ML18066A912

Rev 17 to Quality Program Description for Operational Npps.

ML18066A912
Person / Time
Site:	Palisades
Issue date:	02/01/1997
From:	Fenech R, Joos D, Nicholson R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18066A911	List: ML18066A910 ML18066A912
References
NUDOCS 9703180228
Download: ML18066A912 (87)

Text

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Description for Operational NU.clear Power Plants CPC-2A . -BIG ROCK POlllT NUSRDES

• ONLY ( 9703180228 970307* PDR ADOCK 05000255 P PDR

• ]NFORMATION ONLY --***-*-----*-. _...a A CMS Energy Company 212 West Michigan Avenue Jackson. Mt 49201-2277 Te/:517 7881111 Fax: 517 788 0180 Michael G. Morris President ancJ Chief Executive Officer February 1, 1997

SUBJECT:

ST A TEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMPANY QUALITY PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As President and Chief Executive Officer of Consumers Power Company, I have the ultimate management authority for the Com:umers Power Company Ouality Program Description for Operational Nuclear Power Plants. The Quality Program Description complies with the quality assurance requirements contained in Appendix B of 10 CFR 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds additional guidance contained in ANSI N18. 7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context.of applicability imposed by N18.7. The Quality Program Description for Operational Nuclear Power Plants outlines the actions that are implemented during the operational phase including fueling, testing, operation, refueling, procurement, maintenance, repair, and modification design and construction of the safety-related portions of the nuclear power plants. I have delegated responsibility for establishing, maintaining and implementing the Quality Program Description through the Executive Vice President and Chief Operating Officer-Electric to the Vice President, Nuclear Operations.

I have delegated selected portions of the Quality Program to the Vice PreSident, Fossil and Hydro Operations; Vice President, Electric Transmission and Distribution; Vice President, Information Technology and Operations Services Division; and through a Vice Chairman of Consumers Power Company to the Vice President and Secretary.

This Quality Program Description describes the Consumers Power Company organizations responsible for implementation.

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

• APPROVED BY: QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS REVISION 17 nd Chief Operating Officer -Electric Vi e President, Information Technology n K. C. Emery . ...-I / ./ l , .P /*7 -:< "' .. :J L ..... ...? Vice President and Secretary T. A. McNish ........... , Page ii Rev 17 Date: February 1, 1997 /-5'a-'17 Date /-J/..-9 7 Date Date l/JJ/77 ; Date /-dJ>-97 Date Section 1,.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0

• 17.0 18.0 QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS CONTENTS Title Statement of Responsibility and Authority Approval Page Contents Page iii Rev 17 Date:February 1, 1997 ii iii ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 QUALITY PROGRAM .........

• -** . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 DESIGN CONTROL ........................... : . . . . . . . . . . . . .

16 PROCUREMENT DOCUMENT CONTROL . . . . . . . . . . . . . . . . . . . . . . . . .

19 INSTRUCTIONS, PROCEDURES AND DRAWINGS ...................

21 DOCUMENT CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

25 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES ..... 26 IDENTIFICATION AND CONTROL OF ITEMS ......................

29 CONTROL OF SPECIAL PROCESSES . . . . . . . . . . . . . . . . . . . . . . . . . . .

30 INSPECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

31 TEST CONTROL ... *. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

34 CONTROL OF MEASURING AND TEST EQUIPMENT . . . . . . . . . . . . . . . . .

36 . HANDLING, STORAGE AND SHIPPING . . . . . . . . . . . . . . . . . . . . . . . . . .

38 INSPECTION, TEST AND OPERATING STATUS . . . . . . . . . . . . . . . . . . . .

39 NONCONFORMING MATERIALS, PARTS OR COMPONENTS

...........

40 CORRECTIVE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

42 QUALITY RECORDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

43 AUDITS ......................

• .........................

45

• Page iv Rev 17 Date:February 1, 1997 APPENDIX A .........................................................

47 APPENDIX B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

73 APPENDIX C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

77 APPENDIX D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

80 APPENDIX E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

81 FIGURES 1 Consumers Power Company Corporate Organization . . . . . . . . . . . . . . . . . . . . . . . . .

10 2 Nuclear Operations Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

11 Page 1 Rev 17 Date: February 1, 1997 1 .0 ORGANIZATION 1.1 POLICY Consumers Power Company (CPCo) is responsible for establishing and implementing the Quality Program, as described herein, for the operational phase of its nuclear power plants. Although authority for development and execution of some parts of the program is delegated to others, such as contractors and consultants, CPCo retains overall responsibility.

