View source for JSP-329-93, Forwards Proposed Rev 24 to QA Manual, Including Changes to Insp planning,in-line Review of Procurement Documents, Procedures,Maint Work Request Packages & Condition Repts, Periodicity of Nuclear Assessment Dept Audit & Receipt Insp

{{Adams
| number = ML20056C701
| issue date = 07/14/1993
| title = Forwards Proposed Rev 24 to QA Manual, Including Changes to Insp planning,in-line Review of Procurement Documents, Procedures,Maint Work Request Packages & Condition Repts, Periodicity of Nuclear Assessment Dept Audit & Receipt Insp
| author name = Perry J
| author affiliation = ILLINOIS POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000461
| license number = 
| contact person = 
| document report number = JSP-329-93, U-602142, NUDOCS 9307220050
| package number = ML20056C702
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 62
}}

=Text=
{{#Wiki_filter:-
likno:s Power Company Clinton Power Glation P.O. Box 678 '
Cilnton. IL 61727 Tel 217 935-c226
,                                                                                    Fax 217 935-4632 J. Stephen Perry -              '
Senior V!ce President ILLIN@lS                                         %[;32pa.t99a P4 EWER                                                                                                ;
U-602142 L30-93(744)LP 1 A.120                        -
Docket No. 50-461                                                    10CFR50.54(a)(3)
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

==Subject:==
Proposed Changes to the Clinton Power Station Ouality Assurance Program t

==Dear Sir:==

Based on improvements in various program processes and the experience of Clinton Power Station (CPS) personnel, Illinois Power (IP) has concluded that certain quality assurance functions can be performed effectively without in-line Nuclear Assessment (NA) department (previously known as the Quality Assurance department) involvement. As a result, IP proposes to change several activities described in the current IP Nuclear Program Quality Assurance Manual. These changes include: inspection planning; in-line review of procurement documents, procedures, Maintenance Work Request (MWR) packages and
                                                                        ~
Condition Reports (CRs); periodicity of the NA department audit; and receipt inspection. In accordance with the provisions of 10CFR50.54(a)(3), IP intends to implement these changes within 60 days of the date of this letter. In addition, IP has consolidated Non-Destructive Examination (NDE) responsibilities and has reassigned the Independent Safety Engineering Group (ISEG) to the Nuclear Assessment department. , All of the above changes and several                   1 other minor changes were discussed with members ofNRC Region III staff at a _ meeting in the Region'III office on June 15,1993. The details of and reasons for the proposed changes'aie described in Attachment 1 of this letter. The proposed revision 24 of the quality assurance manual, the 10CFR50.59 safety evaluation, the 10CFR50.54(a) evaluation and the matrix of changes which lists all changes made are also enclosed with this letter.                                     ,
1 This letter is submitted to request approval of the changes in inspection planning, the           q NA department audit periodicity, receipt inspection, and the in-line review of procurement                  ;
documents, procedures, MWRs' and CRs and to identify the consolidation of NDE.-
responsibilities and the reassignment of ISEG resources. As a result of these changes,                      ;
activities described in the current IP Nuclear Program Quality Assurance Manual will be                     i revised as described in the matrix of changes and proposed revision 24 of the manual. The'                   '
intent of the current planning and oversight activities, however, will continue to be fulfilled, 1
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thereby assuring the current level of quality is maintained. These changes are justifiable as the quality assurance program will continue to satisfy the requirements of 10CFR50 Appendix B, and Reg Guide 1.33/ ANSI N18.7 (1976) as described in USAR Section 1.8.                             .,
Sincerely yours, r,
ie S. Perry .
Senior Vice President RSF/nis Attachment / enclosures cc:      NRC Clinton Licensing Project Manager Regional Administrator, Region III, USNRC
            ' NRC Resident Office, V 690 lilinois Department ofNuclear Safety
                                                                                                         'l

I l
Attachment 1              l To U-602142 Page 1 of 5 Qudtylssurang.e Program Change _s Inspection Planning Presently, as part of the processing of a new maintenance item, Nuclear Assessment department personnel determine what quality verification inspections, such as hold and witness points, are planned into hiaintenance Work Request (MWR) and Preventive Maintenance packages. The guidance for determining these inspections exists in site procedures. Maintenance planners within the Plant Maintenance department determine all other details and documents that make up the MWR package with input from the Nuclear Station Engineering department (NSED).
Illinois Power proposes to consolidate the inspection planning function into the work planning function performed by the maintenance planners within the Plant Maintenance department.
Nuclear Assessment department personnel will perform the inspections that the planners specify in the work packages. Individual inspectors will continue to have the freedom to expand the scope of the inspection as appropriate. Additionally, the Nuclear Assessment               ,
department will maintain independent oversight through performance-based surveillances and            !
audits of maintenance activities.
Maintenance planners are independent of maintenance production supervision and currently perform inspection planning that is reviewed by the Nuclear Assessment department.                    t Maintenance planners currently assign " critical points" which specify points in the job sequence that require maintenance supervision oversight. Assigning critical points is a process       :
similar to inspection planning. The detailed task knowledge of the maintenance planners and           -
the empowerment of the inspectors to conduct performance-based inspections will enhance               ,
the overall inspection process. Chapter 1 of the IP Nuclear Program Quality Assurance                 '
Manual will be revised to describe this change as detailed in the enclosed matrix of changes and draft revision 24 of the manual.
[
Erocurement Document Review Presently, Nuclear Assessment department personnel review purchase requisitions and the corresponding purchase orders for quality-related procurements to confirm that quality                ;
assurance requirements are appropriate for the item ordered. The current quality assurance program and its implementing procedures require NSED to specify appropriate quality assurance requirements and product acceptance criteria.- Technical requirements for procurement requisitions for quality related purchases are specified by an NSED preparer and          ,
reviewed by a second NSED individual. The procurement requisitions are converted.to purchase orders and approved by the Purchasing and Material Control department. The NA department reviews have been primarily qualitative in nature, e.g., verifying that quality assurance requirements including receipt inspection criteria are consistent with the item being procured, that suppliers are selected from the Qualified Suppliers List and that specific requirements of the purchase requisitions are accurately translated into the purchase orders.

Attachment t To U-602142 Page 2.of 5 Personnel in NSED and the Purchasing and Material Control department are properly trained and qualified, and are accountable for establishing the appropriate quality assurance requirements for purchased items and ensuring accurate translation of technical and quality requirements into purchase orders. Illinois Power proposes to leave the responsibility for procurement document reviews with NSED and the Purchasing and Material Control department personnel and replace the in-line Nuclear Assessment department review of these documents with performance-based surveillances and audits of related activities. This change enhances the overall quality program by emphasizing individual performance, with appropriate Nuclear Assessment department oversight. Chapter 4 of the IP Nuclear Program Quality Assurance Manual will be revised to describe this change as detailed in the enclosed matrix of changes and draft revision 24 of the manual.
Procedurg Reviews Nuclear Assessment depanment personnel presently review new and selected revised procedures as part of the approval process. These procedures include those for tests, special tests, Technical Specification smveillances and procedures that specify repair or rework activities. Nuclear Assessment department personnel also review changes to the Updated Safety Analysis Repon (USAR) and Corporate Nuclear Procedures (CNPs). The purpose of these Nuclear Assessment department reviews is to assure effectiveness of the programs associated with these documents. The Nuclear Assessment department reviews have been primarily qualitative in nature, e g., verifying that program requirements have been met and that the document is administratively correct. It is Illinois Power's philosophy that quality is achieved through personnel knowledge and motivation to perform the work correctly, backed by independent review and performance-based evaluation of overall execution. Illinois Power personnel responsible for developing and maintaining these documents are producing high quality documents, as demonstrated by the low number and the insignificance of deficiencies identified by the existing Nuclear Assessment department in-line reviews.
Illinois Power proposes to establish performance-based surveillances of the activities associated with the difTerent documents in lieu of the in-line document review process. Illinois Power's experience has shown that performance-based surveillances and audits are better methods for evaluating effectiveness than document reviews, and these surveillances tend to identify more significant problems as well as performance weaknesses.
These changes will enhance the ability of the Nuclear Assessment department to verify that quality-related activities are effectively executed and ensure sufTicient oversight of documents to maintain quality program recluirements. Chapters 1, 2, 5, and 11 of the IP Nuclear Program Quality Assurance Manual will be revised to describe these changes as detailed in the enclosed matrix of changes and drafl revision 24 of the manual.

          .- - - ~ -- - --               - . . - .- - .                         .   .   . .                                 . _
Attachment 1 To U-602142 Page 3 of 5 hiaintenance Work Rectuest and Condition Rep _p_rt Reviews
                                                                                                                                  ]
Nuclear Assessment department personnel presently perform in-line review of MWRs during the initiation process, and MWRs and CRs during the close-out process. These reviews are                                  !
generally performed to fulfill the NA department responsibility of assuring these programs are                            ;
effective and to assure nonconforming material conditions receive appropriate dispositions.                                ,
Illinois Power personnel responsible for creating these documents have been producing high                                l quality documents, as demonstrated by the low number and the insignificance of deficiencies identified by the existing in-line reviews. Illinois Power proposes to replace these in-line                              >
reviews with performance-based surveillances of maintenance activities (for MWRs) and                                     j corrective actions (for CRs).            Performance-based oversight enhances the ability of the                          i Nuclear Assessment department to assure the effectiveness of maintenance / modification                                   ;
processes and CR corrective action implementation. Additionally, Illinois Power will continue                             ,
independent oversight through performance-based audits of maintenance activities.
f f
Chapters 1,2,3 and 15 of the IP Nuclear Program Quality Assurance Manual will be revised to describe these program changes as detailed in the enclosed matrix of changes and draft                                 .
revision 24 of the manual.                                                                                                ;
Nuclear ALsessment Department Audit Currently, the audit of the Nuclear Assessment department quality assurance functions is                                  f performed on an annual basis. The annual periodicity of this audit is a holdover from                                     j
      . construction and more frequent than the twenty-four month periodicity recommended by                                     ,
ANSI N18.7, " Administrative Controls and Quality Assurance for the Operational Phase of                                  ;
Nuclear Power Plants," and endorsed by Regulatory Guide 1.33, " Quality Assurance Program                                 !
Requirements (Operation)."
{
l Illinois Power proposes to change the periodicity of the audit of the Nuclear Assessment department quality assurance functions to twenty-four months to be consistent with ANSI                                   l N18.7 and CPS Technical Specification 6.5.2.8.d requirements. Technical Specification                                     i 6.5.2.8.d requires that audits of activities required by the quality assurance program to meet                            .
10CFR50 Appendix B criteria be performed at least once every twenty-four months.                                         j Chapters 1 and 18 of the IP Nuclear Program Quality Assurance Manual will be revised to                                   f incorporate this change in audit periodicity.                                                                             :
i e
ReceiptLnspection Presently, receipt inspections are performed by trained and certified receipt inspectors reporting to the Nuclear Assessment department. These personnel also perfonn many of the                                 .l tests and inspections necessary to dedicate commercial grade items for use in safety-related                              l applications.                                                                                                             j g
  - -                      . .-  . . - .            .   . ~ . . , - - , _ _   _
4       . . _ .  .--..,--,#,_., . _ _ , .

