MANUAL APPENDIX D AUDIT FREQUENCIES j
D1.
AUDITS Audits of operational nuclear safety related activities are performed by the NPAD staff under the cognizance of Nuclear Performance Specialists. These audits encompass:
The conformance of plant operation to provisions contained within the Technical a.
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.
The performance of activities required by the Quality Program Desenption for Operational c.
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 Plan) at e.
least once per 12 months, f.
Any other area of plant operation considered appropriate by NPAD or the Vice President -
NFHO.
g.
The 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.
1.
An inspection and audit of the fire protection and loss prevention program to be 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 once per 12 months.
k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
I.
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, NPAD, and Management positions responsible for the areas audited within thirty (30) days after completion of the audit.
CPC2R19A.WPD s
~
7 Pag) 78 R:v19a Date: Draf t QPD MANUAL APPENDIX E RECORD RETEPJ1QH l
E1, in addition to the applicable record retention requirements of Title 10, Code of Federal 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:
a.
Records and logs of facility operation covering time interval at each power level, b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principalitems of equipment related to nuclear safety.
c.
All reporteble events as defined in 10 CFR 50.72 and 50.73.
d.
Records of surveltlance at.!ivities, inspections and calibrations required by Plant Technical Specifications.
Records of changes made to the procedures required by Plant Technical Specifications.
o.
f.
Records of radioactive shipments.
g.
Records of sealed source leak tests and results.
h.
Records of annual physicalinventory of all source material of record.
l E3, The following records shall be retained for the duration of the Facility 10 CFR 50 License:
a.
Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Pallsades Updated Final Safety Analysis Report or Big Rock Point Updated Final Hazards Summary Report, b.
Records of new and irradiated fuel Inventory, fuel transfers and assembly burnup histories, c.
Records of quarterly radiation exposure for allindividuals entering 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 limited e.
number of transients or cycles.
f.
Records of inservice inspections performed pursuant to Plant Technical Specifications, g.
Records of Quality Assurance activities required by the Quality Program Description.
h.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
l l.
Records of meetings of the PRC/SRC and reviews performed by NPAD according to Appendix B and C.
CPC2R19A.WPD V
?
P:g3 79 R:;v 19a Date: Draft '
j.
Records of monthly facility radiation and contamination surveys.
k.
Records of secondary water sampling and quality (Palisades only).
1.
Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specifications. This shallinclude the date at which the service lifs commences and associated installation and maintenance records (Palisades only).
1 m.
Records for environmental quslifications which are covered under the provisions of 10 CFR 50.49 (Big Rock Point only).
n.
Records of training and qualifications for members of the plant staff.
i c.
Records of reactor tests and experiments.
[
t p.
- Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION
. MANUAL and the PROCESS CONTROL PROGRAM (Palisades only).
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i CPC2R19A.WPD
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