This of the Quality Program Description (QPD) identifies the CPCo organizations responsible for activities affecting the of safety-related nuclear power plant structures, systems and components and describes the authority and duties assigned to them. It addresses responsibilities for attaining quality objectives; for establishing and maintaining the Quality Program; and for assessing the performance of activities affecting the quality of safety-related items. The control of this Quality Program Description is the responsibility of the Nuclear Performance Assessment Department.

Nuclear Performance Assessment Department (NPAD) functions (audits, surveillances, and independent safety reviews) are performed by personnel within formally designated

• organizational units that report to the Manager, Nuclear Performance Assessment or

• members of other organizations as selected by the Manager, Nuclear Performance Assessment.

The reporting level of the Nuclear Performance Assessment organization affords sufficient authority and organizational freedom, including sufficient dence from the cost and schedule impacts of Nuclear Assessment organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions

.. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph 1.2.1 1.2.2 1.2.2.c Exceptions/Interpretations 2a 2g 2, 2b, 2c 1.2 IMPLEMENTATION 1.2.1 Source of Authorjty CPC-2A.R17 The President and Chief Executive Officer (see Figure 1 of Company Organization Charts) of CPCo is responsible for safe operation of CPCo nuclear power plants. Authority and responsibility for establishing and implementing the Quality Program for plant operations, maintenance and modifications is delegated through the Executive Vice Presid1;mt and Chief Operating Officer -Electric to the Vice President

-Nuclear Operations.

This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer. Other quality-related functions are provided by other organizations as described herein.

Page 2 Rev 17 Date: February 1, 1997 1.2.2 Responsibilitv for Attajning Quality Objectives in the Nuclear Operations Oraanization CPC-2A.R17 The Vice President

-Nuclear Operations is responsible to the Executive Vice President and Chief Operating Officer -Electric for operation and maintenance of CPCo nuclear power plants. Managers who report to the Vice President, NOD, are responsible for directing the performance of activities that affect safe plant operation and/or related functions of structures, systems and components of the operating nuclear power plants in accordance with Quality Program requirements.

a. The Palisades Plant General Manager (see Figure 2) is responsible to the Vice President, Nuclear Operations for operation and maintenance of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable regulations and the Quality Program. The Plant General Manager delegates to appropriate managers and staff personnel in his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed on the authority of the Plant General Manager include: Qualification of plant operating, inspection and maintenance personnel, including certification of inspection personnel.

Preparation, review and approval of plant procedures and instructions.

Modifying components, including procurement, installation, inspection and testing activities when assigned by the Plant General Manager; Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits . . Maintaining Echelon Ill calibration*

facilities'for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE).

Calibration/maintenance of installed plant instrumentation.

Maintaining a calibration recall system. Maintaining a Master List for plant-owned PL-M&TE. Performing start-up and operational testing, such as precritical and criticality tests, low-power, power ascension and plant tests, and surveillance testing. Maintaining equipment status control. Maintaining required controls over chemical standards arid reagents.

Developing, maintaining and implementing site emergency plan. Conducting a water chemistry program in accordance with technical specifications.

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

• CPC-2A.R17 Page 3 Rev 17 Date: February 1, 1997 Plant site inspection program, including inspection of maintenance, testing and fuel handling.

Assuring that nonconforming items are identified, segregated and dispositioned.

Procurement of nuclear fuel and associated services, including source verification at fuel supplier facilities, fuel inspection upon delivery and review of fuel supplier quality-related documentation Reactor engineering such as accident-transient and physics analysis of reloads, reactor core and nuclear fuel design and core thermal-hydraulic and nuclear support of plant modifications and operations.

Development and utilization of nuclear plant probabilistic safety assessment models to evaluate safety and plant reliability improvement Establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program indoctrination and training.

Conducting the inservice inspection program in accordance with technical specifications and State of .Michigan rules. .. Performing reviews to advise the Plant General Manager on matters related to nuclear safety, as specified in Appendix B, Plant Review Committ<<;ie.

-b. The Big Rock Point Plant Manager (see Figure 2) is responsible to the Vice President, Nuclear Operations for operation and maintenance of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable regulations and the Quality Program. The Plant Manager delegates to appropriate

• managers and staff personnel in his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed on the authority of the Plant Manager incl_ude:

Qualification of plant operating, inspection and maintenance personnel, including certification of inspection personnel.

Preparation, review and approval of plant procedures and instructions.

Functioning as the plant design and configuration control authority for compliance of plant modifications and design changes to existing plant design criteria.

Modifying components, including procurement, installation, inspection and testing activities when assigned by the Plant Manager. Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits.

CPC-2A.R17 Page 4 Rev 17 Date: February 1, 1997 Maintaining Echelon Ill calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE).

Calibration/maintenance of installed plant instrumentation.