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                                                                                                    )
Attachment 1 To U-602142 Page 4 of 5          i Illinois Power's philosophy is that these inspection and testing functions could be effectively performed by another organization as part of a consolidation of procurement-related functions. Therefore, the receipt inspection function and the commercial grade dedication test and inspection functions currently performed by the NA depanment receipt inspectors may be        >
transferred to another depanment in the future. Pursuant-to any transfer of the receipt inspection function, the Nuclear Assessment department will maintain independent oversight of receipt inspection activities during performance-based surveillances and audits.               .
To allow the flexibility to transfer the receipt inspection responsibility from the Nuclear Assessment department to another organization, Chapters 1,7,10, and 14 of the IP Nuclear Program Quality Assurance Manual will be revised to indicate that receipt inspections will be     .
performed by certified receipt inspectors without reference to a specific department being responsible for that activity.
Non-Destmetive Examination Previously, Non-Destructive Examination (NDE) personnel reported to the Supervisor --
Quality Engineering and Verification in the NA department and additional qualified NDE resources were available in the In-Service Inspection (ISI) section of NSED. These NDE resources have been consolidated into the Nuclear Station Engineering department reponing to the Supervisor-ISI.
I This change has enhanced the overall quality of the NDE program by having a single line of      1 management for the total NDE function. The Nuclear Assessment department has retained             ,
some NDE expertise and will conduct independent oversight of NDE activities' during performance-based surveillances and audits of the NDE process.
Chapters 2,9 and 10 of the IP Nuclear Program Quality Assurance Manual will be revised to         ;
incorporate this organizational change as detailed in the enclosed matrix of changes and draft revision 24 of the manual.                                                                        ;
Independent Safety Engineering Group                                                             ;
Previously, the Independent Safety Engineering Group (ISEG) reported to the Supervisor -
ISEG within the Licensing and Safety department. A reorganization has placed the ISEG in the Nuclear Assessment'depanment reporting to the Supervisor - ISEG. . Additionally, the Engineering Assurance group which was previously part of NSED.now reports.to the.
Supervisor - ISEG. This change enhances the expertise of the Nuclear. Assessment -                .
department in the area of engineering and technical support. It also consolidates oversight l
functions under the Manager of Nuclear Assessment while maintaining ISEG independence.
The Manager - Nuclear Assessment ensures that ISEG functions are maintained separate and independent from quality assurance functions but with appropriate interface.

p-      s
                                                                                           . Attachment 1 To U 602142 -
                                                                                         - Page 5 of 5 Chapters 1 and 18 of the IP Nuclear Program Quality Assurance Manual will be revised to'
'l'
,..       . incorporate this organizational change as detailed in the enclosed matrix of changes and draft
          - revision 24 of the manual.
l?

a l
l IP NUCLEAR PROGRAM QA MANUAL L
   .                       Revision 24 Matrix of Changes Entire Manual Page     Para.                    Change / Reason For Change                          ]
l All      All    Added Centralized ' Commitment Tracking Numbers (CCT-              'l XXXXX) directly after - the applicable sentence or                   ,
paragraph for identification of prior commitments                      !
to manual content.
All       NA    Removed the dates at the bottom of each page.               A        ,
L                           decision was made during the processing of revision 23 not to allow individual page/ chapter changes.                    j Since any change will now' require revision lof the entire manual revision dates on each page are not nececsary, manual simplification.
First Page    NA    Removed     'the    approved     by:         Manager-Nuclear of each           Assessment block as' individual chapter revisions.                   .
Chapter            are no longer ellowca, t.anual simplification.
All       NA     Changed Quality. Assurance Department, Manager and'                 >
personnel      references     to    Nuclear       Assessment Department, Manager and personnel. Due to a recent.
organizational change.                                         ]    .
1 All       NA     Changed Nuclear Planning and Support Department,                    i Manager,     and personnel      references      to . Nuclear Support      Services     Department,        Manager. and personnel. Due to a recent organizational change.
All       NA     Changed Licensing and Safety Department, Manager               'j and personnel references to Licensing Department, Director     and personnel.          Due. to   a   recent        .
organizational changa.                                              !
All      NA     Changed      " Department    Manager"     . references    to -      .
                              " Department heads", organizational change.                         ;
                                                                                             -1 1
i 9
1                                                  .

t IP NUCLEAR PROGRAM QA MAlWAL
    ,..                         Revfsion 24 Matrix of Changes i
Table of Contents                                                                      ,
Page          Para.                Change / Reason For Change-i            NA    Rem'ved o     List of Effective-Pages. The entire' manual' was changed to Revision 23 during . the last anntal.     '
update which will require full manual revisions in.           +
lieu of chapter revisions in- the ' future which-eliminates the need for a list of effective pages.
i            NA    Changed Appendix     "A" to Glossary of - ' Terms and         ,
deleted old Appendix . "A" that addressed- revisions to. the Quality Assurance Manual which is covered in Chapter 2 and by implementing procedure QAP 102.02.
E t
t B
i 2

IP NUCLEAR PROGRAM QA FANUAL
  .                      Revision 24 Matrix of Changes                                   ,
Introduction                                                                       ,
Page     Para.                 Change / Reason For' Change-P 11   4 6.6  Corrected description / reference ~ to Appendix "A" and        #
added an explanation of the Centralized Commitment             .
Tracking numbers placed 'in -the' Quality Assurance Manual.       Appendix-   "A"   vas    changed- from - 'a description of how        to- make    revisions .to the Illinois. Power Nuclear Program - Quality Assurance'-
Manual to a    Glossary of Terms.       Revisions to the manual are addressed in Chapter 2'and-Implementing-Procedure QAP 102.02.                                          .
I t
I a
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3

                                                                                              ,.b IP. NUCLEAR PROCRAM QA MANUAL
: y. .                          Revision 24 Matrix of Changes Authorization Page       Para.                    Change / Reason For Change 111         1      Removed sentence "It is emphasized.that the. portion         .i of the program assigned to the Quality Assurance               ;
organization     primarily     . concerns-    verification activities,     such     as. inspection,      -auditing, surveillance,        evaluating.       and        reporting effectiveness, and providing' recommended solutions to noted ' problems."     to emphasize that the maj or portion of the Quality Assurance Program is' carried out    by   IP   departments lother        than . Nuclear Assessment.
The quality assurance ~ functions. of assuring effectiveness will . be implemented . in a performance based (off-line) manner as appropriate             -
while leaving . departments' performing a quality               '
activity with the in-line responsibility for that activity,    Also changed " Department Manager" to-
                                   " department head". The Licensing Department is managed by a director, iii    Approval    Added "/Date"      to   signature     line    to   indicate Signature    revision date which is no longer listed at- the Line     bottom of each page or~ the first page of each-               >
chapter.
l C
4 4

IP NUCLEAR: PROGRAM QA MANUAL s-                      Revision'24 Matrix of Changes
   , Chapter 1                                                                               I Page   Para.                   . Change / Reason For Change 1
1 1 of 7    1.1    Removed words "the establishment of" to take credit-for the prior establishment of the organization.-
1 of 7 1.2.1(3)  Changed: "Each CNP is reviewed and concurred with by the Manager-Quality Assurance for QA program requirements."
to: "Each CNP is reviewed and concurred with by responsible department management for incorporation-of quality assurance program requirements.". to                  ,
remove the Nuclear Assessment department from in-line document reviews.           In-line responsibility remains    with    the' responsible      department with         ,
Nuclear    Assessment     oversight     through Nuclear Assessment      department    management -review        and concurrence.
2 of 7 1.2.1(4)   Changed:     "The     organizational      structure-    and.
functional    responsibility     assignments are       such      :
that: (1) attainment of quality objectives is by-f.1dividuals assigned responsibility for specifying quality or performing work to specifications; (2) verification of conformance to . established quality-requirements is by _ those .who _ do not have direct-            ,
responsibility      for -specifying,;      producing,-     or expediting products; and (3) personnel in key'.
quality assurance functions.- have direct access to responsible management."
to: ' "The = organizational structure and functional-responsibility assignments       are such : _ that:      (1) attainment of quality. objectives is by individuals assigned responsibility for- specifying quality                 .
requirements or performing work to specifications;-             l (CCT 8196) and'(2) personnel performing.the' quality assurance functions - of _ verification, surveillance and audits- have direct access to responsible-management and organizational- freedom,- including-sufficient-independence from cost and schedule ~vhen-opposed to safety considerations."
                         'This provides wording more consistent with .10CFR50            I!
Appendix B.                                                     1 i
5

i i
                                                                                            .1 IP NUCLEAR PROGRAM QA MANUAL'
.y                      Revision 24 Matrix.of Changes                                           !
J Chapter 1 Page   Para.                      Change / Reason For Change                          )
2 of 7 1.2.l(5)    Changed:   " Specific Quality Assurance. activities.                 ;
(j ob  duties      and    responsibilities)       have     been identified     for     each   section      wit.hin the- QA.
department and are based on the amount 'and type of activities      conducted.         Staff!ng      levels'    are   j established so that the work can to r.ccomplished in                !
a manner      supportive     of    plant     operations     and outages. Further, once a year the QA ' department                -
manning levels are reassessed and personnel levels-                 ,
are revised as necessary to assure adequate - and                   l timely coverage of QA activities.                This . review      ]
permits recruiting and training activities : to be                  ,
carried out in'such a manner as to provide trained                  ;
Quality Assurance personnel-necessary to assure the                 i quality of the work.         Quality Assurance personnel
* are free from non-QA duties and provide- full attention to assuring the effective implementation of the QA program.       Effectiveness of the program'is.        . ;'
assured      by       Quality      Assurance         departatent participation       in   the    work planning,          through surveillance and audits,           by the authority. of Quality Assurance personnel to stop specific. work -
activities where it appears t. hat quality may . be jeopardized, and the authority. of the Manager >
Quality Assurance to initiate a Stop Work Action."
a' to: " Activities affecting safoty- related functions (job   duties     and    responsibilities)         have. been identified.     (CCT   8309)       Eft'ectiveness of the program      is      assured     through       verifications,       [
surveillances,       audits and by the authority' of                ,
individuals performing these activities to stop                    ;
specific work activities where it' appears' 'that                  '
quality - may be - j eopardized, and the authority of the Manager - Nuclear' Assessment to initiate a Stop
* Work Action. (CCT 8192)"
This clarifies that the Quality Assurance Program                   j is also implemented by personnel ~ outside of the Nuclear    Assessment. Department . with               Nuclear Assessment Department oversight through- various means to assure effectiveness.              Other- editorial =
changes made for clarification and simplification.
1 k
5 6

g                          v.                                                            ;
                                                                                         .I i
IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matri:t of Changes                                       ,
Chapter 1                                                                            .,
Page    Para.                    Change / Reason For Change 2 of 7 1.2.l(6)   Changed:     " Inspectors are provided with approved-inspection procedures and instructions prior to performing inspection operations.              (During - plant operations      emergencies,        inspections      may_   be performed without written procedures.)             To further assure that inspections are ~done in a timely manner, the QA organization identifies specific inspection points in the work documents and makes provisions      for   notification        of    verification /
inspection witness, and hold points.           In addition, designated QA personnel regularly attend and participate in planning,            scheduling and status meetings during testing, operations and outages to assure (1) they are kopt abreast of day-to-day projected work assignments throughout the plx.4t and (2) that the necessary QA inspection controls, acceptance     criteria,     procedural       controls    and' qualified QA staffing is available to properly carry out the assigned tasks."
to:   "Inspectkn     personnel       are    provided    with    6 procedures and instructions prior -to performing inspection operations.        (During plant . operations emergencies, inspections may . be performed without written procedures.) (CCT 8304)            To further assure that inspections are done . in 'a timely manner, specific inspection points are identified in work documents with provisions for notification of inspection / witness, and hold points. (CCT 8305)"
Allows inspection planning responsibility to exist outside the Nuclear' Assessment department with the Nuclear Assessment department retaining oversight responsibility. Other editorial changes made for clarification and simplification.
2 of 7   1.2.2     Removed     reference     to     Figure     11     for    the organizational structure.       To eliminate' unnecessary duplication     of     the       description       of. the organizational structure.          Also made two minor..
editorial changes, removing the word " individual"              ;
in the sentence which describes the: purpose of the             ~
section and changing "within IP"           to   "at Clinton Power Station".
2 of 7  1.2.2.1     Changed " Chairman, President 'and Chief Executive Officer of IP" to Executive Vice President - Energy-Supply" to' reflect a recent reorganization.
7 i

IP NUCLEAR' PROGRAM QA MAhTAL Revision 24 Matrix of Changes Chapter 1 Page    Para.                       Change / Reason For Change 2 of 7  1.2.2.1   Changed "Vice President" to " Senior Vice President" to correct title.
3 of 7  1.2.2.2   Changed: "The Senior Vice Prnsident is responsible for the overal           effectiveness     of the Quality;     '
Assurance         Program     and-    it   responsible     for establishing the quality assurance policies, goals
                     .and objectives, as well as' testing, maintenance,.             ,
operations, nuclear support, and engineering.             The Senior    . ice    President is also respons111o' for assuring       that    annual management reviews are conducted and documented on the status, adequacy and effecti'.eness of ' the overall QA program. The Senior Vice President is responsible for _ assuring that the authority and independence ~ of Quality _
Assurance       personnel     are such that        they   can effectively       assure    the conformance      to   quality requirements         and   are     independent    of    undue influences and responsibilities for schedule and costs."                                                        -
to:   "The. Senior Vice President is responsible for the overall effectiveness of the Quality Assurance             t Program and for assuring oversight of the quality
* assurance program for effectiveness.              The Senior' Vice President is responsible for assurin5-that the authority and independence of personnel performing quality assurance functions are such that they can effectively       assure the conformance to quality requirements and are sufficiently independent from.
cost. and        scheduling when. -opposed- to         safety. '
considerations."
This provides management flexibility in oversight of the Quality Assurance Program - consistent .~ with Regulatory Guide 1.33 and ANSI N18.7 and recognizes that some quality assurance program activities are performed -by personnel not              in-  the. Nuclear Assessment department.          New wording is consistent' with 10CFR50 ' _ Appendix . 'B' .      Removed unnecessary detail for simplification.
3 of 7  1.2.2.4    Removed specific responsibilities covered in other.
sections of the manual,             for Quality Assurance Manual simplification.                                        .
8-

_                                                             ,                             il i
IP NUCLEAR PROGRAM QA MANUAL
    ,                     ' Revision.24 Matrix of Changes Chapter 1 Page    Para.                      Change / Reason For. Change 3 of 7  1.2.2.5     Removed "The Manager - Nuclear Planning and Support is responsible for controlling . the Nuclear Program procedures governing' the procurement activities."
Removed specific ' responsibilities for planning and.
executive     plans,    resource      management,-     medical services,    nuclear'. program staffing and- change department name' to         Nuclear' Support       Services.        f Wording eliminates- unnecessary detail- in: the, program manual and reflects recent organizational change.      Changed " integrated"- to " integration",
editorial 4 of 7  1.2.2.8     Added    responsibility      for     the _ Manager : Nuclear -
Training to manage. the           Emergency PreparednessL Program. Recent organizational change.           ' Removed detailed     description     of -duties       to   eliminate
;                            unnecessary detail from 'the Quality Assurance Manual.                                                          _.
4 of 7  1.2.2.9     Removed    qualifications       of- the     Manager-Nuclear         '
Assessment, covered in the Updated Safety Analysis Report and detail         description of the Nuclear Quality Assurance Program.           To remove unnecessary detail from the Quality Assurance LManual.'              Addedl words to address that- the ISEC ' reports- to the
-                           . Manager-Nuclear : Assessment and - to emphasize their independence from the Quality Assurance- function.
Also other minor editorial changes for clarity.
4 of 7 1.2.2.9.1     Removed Director-Nuclear Assessment responsibili-ties to reduce unnecessary detail 'in the Quality Assurance      Manual     and-    limit      responsibility 1      '
dis.assion to department head.
4 of 7  1.2.2.10     Spelled out meaning of abbreviation USAR.                 Also removed the responsibility for ISEC activities.
Changed     " Manager-Licensing        and     Safety" '    to
                              " Director-Licensing" and removed the responsibility-for   management    of. the Emergency Preparedness Program. To reflect recent organizational changes.
Removed unnecessarv details in the ' description of Director Licensing responsibilities.
5 of 7  1.2.2.11     Removed      some     responsibility-        details       for     ;
simplification of the' Quality Assurance Manual-and made a minor editorial change.
9

n   e IP NUCLEAR PROCRAM QA MANUAL-Revision 24 Matrix.of Changes Chapter 1                                                    -
i Page    Para.                       Change / Reason For Change ~
5 of 7   1.2.3     Removed     reference      to    organizational ' structure" (Figure 1-2).       (CCT-8201) 5 of 7   1.2.3     Removed     responsibility:       ' "Review          Quality-related-procurement        requisitions        and,          as    specified, Condition Reports, procedures,                     instructions and.
other     Quality-related       documents."                 (CCT-8182)-
Removed Nuclear Assessment from in-line document reviews       leaving       responsibility              with.       line-management, with Nuclear Assessmento                        performing,      ,
performance based assessment to determine program effectiveness. Also other minor editorialichanges.
5 of 7    1.2.3     Removed responsibility to review'all changes to the USAR.     (CCT-8316)       Remove Nuclear Assessment from in-line document reviews             leaving responsibility                 ,
with    line     management- with Nuclear- Assessment responsible      for    assuring effectiveness through-oversight.
5 of 7    1.2.3     Removed reference         to. responsibility. . for               trend analysis to eliminate unnecessary detail from the
                            . Quality Assurance Manual,              trend . analysis             is discussed in chapter 16.
6 of 7  1.2.3(f)    Removed the words " develop and" to take credit for the - audit, surveillance and inspection programs which have already been_ developed. Other editorial changes made for clarity.             Changed QA ' to - Qualityc Assurance.
6 of 7 1.2.3 (h)   Changad "QA" to " Quality' Assurance"; editorial.
6 of 7 1.2.3(i)    Changed "QA Management" to " management"; editorial.
6 of 7  1.2.3.1    Removed     Quality      Engineering            and    Verification.
section description.           Remove- unnecessary detait from QAM.     (CCT-8223) 6 of 7  1.2.3.3    Removed Quality Systems section description. Remove unnecessary detail from the QAM. (CCTs-8321,~8322 and 8324) 6 of 7  1.2.3.4    Removed     Audit      Section       description.              ' Remove unnecessary detail from the - QAM. '(CCTs-8325, 8326-and 8327) 10
                                  =       -             -                 _. _

IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes Chapter 1 Page   Para.                     Change / Reason For Change 6 of 7 1.2 3.5   Removed Program Monitoring Section description.
Remove unnecessary detail from the QAM.
6 of 7 1.2.4(1)   Changed:    ." Activities affecting .~t he quality of safety-related systems, ~s tructures 'and : components -
are performed by or under!the: cognizance.-of various IP organizations. Other.. sections.of QA may perform some    of the functions' of another QA. .section-provided that personnel are- adequately trained,.
qualified / certified and these l work activities. are .
performed to the same (or similar) procedure o and instructions."
to: " Activities affecting the quality of safety-related systems, structures. and components are-considered quality assurance program activities andL are performed by, or under the cognizance of various IP organizations.           Any . department may perform these quality assurance activities provided that      personnel       are     adequately.      trained,
                    . qualified / certified, have the required. authority and    organizational      freedom,    .and' these work-activities     are' performed      in    accordance     with approved procedures.and instructions." .CCT-39591)
(
Recognize that' Quality Assurance functions can.be performed by personnel other than those..in the Nuclear Assessment department.
6 of 7 1.2.4(1)   Removed "between members of . these ' organizations" and changed " Chairman and CEO." to " Executive Vice President    -
Energy Supply"       (CCT-8618)      Remove limitations on types of disagreements or disputes to be brought .to ' management's attention.
7 of 7 1.2.4(2)   Removed "and quality assurance with the Quality Assurance       Department"      when;     referr'ng =     to responsibilities to ensure that it is understood-that other departmet ts arc responsible for Quality as well as the Nuclear Assessment Department.
NA    1.2.5    Removed nuclear program organization charts.              .QA Manr 21 simplification.
11

IP NUCLEAR PROGRAM QA MANUAL                                     i Revision 24 Matrix of Changes.
    ~ Chapter 2 Page       Para.                      Change / Reason For Change 1 of 5        2.2       Changed " package" to " packaging"; editorial.
1 of 5       2.2.1      Changed " Quality Assurance" to " Quality _ assurance" to clarify description of the program.
2 of 5       2.2.2      Changed Quality Assurance program " implementation" to " revisions".      Also removed the first paragraph explaining the past implementation and statement-that . the program -is fully implemented.           Removed reference to Appendix A in the description of QA Manual revisions. Changed words describing when a               '
change should be submitted to' the NRC for approval:
to more accurately describe requirements.              Also removed unnecessary detail describing the change submittal process for Quality Assurance Manual simplification.
2 of 5    2.2.3.a. Replaced reference to " Nuclear Policy Statements" with     the words " Policy Documents"- to . remove unnecessary detail from the Quality Assurance Manual for simplification.
3 of 5   2.2.3 b.2      Changed responsibility for reviewing CNPs from Manager-Nuclear         Assessment       to   ; responsible 1 department management.       (CCT-40847)   Remove   Nuclear Assessment-     from     in-line-   reviews    and     leave responsibility with responsible management.
3 of 5     2.2.3.c      Removed reference to Table 2-1,        (CCT-8340) because Table 2-1 was removed from the manual.
3 of 5     2.2.3.c      Replaced " Corporate Nuclear Procedures. and the ~ IP Nuclear Program Quality Assurance Manual." -with "The upper tier documents listed in section 2.2.3 a&b above. "     To include Policy Documents, Records-Management Standards .and ISI . Manual to . list of upper tier documents         implemented by department procedures and instructions.
3 of 5       2.2.4      Changed " Manager or Director" to " department'. head" in the description of who is responsible for proper qualification        of    , personnel,     for      manual simplification.
4 of 5   2.2.5 (1)      Changed " Regular management reviews..." to " Regular reviews..."; editorial.
12

R v
IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes Chapter 2.
f            Page     Para.                        Change / Reason For Change i                                                                                                ,
4 of 5  2.2.5 (1)-  Changed: "This review function consists of meetings with key . QA personnel,. as well' . as review of QA-department audit- and status . reports, and the performance of a IP-Nuclear'QA Program. assessment, which is preplanned and ' . documented.            Corrective action required as a- result . of adverse conditions identified during the assessment are documented, tracked, and completion is verified and documented by IP Quality Assurance."
to: "This review function' consists-of meetings with' key Nuclear Assessment personnel, as well as review j                                of audits and reports, and the performance of an IP Nuclear Quality Assurance Program assessment, which             '
is preplanned and documented.             Corrective action required        as    a   result    of  adverse conditions identified during the assessment are documented, tracked, and completion is. verified and documented.
(CCT 8342)"
To    provide         for    organizational    freedom    for responsible departments to document, -track and verify completion of corrective actions.                 Also minor editorial changes for clarity.
2.2.5 (2)   Added "or authorized ~ agent" -to_the sentence stating 4 of 5 who audits suppliers' quality assurance programs -
and removed "in activities", editorial.
4 of 5    2.3.2     Added item c.          Maintain procedures / instructions' to   '
the   extent necessary _to -carry out activities affecting ' quality.        To ensure responsibility for adequate procedures          rests with the responsible department.
             .5 of 5   2.3.4      Removed      specific      Nuclear    Station    Engineering responsibilities covered in over chapters of _ the manual    and       added    overall   responsibility. *a.
Implement the design control- program for CPS, including design interface control activities'"            .
Quality Assurance Manual' simplification.
5 of 5  2.3.5.a     Removed      " Establish,"      from   Nuclear -Training's     1 responsibility.to maintain and implement:a Licensed             :
Operator Training program and a General Employee                '
Training program.         Added Maintenance and Technical        ,
Training program.         Take credit for the established      !
training program.
13 d

c~             ,                                                                    .
IP NUCLEAR PROGRAM QA MANUAL' Revision 24 Matrix of Changes Chapter 2-Page       Pata.                   Change / Reason For Change 5'of 5      2.3.6   ' Removed spe'cific Nuclear Assessment responsibili-ties covered in other chapters in .the manual for manual simplification.
5 of 5      2.3.6    Removed Nuclear Assessment responsibility " Review all changes to the USAR, with_ the exception of-Chapter 16, Technical Specifications."      To remove Nuclear Assessment from-the in-line' review process.
5 of 5      2.3.6    Added' Nuclear Assessment responsibilities:
: a. Perform activities to ensure the established quality assurance program meets requirements and_is effectively executed,
: b. Identify quality problems and assure corrective actions are effective.
5 of 5    Table 2-1  Removed Table 2-1 for manual simplification - and eliminate    confusion .about        the degree   of applicability indicated in the table.
14

IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes Chapter 3 Page     _ Para.                   Change / Reason For Change
:1 of 5    3.2(2)   Editorial change to correct' grammar and spacing.
3 of 5 - 3.2(5)d. Removed " release" and''" distribution" ~ from the list        '
of activities performed by each : organization in-relation to drawings specifications, data sheets, ,
etc.       These activities are performed- by the-             ;
Document Control. Group."-
4 of 5    3.2(8)   Changed " operations" to " operation", editorial.
4 of 5    3.2(9)   Changed "The" to "These"         editorial.                    t 4 of 5    3.2(10)  Changed:     "When a- verification test           cannot be performed prior to installation, proposed Ltesting programs shall be reviewed and approved by Illinois-Power to ensure that the program ~ is conducted within - licensing limitations prior to the point when the installation -would become irreversible, and that no unresolved              safety  questions    are involved."
to: "When a verification test cannot be performed prior _ to installation, proposed ~ testing programs          "
shall be reviewed and approved by Illinois Power to-ensure that no unresolved safety questions are involved and the . testing is conducted within licensing limitations prior to the point when the installation would become irreversible."                      ,
r Editorial.
4 of 5   3.2 (11)   Removed     responsibility        assignment    from    this description section and added-surveillances to the -
methods used to        ensure design - ac ti_vitie s are implemented        in     accordance       with'     program requirements. Editorial.
4 of 5    3.3.2.a   Removed     " Develop    and" -    from Nuclear      Station Engineering responsibility to implement the des' p            ,
control program for CPS, including design' interface control activities.       To take credit for the design control program that has been developed.
5 of 5    3.3.2.f   Removed "in the central file" from the end of this-section and other minor editorial ' changes . for clarity.
15

IP EUCLEAR PROGRAM QA MANUAL'
;, _                    Revision 24 Matrix of Changes-
     -Chapter.3 Page ' Para.                . Change / Reason For Change 5 of 5   3.3.4  Removed    Nuclear Assessment         responsibility -to-     '
                         " Review   the    authorizing      work   documents   for implementing design changes for. systems, components and structures and ensure that- the IP Nuclear Quality     Assurance      program     requirements. 'are incorporated."     The  . quality assurance functions of assuring effectiveness will be implemented in a performance based (off-line) manner as appropriate while leaving departments performing -a- quality activity with the in-line responsibility for that activity.                                                     t 5 of 5 3.3.4.a  Removed the word " periodic" and added surveillances to the methods used to determine design control' activities     meet   the     applicable. requirements.
Editorial.
s t
                                                             =
b r
s 16

                                                                   .       ..    =    ~     .      . .
                                 'IP NUCLEAR PROCRAM QA MANUAL'
,                                 Revision 24 Matrix of Changes
  ' Chapter 4                                                                                           '
Page       Para.                             Change / Reason For Change 1 of 3-       4.2            Removed     responsibility ' assignments         from     this     l description section,~ editorial.
1 of 3  4 ~. 2 (2 ) &(3 )    Changed:     " Purchase requisitions       for , materials, parts,     components' or       services    for     CPS    are      ,
ori inated 5       by the CPS ' organization     having~ ' a need for the material, part, component or service - for the . operation, maintenance, refueling, repair or modification of the plant.
Purchase requisitions are prepared in accordance with documented procedures that require:
: a. Applicable     specifications,     drawings, quality control requirements, and related documents be -.
included or referenced."-
to: " Purchase requisitions for materials, parts, _
components or services' are. originated for the operation,      maintenance,     refueling,_     repair     or modification of the plant. (CCT 8350)
Purchase ' requisitions are prepared in accordance-with documented procedures that require:
: a. Applicable specifications, drawings,- _ quality.
requirements , . and related documents .be , included -
or referenced.":(CCT 8351)                                    .
Editorial change.                                                   .
2 of 3     4.2(4)            Removed "The Quality Assurance; department. verifies appropriate Quality- requirements are- specified."
(CCT-8353) because the . originating department is responsible for specifying requirements on purchase requisitions.       The ; quality assurance ' functions of-         i assuring . effectiveness wi.11 be implemented .in a performance based (off ,ine) manner . as - appropriate while leaving 1 departments performing. a quality activity with the in-line responsibility for that activity. Also other minor editorial changes.
17                                                  #

          *   ^''                                                            -         -                -
IP NUCLEAR PROGRAM QA' MANUAL Revision 24 Matrix of Changes                                                      '
Chapter 4 Page     Para.                       Change / Reason For Change 2 of 3   4.2(5)      . Changed: " Quality Assurance performs a review to ensure the requirements ("a" through "f" above) have been met."                                                              ,
to:   "a   review        is   performed      to . ensure- the-requirements ("a" through "f"                above) have been
* met."    (CCT-8347)
Responsibility           for    . ensuring . the-             Quality..
requirements are specified'in purchase requisitions is shared by NSED and Nuclear Support Services..
The. quality        assurance oversight functions. of                             :
assuring effectiveness .will be implemented :in a                                ,
performance based (off-line) manner as. appropriate while leaving departments .. performing                 a- quality activity with the in-line responsibility'. for that-activity.      Also remove         "for placement -on              the.          '
Qualified Suppliers List" editorial.
4   I 2 of 3   4.2(6)        Changed-   " Nuclear        Planning     and      Support"          to-
{
                              " Purchasing and Material Control" . . Organizational change.
2 of 3   4.2(7)       Removed the word " periodic" and added surveillances to the methods used to deternine design control                                  ,
activities     meet       the    applicable      . requirements.                 ;
Editorial.                                                                       ;
3 of 3   4.3.2 &      Added section for Purchasing' and Material Control-4.3.3       responsibility and transferred responsibility for preparing purchase orders from Nuclear Support Also Services to Purchasing'and: Material Control.
renumbered       subsequent       sections,         to       clarify responsibilities.        Organizational. change.                                 7 Added responsibility for Purchasing and ' Material
                                                                                               ~
3 of 3   4.3.3.b                                                                  -
Control to review purchase orders / contracts for
                             -qu_ality -assurance program requirements. .To remove the Nuclear Assessment Department: from in-line                                  ,
reviews and incorporate those reviews 1 into .the appropriate line functions.                                                      :
r 3 of 3  4.3.4.d.       Removed "to perform", editorial.
                                                                                                            -. i f
18 '
e   -           -                            ~                 ,,#       -
                                                                                             ,     -- i--

,Y.
  '                             . IP NUCLEAR PROGRAM QA HANUAL-
                                  ' Revision 24 Matrix of-Changes-
            , Chapter 4 Page-  Para;                     Change / Reason For Change                    ,
3 of 3  4.3.5       Removed    Nuclear'  Assessment' responsibility     .to
                                     " Verify   appropriate . Quality    requirements- are specified for materials,       parts, . components ; or services for CPS."- The quality assurance. functions.       ,
of assuring effectiveness will be implemented in a performance based (off-line) ' manner as appropriate while leaving departments performing 'a. quality activity with the in-line responsibility for ' that         :
activity.                                                   ,
3 of 3 4.3.5.b      Removed the word " periodic".and-added surveillances        +
to the methods used to determine design ~ - control activities    meet    the   applicable   requirements.
Editorial.
5 t-4
                                                                                               .t 19                                           !
I

IP NUCLEAR PROGRAM QA' MANUAL-
.                       Revision 26 Matrix of Chenges Chapter 5 Page    Para.                    Change / Reason For Change 1 of 2   5.2(1)  ' Removed the word " issuing" from the individual and 5.3.1   departments'      responsibilities     for   developing.    ;
reviewing,    approving and complying with formal documentation      . as    this-   activity    is      the~ !
responsibility of the document control organization-which does this for each department.       (CCT-8277) 1 of 2   5.2(2)    Removed- reference to Table 2-1 which has been removed from the manual. (CCT-8278) 1 of 2   5.2(3)    Removed the word " periodic" and the responsibility.
assignment. Editorial.
2 of 2    5.3.2    Removed the Nuclear Assessment responsibility .to
                           " review selected CPS departmental ~ procedures and        ,
instructions for QA program requirements."           This  ;
responsibility statement was redundant to the other responsibility listed in 5.3.2.a and supports the approach that the        quality assurance function of assuring effectiveness will be implemented in _ a performance based (off-line) manner as appropriate while- leaving departments performing- a quality-activity with the in-line responsibility .for that activity.
2 of 2  5.3.2.a. Removed the word " periodic" -and added-         "
                                                                              ,   are adequate". Editorial.
20

n1 IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changee Chapter 6~                                                                                   ,
Page          Para.                          _ Change / Reason For Change 1 of 3   6.2(1)     Removed -description of -how to make                  temporary      l changes to procedures as this ..is '                adequately described ~in       the .USAR~ and station _ procedures,'            '
manual simplification.           Also corrected reference-outline.
2 of 3 6.2(2)a. Removed      responsibility        assignment      from    this description section.
2 of 3 6.2(2)f. Spelled-out inservice inspection prior to ISI.
* 2 of 3 6.2(2)g. Removed Corrective Action - documents from the list of controlled documents. Not all Corrective Action documents _ are controlled documents.                  Changed-
                                " Nuclear Policy Statements" to " policy documents".               ,
3 of 3 6.2.(3)b. Changed: "A program for _ approving the receipted documents for use-in activities associated with CPS by that organization."
to:  "A  program for reviewing and approving ' the documents received for-use in activities. associated with CPS by that organization."
Editorial.                                                        ;
3 of 3   6.2(5)      Removed      the     ' word    " periodic"     and     removed     ,
responsibility assignment from this description.
section. Editorial.
3 of 3  6.3.3.a.      Removed the word " periodic".         Editorial.
t t
4 h
4 I
21                                                'l

~
l IP NUCLEAR PROCRAM-QA MANUAL
,                  Revision 24 Matrix of Changes                                    j 1
Chapter 7                                                                         i Page  Para.                    Change / Reason For Change                  :l l'of 5  7.2    Removed     responsibility. assignments    from. this description section.
1 of 5 7.2(3)  Removed "The Quality Assurance department specifies.-
the Quality Assurance program requirements.' that-must     be met by suppliers."            Remove - Nuclear   J Assessment      from   in-line     document   review and.      '
eliminate duplication in re'sponsibility between NSED and Nuclear Assessment. (CCT-8354)                 This  -
supports the approach that the quality assurance functions     of   assuring     effectiveness    will    be implemented     in a     performance- based     (off-line) manner as appropriate while leaving departments-performing a quality activity. with the in-line responsibility for that activity.
1 of 5 7.2(3)   Changed: "Where necessary, the determination of a supplier's      acceptability     includes . information obtained through audits of the supplier by the Quality Assuranca organization."
to: "Where necessary, a supplier's acceptability'is determined by an audit of the supplier's Quality.
Assurance program." (CCT-8355)
Editorial change requested by the' Audits group .to clarify meaning / intent, since such audits may be
                    -performed by a utility cooperative.
1 of 5 7.2(3)    Changed: "Such audits 'are performed in accordance with a written plan or checklist to determine the ability   of    suppliers    to   comply . with Quality Assurance program requirements of ' the . procurement document."
to: "Such audits are performed in accordance with a.
written plan.or checklist to determine the ability of   the supplier to comply with the Quality Assurance program requirements of the procurement.          ,
document." (CCT-8355)
Editorial change.
22 x

1 IP NUCLEAR PROGRAM QA MANUALT                                                l Revision 24 Matrix of Changes                                             j Chapter 7                                                                                   d Page      Para.                          Change / Reason For Change 1-of 5     7.2(3)  Changed:           "The- determination        of 'a     supplier's-and 2 of 5           acceptability may be- made by means other than'                       :. ,
audits of the supplier by Quality Assurance."'
to:          "The       determination      of     a     supplier's acceptability may _ be made by means . other than audits."
Changed: "When these means are either not available or do not permit a complete evaluation of a supplier's Quality capabilities, Quality Assurance will conduct a survey or an audit of the' supplier."
to: "When these means are either not available or do not permit a complete evaluation of.a supplier's Quality capabilities, a survey or an audit will be conducted of the supplier."
Changed:          "The Quality Assurance department' is responsible for maintaining the qualified suppliers :-
lis t .' "
to "A Qualified _ suppliers list is maintained." to                      .
remove language which implies ' Nuclear Assessment                       '
has        the sole        responsibility. . for-     determining-supplier acceptability. '(CCT-8356)                             .
2 of 5    7.2(4)   Changed:           " Purchasing and material control is assigned the responsibility of ascertaining -that required technical and quality assurance oreviews and evaluations..."                       -
to:     "a review is performed to ensure that the required            technical     and      quality'     assurance evaluations..."
Manual           simplification,       describe      program      in description sections and . assign responsibility in responsibility sections.
F 23

3
                             'IP NUCLEAR' PROGRAM'QA MANUAL
,y                            Revision 24 Matrix of Changes Chapter 7-                                                                            ,
Page      Para.                       Change / Reason For Change s
2 of 5     7.2(5)      Changed: "Following the award of the contract or placement    of the     purchase order . the Quality Assurance      organization     is     responsible-  for performing periodic surveillances and evaluations at the supplier's facility, as necessary,.to verify continued compliance with the quality - assurance:
requirements of the procurement . documents.         The-results of these surveillances and evaluations . are        ,
documented. Where specified in the purchase order           '
or contract, source inspections at the supplier's facility are accomplished by the Quality Assurance organization or qualified agent to verify. that the procured item or service is being supplied in compliance with the requirements of the procurement-documents.      Such inspections . are accomplished in accordance with written procedures, plans, and/or checklists containing or referencing appropriate acceptance criteria."                                       ,
to: '"Following the. award.of          the contract or
* placement of the purchase order,.surveillances and evaluations      at  the    supplier's    facility   are conducted to verify continued compliance with the-quality assurance requirements of the procurement documents. Where specified in the purchase order or contract, source' inspections of the supplier's         ,
facility are accomplished by qualified individuals or qualified agent to verify that - the procurement item or service is being supplied in 'accordance with the requirements of the procurement documents.
Such inspections are accomplished -in accordance with written procedures, . plans, and/or . checklists containing or referencing appropriate ~ acceptance criteria. (CCT 7997)"'
Manual      simplification / editorial,     specifically defining the QA program in general rather than in terms    of   the Nuclear ' ' Assessment department's responsibilities.       Responsibilities are described in the responsibility section.
24

[c . s i
IP NUCLEAR-PROGRAM QA MANUAL E,                         Revision 24 Matrix of Changes
       ' Chapter 7-Page  Para.                    Change / Reason.For Change                     ..
2 of'5  7.2(6)   Changed: "Upon receipt at CPS, Nuclear Planning and              ;
Support is responsible for . the' control of safety-            ,
related materials, parts . . . and components . Quality     ;
Assurance inspection personnel . are' responsible for inspecting, releasing,. and identifying purchased-material and equipment as to the -inspection status          .;
as required by the purchase order."
to: "Upon receipt at CPS, safety-related materials, parts, and components are controlled.             Qualified, inspection      personnel-     'are     responsible. for  'l inspecting, releasing, and identifying purchased material and equipment as to the inspection status.
(CCT 8357)."
This change      recognizes     that the organizational.
structure    for    executing     the - quality  assurance program may take various' forms. provided. that persons and organizations. assigned the~ quality assurance oversight functions'have direct access to-responsible management and sufficient independence'            ;
from cost and schedule when opposed to safety =                ;
considerations.       Also : removes the limitation ' on inspections to' those specified in- 'the purchase-order. The Nuclear Assessment department will.              :
share the quality . assurance. function with ' . the -        >
organization responsible - for receipt inspection -in that_ program . effectiveness will be' assured in other       '
than an in-line; approach as appropriate- using surveillances and audits.
4 l
                                                                                          ~
25                                                4 l
I l

IP_ NUCLEAR PROGRAM QA MANUAL Revision 26 Matrix of Changes Chapter 7-Page   Para.                   Change / Reason For Change -
2 of 5  7.2(7)  Changed:     "After   receipt. inspection,     storeroom personnel of Nuclear Planning and Support are responsible for forwarding the material- to a controlled     storage . area .or     releasing' it for.
installation or further work. Personnel-from other        ,
departments also perform acceptance activities such as evaluation of content of technical documents required by the purchase order, and the conduct of -
special tests and measurements which are identified in the purchase order. . When; these activities . are accomplished, QA personnel verify that those' acceptance activities were accomplished prior . to final acceptance of an item.        Receipt inspections are    accomplished    in   accordance with written procedures and/or plans containing or referencing appropriate acceptance criteria."
to:      Acceptance activities such as evaluation of-content of technical documents required by the purchase order, and ' the conduct of- special tests and measurements which - are identified in the purchase order are also performed.              . Receipt inspections are- accomplished in; accordance with written procedures and/or ' plans containing or referencing appropriate acceptance criteria. After receipt    inspection,    the purchased- material is forwarded to a controll_ed storage area or released for installation or further work.       (CCT 8188)"'
Manual simplification, to describe the program in the description section and assign responsibility in the responsibility section.
26

g IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes                                     j Chapter 7 Page     Para.                     Change / Reason For Change 2 of 5   7.2(8)    -Changed: "The validity of a supplier's certificate and 3 of 5            of conformance is ascertained through any of the following methods: source inspection, independent               ,
inspection         agency,       receipt         inspections,-
surveillance,       testing     of     hardware.       Quality  4 Assurance audits or surveillances.
to: "The validity of a supplier's certificate of conformance     is ascertained through any of' the              ,
following methods: source inspection, independent-
* inspection         agency,       receipt'       . inspections, surveillance,       testing     of     hardware,       quality.
assurance audits or surveillances.                              ;
Removed the capital letters . from the words Quality Assurance which implies that only the Nuclear Assessment      Department, _ formerly         the     Quality-Assurance Department, audits these activities ' and recognize         audit      results         from         other
                          -departments / organizations. (NUPIC. INDEX,'.NUMARC).           '
(CCT-8358)-
3 of 5   7.2(10)     Changed: "The Quality Assurance department conducts periodic surveillances and audits .of the control-measures..."
to: "Surveillances and audits are conducted of the control measures..."
and changed " Quality Assurance audits of suppliers" to " Audits of suppliers".
Remove the wording which implies only the Nuclear Assessment Department audits these activities and recognize        audit       results'       from         other departments / organizations (NUPIC. INDEX, NUMARC).
(CCT-8358) 4 of 5  7.3.3(b)    Changed     " Quality. Assurance"      to       " Qualified
                           -inspectors". To use qualified inspectors in other          ,
departments.
4 of 5  7.3.5.a     Changed    " evaluations"     to    "surveillances",       and removed "as necessary". . Editorial.
l 4 of 5  7.3.5.b    _ Changed   " evaluations"    to   " audits"     and -removed-  .
periodic" and "as necessary".       Editorial.
27
                                                                                           )

_, . .=          . _ ,   .-
IP NUCLEAR PROGRAM QA.MAIRfAL' Revision 24 Matrix.of Changes
              ! Chapter 7 i
Change / Reason.For Change
    ^
Page             Para.
  .                                                                                                                                =j 4 of 5            7.3.5.c      Removed the word " periodic",           Editorial.
5 of 5            7.3.5.d      Removed the word "as necessary".              Editorial, a
5 of 5            7.3.5e      Changed      " evaluations        or      audits"            to         "the-       ,
surveillances and audits".            Editorial.                              - .;
5 of 5            7.3.5       Removed " Perform and document receipt inspection of                                 1 purchased items, including verifying - the . required l                          j documentary evidence of; conformance -to; procurement requirements is available ati CPS and verifying                                  .j activities of other groups are . accomplished : prior                               i to final acceptance of ' an - item and release- for                                 ,
use."     Organizational change, receipt inspection                                 ,
may be performed by another organization- l in the future, t
5 of 5             7.3.5      Removed reference -to          performance of . receipt or.                         ;
by     the Nuclear ' Assessment.
source     inspections department as these inspections may .be- 'done by.                               .!
another organization. in              the    future.            Removed
                                                   " Review purchase        requisitions        and     specify the                   -
                                                 ' Quality. Assurance Program requirements 'for_.the'                                 '
item (s) to be procured." because thisLis. covered in l
section     7.3.2.a       Nuclear.. ' Station- Engineering'.                       !
responsibilities.        The quality assurance functions                        !!
of assuring effectiveness will be implemented in'a                                 !
performance based (off-line) manner :as ; appropriate                              '
while leaving '' departments ~ performing a quality-activity with the in-line responsibility . for ( that
                                                                                                        ~
activity.                                                                         J a
t i
r f
f 7
28                                                             .l r          e    --     -+,         , - -                                         *-*;            -- '            "

   'a"-      -
l IP NUCLEAR PROGRAM QA MANUAL                                                   ;
Revision 24 Matrix of Changes.                                                  -
Chapter 8                                                                                               .
Page      Para.                          Change / Reason.For: Change                               ;
1 of 3      8.2.a. Changed " items of purchase" to             " purchased ' items" .
Editorial.
2 of 3 -      8.2    . Removed      responsibility' assignments              from    ~ this=
description section. editorial.
l 2.of-3      8.2(3)      Changed:           "During        fabrication,          assembly,            !
installation,         'and ' shipping      activities       at    'a-supplier's facility, the supplier .is responsible-for identification and. control of materials, parts,-
and components in accordance with the . requirements                         ,
of the IP purchase order."
to: "During fabrication, assembly, installation,                             ;
and shipping activities at a supplier's facility,                            ;
the supplier conducts verification inspections ~ and-                      a is -responsible for - identification and control . . of]                     ;
materials, parts,'and components in accordance'with-                         l the requirements of the IP purchase order." (CCT-                          '!
8296)
To   clarify        the supplier's' responsibility- for.                     j quality under the Quality, Assurance Program.                                ,
2 of 3      8.2(5)      Removed " verification inspections and" from the.-
sentence        stating      what- the~ Nuclear Assessment                   -
Department- conducts.
To  remove     prescriptive.
inspections from the - Quality Assurance Program '.                         ,
Manual.
The performance of. surveillances 'and audits adequately describes the. quality function'to assure . program effectiveness.             Also ' removed the              ,
word " periodic", editorial.                                                 ;
i 2 of 3     8.3.2.a      Removed " Develop and"           from the' sentence which describes the program responsibility for ' material identification . and control.           Take credit for the-program which has already been developed.
e 3 of 3     8.3.3.a      Removed " Develop         and"    from -the . sentence which describes the res'ponsibility. for the inventory control system.         To ' take credit for- the inventory                 3 system which has been developed.                                            -
3 of 3     8.3.4       Removed'" Ensure that. suppliers: comply with approved
                                             . procedures." to remove implied continuous oversight.'.-                   _!
and cover with the remaining responsibility - for -                       _l conducting surveillances and audits.                     ,
                                                                                                                           ?
29                                                        :
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IP NUCLEAR PROGRAM QA MANUAL Ravision 24 Matrix of Changes                            .l n      Chapter 8 Page                                      Para.                Change / Reason For Change s
3 of 3                                     8.3.4  Changed:   " Conduct verification inspections and periodic    surveillances . and ' audits. of the=
identification and ' control of -items to- ensure-compliance with the requirements of this chapter."
to:   " Conduct surveillances     and audits of .. the identification and control of -items to ensure compliance with program requircuents. (CCT 8298)"
Remove prescriptive _ inspections from the - Quality Assurance Program Manual and an editorial '. change .
The   performance    of   surveillances. and    audits adequately describes     the   quality   functions- to-assure program effectiveness.
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_ . _ . ,       . .     .           _,      ,                               . ~ .
:IP NUCLEAR PROGRAM-QA MANUAL Revision 24 Matrix of Changes
    ' Chapter 9                                                                                                       ,
Page        Para.                       . Change / Reason For Change                                   ;
1 of 4           9.2      Removed "Special' processes include velding, heat treatment,      nondestructive examination . (testing),
chemical      cleaning,      pipe. bendingr. and                special coatings." To eliminate redundant material covered.
in Section 9.1.
2 of 4-          9.2      Removed:      " Nuclear Station . Engineering.' specifies special      processes      in- technical ' documents and' procurement requisitions. ~The control of. scheduled                            '
ISI    examinations        .and- -inspections.               is-    the; responsibility of the Nuclear Station _ Engineering -                          -
Department.       The control- of other. special processes'                     ;
is .the responsibility of . CPS Plant. Staff.                       The-control-~of NDE to support plant operations . is the responsibility of the QA department." 'Also removed other    responsibility         assignments ~. 'from               this        '
description section.
Responsibility for' Non-_ destructive Examination has                       -,
been _ assigned       to   Nuclear   Station            Engineering.           I (CCT-8005)      Organizational change, and to describe
* responsibility _in the responsibility section.
2 of 4      9.3.la&b'    Removed        " Establish      and     "
                                                                                           ' from'      these and 3 of 4       and 9.3.21    responsibilities to take credit for the established'                           >
programs. Editorial.
3 ef 4.      9.3.2      Consolidated        Non-destructive     Examination               (NDE)        l responsibilities in Nuclear . Station'' Engineering.
and 9.3.3 The Nuclear Station Engineering'Departaent performs the majority of the NDE 'at Clinton Powc r Station,                             ,
Through      the     implementation    of          the       inservice     .'
Inspection Program, .this change will' consolidate                             ;
all NDE activities.
l 3 of 4'     9.3.3a      Removed the word " periodic", editorial.                                    ?
4 of 4       9;3.3      Removed      "If. radiography . .is; performed                 by- IP,         .
maintain the required 'NRC license for. radioactive -
source- material."         from' the     list           of     Nuclear Assessment' responsibilities.        This type' of work (is .
contracted through a licensed provider and NSED has.-                          :
the responsibility to contract this work.                                      l q
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IP NUCLEAR PROGRAM QA MA! MAL Revision 26 Mai:rix of Changes
!    Chapter 10 Page    Para.                  Change / Reason For Change-n-      2 of 3    10.2   Removed ." Qualification requirements of inspection-personnel; and" from the list of items identified             ,
in   the _ programs of . inspection.          To   remove.     .
implication       that       inspector     qualification.
requirements are specified in work documents. .Also other minor. editorial changes including the removal of responsibility assignmer*s.
2 of 3  10.2.c. Changed: " Inspection personnel are qualified and certified in accordance with the requirements of applicable codes or standards and are persons other than those who . performed or directly supervised that activity being inspected.        The qualifications and certifications of. inspection personnel are maintained current."                                          ,
to:   " Inspection    personnel are - qualified and certified in accordance with the requirements of applicable codes, standards and written procedures.
Inspections are performed by persons other than               ,
those who performed or directly supervised the activity being inspected.       The qualifications and certifications     of     inspection    personnel    are maintained current. (CCT 24343)"
Editorial clarification.
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r IP NUCLEAR PROGRAM QA MANUAL
                       . Revision 24 Matrix of Changes Chapter 10 Page   Para.                    Change / Reason For Change                        ,
2 of 3  10.2     Removed    "The Quality Assuranca department - is -
responsible- for inspection of plant- structures, systems,    and components.        The Nuclear Station Engineering department is responsible for scheduled ISI    Program       examinations     and    inspections.
Inspections conducted include:           maintenance and          ,
modification inspection, receipt inspection, new fuel inspection, inspections of surveillance tests, inspections of functional and preoperational tests, ISI examinations and inspections, and housekeeping
* inspection.       The Quality Assurance department is responsible for evaluating and determining .thef acceptability of inspection results in accordance with specified inspection criteria.          The Nuclear Station Engineering Department is responsible for evaluating and determining the acceptability of scheduled ISI Program ' examination and inspection results. The Quality Assurance Department and the Nuclear Station Engineering. Department may use the services of other IP department personnel or may -
engage the services - of _ external' organizations to accomplish any ' inspections, evaluations or reviews-of inspection.and test results."        This material is adequately covered in the responsibility sections                 e and'   the     implementing     procedures.       '. Manual simplification       and   Non-destructive    Examination program is the responsibility' of the Nuclear                     ;
Station Engineering Department.       (CCT-8017) k 6
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                                                       - . ~ .                 .        ..
IP NUCLEAR PROGRAM'QA MANUAL-Revision 24 Matrix of Changes Chapter 10 Page    Para.                      Change / Reason For Change 2 of 3   10.2    -Changed: "The need to invoke the requirements of ANSI N45.2.6 on suppliers ;is evaluated by the
_ Quality Assurance- department and the Nuclear.
Station Engineering Department during the ~ review of; procurement documents for items and services. The-complexity of tha' item and the extent of source and receipt inspection are factors which are considered when determining whether or not to invoke ANSI N45.2.6."                                                               i to: "The need to invoke the requirements - of ANSI N45.2.6       1978      ' Qualification         of      Inspection, Examination,       and Testing Personnel              for Nuclear Power Plants' on suppliers is evaluated during the review of procurement documents for items and                           ,
services.        The complexity of the item and the extent of source and receipt inspection are factors which are considered when determining whether or-not to invoke ANSI N45.2.6. (CCT-8018)"                                 ,
To remove the Nuclear Assessment department - from in-line     review        of     procurement'      documents     'as described in changes to Chapter 4.                     Also leaves discussion          of          responsibilities            to'  the responsibility section.                                                 .
2 of 3  10.2(3)   Removed "IPQA",        the word " periodic", and removed-the responsibility assignment / editorial.
3 of 3  10.3.1.a  Removed      " Develop         and"   from. CPS Plant- Staff responsibilities for implementing a program that                       ,
provides for inspection.              To take credit for the program that has already been developed.                               ,
3 of 3  10.3.2.b   Changed;     " Develop and- implement an inspection program for scheduled ISI program examinations and i
inspections."
to: " Implement an inspection program for scheduled:                   >
ISI    program examinations                and   inspections    and.   ,
perform NDE to support plant operations."
Take credit for developed programs and transfer'NDE to Nuclear Station Engineering.
Y 34 1
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        ~
l IP NUCLEAR PROGRAM'QA MANUAL Revision 24 Matrix of Changes                             l Chapter 10 Page     Para.                   Change / Reason For Change                I l
3 of 3  10.3.3.a. Changed:   " Develop   and   implement    an inspection  '
program for CPS."
to:   " Implement an . inspection progran for . CPS .
excluding Material Receipt, - ISI, . NDE .and Welding Inspeetion. (CCT 8021)"
Take ' credit for inspection program which has been developed and clarify. scope of responsibility.
3 of 3  10.3.3.c. Changed "the" to "an",   editorial.
3'of 3  10.3.3.d. Removed the word " periodic", editorial, 3
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:2 IP NUCLEAR PROGRAM QA MANUAL' Revision 24 Matrix of Changes
          . Chapter'll-Page       Para.                     Change / Reason Far Change p
                        ~
2 of 3     11.3.1.a-   Removed '" Develop and" _ from j the . CPS Plant Staff-            j responsibility for implementing testing programs to take credit for tha proBrams . which have been developed.
3 of 3      11.3.3     Removed    Nuclear   Assessment          responsibility      for-reviewing    and   approving         te s t' . procedures and-
                                                                                           ~
approving test .results.          The quality'. assurance functions   of   assuring.- effectiveness .will :be implemented   in  a performance based               (off-line)-  '
manner as appropriate. while leaving departments performing   a quality _ activity with the- in-line
                                       .cesponsibility for that activity.
3 of 3     ll.3.3.a    Removed the word " periodic", editorial L
4
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IP NUCLEAR PROCRAM QA'MM?UAL-Revision 24 Matrix of Changes Chapter 12 Page-    Para,                     Change / Reason For Change 3 of 3     12.2      Removed    responsibility    assignments     from  this description section, editorial.
3 of 3   12.2(4)     Removed the word " periodic", editorial.                 ,
3 of 3    12.3.1   ' Removed     the     wording     under     Plant   Staff (a)(b)(d)    responsibility to develop programs -and leave only the responsibility for implementation to_ take credit for the programs which have already been developed.
3 of 3    12.-3.2    Removed the Nuclear Assessment . responsibility to review the M&TE control program of suppliers performing. work at CPS. Suppliers performing work''
at CPS are subject to audits and surveillances (per Chapter 7) which verify compliance with the requirements of the CPS M&TE program.                    .
3 of 3   12.3.2a     Removed the word " periodic", editorial.                 >
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37

IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes.
F Chapter 13 tr                                                                                                .
Page     Para.                    Change / Reason For Change 1 of 2   13.2(4)    Removed " document reviews" from the methods used to determine if appropriate procedures and controls are being applied regarding handling, storage _ and                ,
shipping of materials and equipment. To remove the                 '
Nuclear Assessment Department- from' the in-line document review process and clarify that this - is verified during audits .and surveillances.               (CCT-8007)     Also removed the word " periodic" .and-                  .
i responsibility     assignments    from   this     section, editorial.                                                         '
2 of 2    13.3.1    Removed the wording which refers to developing and 13.3.3  programs as these programs .have been developed and currently only require implementation.
2 of 2   13.3.1.b   Removed the word " radioactive", editorial.                    -
2 of 2    13.3.4    Removed    " document   reviews"     from the Nuclear' Assessment responsibility to verify compliance with the requiremencs of ' this chapter.      'To remove - the Nuclear Assessment Department from the in-line document- review process and clarify that this activity is verified by audits and surveillances.
Also rc:aoved the word " periodic", editorial.
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                             . IP EUCLEAR PROGRAM QA' MAtRJAL Revision 24' Matrix of: Changes Chapter 14 Page   Para.                  Change / Reason For Change 1 of 3-  14.1    Changed:    "To    define. the      requirements   and-responsibilities for identifying the- inspection, testing and operational status of materials,' parts,
_                             components and assemblies.-to assure that only items which have passed the required inspections and-tests are installed or. operated."-
to:     "To     define     the-    requirements   ~ and responsibilities for identifying- the -inspection, test and operating status of materials, . parts, components .and assemblies to assure that only items which have passed the required inspection.a' and tests are installed or operated."
                               . Editorial.
2 of 3  14.2b    Changed QA to Quality Assurance, editorial.
2 of 3   14.2    Removed the responsibility assignments froa .this description section, editorial.
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IP NUCIIAR PROGRAM QA MANUAL
,                         Revision 24 Matrix of Changes
  ' Chapter 14                                                                                    '
Page      Para.                      Change / Reason For Change                           :
2 of 3    14.2(2)   Changed; " Quality Assurance is responsible for ' the identification        of     the    inspection      status     'on materials, parts and components.             As imposed by the-        !
contract documents, suppliers performing activities at CPS or furnishing materials, parts, components                      ,
or     assemblies       for     use    at    CPS    also    have responsibilities          for     the     identification        of inspection,      test and operating status of items under their control.            CPS Plant Staff and the - QA-Department review and approve                the programs       of.
suppliers      performing      work at CPS          to   ensure compatibility with           the CPS status          indication system."
to: " Inspection' personnel are responsible for the identification        of    the     inspection _ status        on materials, parts and components. (CCT 7998) . As imposed by        the    contract      documents,     suppliers per forming      activities      at     CPS   or     furnishing materials, parts, components or assemblies for use at     CPS    also have responsibilities for the.
16 itification of inspection, test and operating sta us of items under their control. (CCT 8083)
The programs of suppliers performing work at CPS are reviewed and approved to ensure compatibility-with the CPS status indication system." (CCT 8084)
Recognize that not all inspection personnel report to the Nuclear Assessment department.              Remove the
* Nuclear Assessment department from- the in-line document       review      process      and     clarify     that      '
verification. by Nuclear Assessment is. through audits and surveillances performed in accordance.                    l with     Chapter 7.           Also remove responsibility assignments from this description section.
2 of 3    14.2(3)   Removed the word " periodic", editorial.
2 of 3    14.3.1    Removed the references to developing programs and and 3 of 3  14.3.2     establishing procedures.          It is only necessary to            !
implement the ' established procedures            id developed programs in place currently.
3 of 3   14.3.1.d    Moved the responsibility to implement pror ams' to indicate. status of nonconforming items from .the Quality Assurance Department-to Plant Staff.              Plant Staff     is   responsible      for    the   programs    which indicate status.                                                    '
l 40 l

                             . IP INCLEAR PROGRAM QA MANUAL-Revision 24 Matrix of Chenges Chapter.14.
Page     Para.                      Change / Reason For Change 3 of 3    14.3.3       Removed   the    responsibility   for   reviewing    and approving    programs    of    suppliers    to'   ensure compatibility with the various status indicating systems    from     Nuclear LAssessment _ - as      this responsibility was shared with Plant ' Staff.      (CCT-8084)     The Nuclear- Assessment department will continue to perform audits and surveillances per Chapter 7 to verify this activity.as necessary.
3 of 3    14.3.3       Plant Staff.is responsible 1 for the programs which indicate    status.       Moved. responsibility      for implementing programs       to   indicate    status   of nonconforming ' items from Nuclear Assessment- to Plant Staff to reflect this.
3 of 3    14.3.4       Removed the responsibility 'for - indicating receipt inspection status.       This responsibility way .be performed by another organization in the future.
3 of 3   14.3.4.a. Removed the word " periodic", editorial.
                                                                                          .i J
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IP NUCLEAR PROGRAM QA MANUAL ~
Revision 24 Matrix of. Changes Chapter 15 Page     Para.                      Change / Reason For Change 1 of 4  15.2 (1)c. Replaced      "they"    with      " nonconforming       items",
editorial clarification.
2 of 4  15.2(1)f. Corrected the spacing between the words "for" 'and -
d)      "that".                                                             $
2 of 4    15.2.1    Removed "and reviewed' by the Quality Assurance Department."      after    " Acceptable    alternatives- to original inspection or . test requirements may be used provided they are assessed for adequacy -and the rationale documented."          The quality assurance functions     of   assuring     effectiveness       will' be implemented     in   a performance based (off-line)                ,
manner .as -appropriate while leaving departments performing a quality activity with 'the- in-line responsibility for that activity.             Also added a comma to correct punctuation.
2 of 4     15.2      Removed " Reports documenting nonconforming items                  I are reviewed by the Quality Assurance Department prior     to     closeout-     to    . verify     that      the nonconformances        were       properly       documented, dispositioned,      corrected     and inspection and/or acceptance verification is completed."           The quality       ,
assurance functions of assuring effectiveness will   _
be implemented l in a - performance based (off-line) manner as appropriate while leaving departments performing a : quality- activity with the in-line responsibility for that activity.
3 of 4   15.2(5)     Changed   "the .Vice President - Clinton Power Station" to "the Vice President and-Manager Clinton Power Station"                                                     !
3 of 4   15.2(7)    Removed the word " periodic" and the responsibility assignment, editorial.                                           j, i
3 of 4  15.3.3 b. Changed:    " Evaluate and document,         together with.        l NSED,   the safety significance of nonconforming items."
to: " Coordinate with NSED to ovaluate and document-the safety significance of nonconforming items."
Editorial.
42
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IP NUCLEAR PROGRAM QA MANUAL
  ,-                      Revision 24 Matrix of Changes Chapter 15 Page     Para.                    Change / Reason For Change 3 of 4  15.3.3.c   Changed:     " Develop    and    implement. procedures, irstructions or work control documents for the.
correction of . nonconforming items with repair. or.
rework dispositions."
to: " Develop and implement procedures, instructions or work control documents for the control. and.
correction of nonconforming items with repair 'or.
rework dispositions."
Editorial.
4 of 4   15.3.4    Removed the 'words " Establish and" before Nuclear Support Services' responsibility ~ to implement' an effective     program     -for    processing
* supplier nonecnformance reports.         To take credit for the established program.
4 of 4  15.3.5.a    Removed the words " Establish and" from the Nuclear .
Station ~ Engineering responsibility to implement a program for dispositioning nonconforming items.         To take credit for the established program.
4 of 4  15.3.5.b. Changed:   " Evaluate and document, together -with Plant    Staff,      the    safety    significance    - o f-nonconforming items."
to: " Coordinate with Plant Staff to ' evaluate ~ and document the . safety significance of nonconforming items."
Editorial.
43
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p..
IP NUCLEAR ~ PROGRAM QA MANUAL Revision 24 Matrix of Changes Chapter 15 Page   Para.                   Change / Reason For Change 1
4 of 4  15.3.6  Removed the Nuclear Assessment responsibilities:
                            -Establish and implement a program for verifying acceptable     disposition      .as    required     by    the disposition of nonconformances.                                    '
                            -Establish and implement programs for the review of nonconformances- to- verify effectiveness in meeting the requirements of the chapter.
                            -Perform      review      of     conditional'      release.
justifications.
                            -Ensure    that     procurement      documents     require suppliers to establish a nonconformance program consistent with this chapter.
The   quality     assurance     functions     of    assuring effectiveness will be implemented in a performance based    (off-line)     manner- as      appropriate 'while leaving departments performing a quality -activity with the in-line responsibility for that activity.
The   Nuclear Assessment Department will still perform      periodic        surveillances       'of      the nonconformance programs.
Also    changed:    " Conduct periodic- 'surveillances/
audits of the Nonconformance. Program at. CPS to                 '!
ensure compliance' with the requirements of this chapter."-                                                         ,
to:   " Conduct surveillances- and audits - of the nonconformance control program at CPS to ensure compliance with - the requirements of the IP Nuclear Quality Assurance Program."
Editorial.
i
:i IP~ NUCLEAR PROGRAM QA MANUAL v
: Revision 24-Matrix of Changes Chapter 16 Page    Para.                      Change / Reason-For. Change 1 of 3  16.2(1)    Changed:    " Reporting may be accomplished through various     reporting        documents     a s ._   defined     in documented procedures."
to: "Reportin5 may be accomplished through various reporting documents as defined in procedures."
Editorial.
1 of 3  16.2(2)    Changed:     "The      IP   Quality Assurance ' Department performs trend analysis. on conditions adverse . to. ~
1 plant safety and/or quality to determine if a trend representing a significant condition adverse to plant safety and/or quality exists.                        Nuclear Station Engineering performs             trend analysis . of-conditions documented on maintenance work documents to    identify      equipment     failure    and      reliability concerns."
to:    " Trend analysis is . performed on conditions adverse to plant safety and/or quality to determine                  ;
if a trend representing. significant conditions adverse to' plant safety and/or quality exists. (CCT-8014)     Trend analysis of conditions ' documented on-maintenance work ~ documents - to identify equipment                 ,
failures       and      reliability     concerns         is'  also performed."
To describe the program in the program description section    and       assign- responsibilities            in. the responsibility section and other minor editorial changes.
2 of 3  16.2(4)     Changed: " Corrective action is evaluated by the Quality . Assurance. Department           to      determine    its-e ffec tivene.s s , including steps taken to identify the cause of significant conditions' adverse to                     .
plant safety..."
to: " Corrective action = is evaluated to determine-its    effectiveness,        including    steps        taken "to identify     the .cause       of   significant ' conditions adverse to plant safety..."
This change         removes    responsibilities        assignment' from the program description section'.                              '
45

IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix.of Changes Chapter 16~
Page     Para.                    Change / Reason For Change 2 of 3     16.3    ' Removed reference to established trend analysis programs    and   renumbered     sections   accordingly.
Trend analysis is just one of the tools used . to .           '
evaluate the effectiveness of the corrective' action.
program. Remove unnecessary details from ' Quality     '
Assurance Manual; 2 of 3   16.3.2.a   Removed   " Establish    and"   in   the .beginning    of sentence. describing      the     Nuclear    Program-Departments' responsibility for implementing .a corrective action procedure (s)...
3 of 3   16.3.4.b. Removed the word " periodic", editorial.
1:
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IP NUCLEAR PROGRAM QA MANUAL'
'd.
Revision 24 Matrix of. Changes Chapter-17 Page        Para.                        Change / Reason For, Change                                  )
_. f 1 of 2-and     '17.2      Removed' responsibility          assignments       from       this 2 of 2-               description section, editorial.
2 of 2      17.2(5)     Removed the word " periodic",-editorial.
2 of 2      17.3.1.b    Removed the capital letters from the words1Quility~                            l Assurance, corrected ~ department ' title, removed : the                       ;
word    " maintenance"      and added      a- comma       to    the sentence, editorial,                                                            ,
2'of 2      17.3.3.a    Removed       the     word      " periodic"      .and.       added              '
                                    "surveillances and", editorial.
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IP WUCLEAR PROGRAM QA' MANUAL
   .                       Revision 24 Matrix of Changes Chapter 18' Page      Para.                    Change / Reason For Change                  ,
       ' 1 of 3   18.2(1)   Changed: "The IP Quality Assurance organization'has the responsibility 'for implementing the QA audit program. The audit program provides for the followin5:"
to: "The audit program provides for the following:"
Editorial.
                                                                                        'i 1 of 3   18.2(1)b   Changed: " Additionally, QA program . audits include indoctrination and training' programs; interface control between IP, the-audited organizations and           t other affected organizations; USAR commitments; and Technical Specification requirements."
to:    " Additionally,     program     audits   include indoctrination and training programs;         interface between IP audited organizations and other affected         ;
organizations;    USAR    commitments; _and   Technical Specification requirements. (CCT 8105)" Editorial.
2 of 3   18.2(1)k. Changed "re-audits" to "re-audit", editorial.
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                        'IP NUCLEM PROGRAM QA MANUAL-
                        -Revision 24 Matrix of Changes                                  !
Chapter 18 Page    Para.                     Change / Reason For Change I
2 of 3- 18.2(2)   Changed: .      "Within      the-     Quality'   Assurance organization,      the Supervisor - Audits has the-responsibility for maintaining' and implementing an audit plan which verifies that applicable elements          -
of -the     Quality     Assurance program have- been developed,      documented,       and    implemented    in accordance with the - requirements of this manual.
Audits will be initiated as early ' in the life of the activity as practicable consistent with the schedule for accomplishing the activity to assure timely implementation _ of the quality assurance requirements.      The plan =is' reviewed periodically to insure that it is current and may be- augmented ' at        :
any time based on recommendations from the' Nuclear Review and Audit Group,             or. Nuclear Program personnel as the scope of work and .other                   :
requirements for auditing an activity change."
to: " Audits are initiated as early in the life of the activity as possible _ consistent with the schedule for accomplishing the activity to assure timely      implementation of the quality assurance requirements. (CCT 1433)         Audits may be augmented at any time based on recommendations from the Nuclear Review and Audit Group, or Nuclear Program personnel as the scope of work and other requirements for auditing an activity change. (CCT 1434)"
Editorial / manual simplification, remove unnecessary detail from the QA Manual.                                  ,
2 of 3 18.2(4)     Changed:    "IP management obtains an independent-audit of the IP Quality Assurance organization on an annual basis."
to: "IP management obtains independent. audits of the IP Nuclear Assessment. organization."
To remove commitment to audit annually and audit' biennially, which is consistent with Regulatory Guide 1.33 Quality Assurance Program requirements          1 (Operations).
3 of 3  18.3.3    Moved     responsibility      for     Independent    Safety Engineering     Group    to   the Nuclear Assessment organization. Organization change.
49

                   ..          . .. _           _.           _        .-          ,-_ _        ,  4 - - . .     .   -- , , . . - .
I IP NUCLEAR PROGRAM QA MANUAL Revision 24 Matrix of Changes
-              - Appendix A?                                                                                                          ,
Page          Para-                           _ Change / Reason For Change
                                                                                                                                    'i NA               NA         The former Appendix" Af " Revisions .to " the ' IP' Nuclear J                   .?
Program- Quality ' Assurance Manual": was d' eleted - to -
simplify. the manual as . the revision , of . the ' manual is    addressed in' Chapter 2 and implementing:-
procedure QAP-102-02.        This Appendix L was ' replaced :
                                                                                                              ~
with the new Appendix A " Glossary of Terms".
A-3 of 10    Examina-             Changed " gaging" to " gauging".,' editorial.
tion A-3 of 10   Hold Point Changed "the Quality Verification :section1 (QV)y of.
the Quality Assurance : department" ~ to " inspection.
personnel".. and- changed       "QV"     to       ."inspec tion -
personnel".      To remove wording ' which - implies _. that; all inspection personnel . report            to' the Nuclear-Assessment department.
A-C of 10      Receipt            Removed " performed by' Quality Assurance- Inspectors ,                           l Inspection verifying                that     the"  and    replaced with             "which'.
verifies that" because _ receipt inspectors _ may be'.
                                                                                             ~
                                                   - transferred to another department, in the future.
A-10 of 10  Verifica-             Changed " Quality . Verifica tion (QV)" to._ " inspection tion /        personnel".          To   re move -- implication. that -all"
-                             Inspection            inspection personnel report to Nuclear Assessment..                               '
Point
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4.
* IP HUCLEAR PROGRAM QA MANUAL Revision'24 Matrix,of Changes Appendix B Page    Para.                   Change / Reason For Change B-6 of 12  NA      Corrected reference : to . Chapter 16 applicability to the' security plan.
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