Maintaining a calibration recall system. Maintaining a Master List for plant-owned PL-M& TE. * . Performing start-up and operational testing, such as precritical and criticality tests, low-power, power ascension and plant tests, and surveillance testing. Maintaining equipment status control. Maintaining required controls over chemical standards and reagents.

Conducting a water chemistry program in accordance with technical specifications.

Stopping unsatisfactory work.to control further processing, delivery or installation of nonconforming materials or items. Plant site inspection program, including inspection of maintenance,.

testing and fuel handling.

Preparation, review, and approval of Q-list updates. Assuring that nonconforming items are identified, segregated and dispositioned.

Reactor*engineering such as accident-transient and physics analysis of reloads, reactor core and nuclear fuel design and core thermal-hydraulic and nuclear

• support of plant modifications and operations.

Establishing, implementing and documenting the training of nuclear operations and technical support personnel, including Quality Program indoctrination and training.

Development and utilization of nuclear plant probabilistic safety assessment models to evaluate safety and plant reliability improvement.

Procurement, including preparation, reviews and approval of purchase requests for spares, replacement items, consumables, and materials, items and services and submittal of purchase requests to Purchasing.

Planning and execution of vendor source surveillance or inspection, receiving inspection, and review of supplier quality.:related documentation, as well as vendor surveys for urgent procurements.

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

Accomplishing plant licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or tracking licensing

• CPC-2A.R17 Page 5 Rev 17 Date: February 1, 1997 commitments and coordinating internal action on NRC bulletins, generic letters, etc. Providing evaluation, processing and status reporting for assigned corrective action documents, including determination of NRC reportability.

Operating experience reviews including NRC Information Notices. Performing the engineering, construction, inspection and testing associated with generating plant modification projects as assigned.

Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules. Developing, maintaining and implementing security, fire protection and emergency plans. Performing reviews to advise the Plant Manager on matters related to nuclear safety, as specified in Appendix B, Plant Review Committee.

c. The Manager, Nuclear Performance Assessment Department, (see Figure 2) is responsible for: Assessment of the effectiveness of the Nuclear Operations Quality Program. Performance of the offsite safety review functions for the nuclear power plants as . described in Appendix C, Independent Safety Review. Supplier surveys and evaluation including review/approval of supplier QA programs;

• and maintenance of the NOD Approved Suppliers List. Preparation, review, approval and implementation of departmental procedures governing nuclear assessment activities.

Assessment of nuclear safety performance as described in the Technical Specifications.

• . Assuring that assessments are done by personnel not directly responsible for the work being performed.

Recommending to the Plant General Manager/Managers or the Vice President, Nuclear Operations that a plant be shut down if such action appears necessary.

Assessment programs (plant sites and Corporate Office), including follow-up on corrective action for audit findings.

Review of performance trends associated with NOD activities including corrective actions .

CPC-2A.R17 Page 6 Rev 17 Date: February 1, 1997 Analysis of new and/or changed regulatory direction, codes and standards to determine their effect on the Quality Program. Maintenance of the Quality Program Description for Operational Nuclear Power Plants. Reporting audit findings relative to follow-up on corrective actions and the effectiveness of the Quality Program to CPCo Management.

Maintenance/operation, processing and status reporting of the corrective action system (Palisades only). In order to implement these responsibilities, the Manager, NPAD, is provided with "Stop Work" authority whereby he can suspend any quality related activity or process which may, in his opinion, adversely affect public safety or the safe operation of Consumers Power nuclear plants. A Stop Work order that would result in plant shutdown is given as a recommendation

-NRC licensed operating staff are responsible for determining and carrying out the safest course of actions. The Manager, Nuclear Performance Assessment has no other primary duties or .. responsibilities unrelated to Nuclear Performance Assessment that would prevent

• his attention to Nuclear Performance Assessment matters, is sufficiently free from . schedule and cost pressures to give appropriate weight to quality _considerations in his decisions and recommendations, _and has direct access to' high enough levels of Management to obtain resolution of quality problems.

d. The General Manager, Nuclear Services (see Figure 2) is responsible for designated activities in support of the Palisades Plant:

• Preparing, reviewing, approving and implementing procedures for activities carried out by the department.

• Accomplishing plant licensing activities including*

maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or tracking licensing commitments and coordinating internal action o_n_ NRC bulletins, generic letters,*

etc. Providing determination of NRC reportability for corrective action documents.

Operating experience reviews including NRC Information Notices.

Functioning as the design and configuration control authority for compliance of plant modifications and design changes to existing plant design criteria.

This includes preparing, reviewing and approving changes to plant engineering/design documents.

Performing the engineering, procurement, construction, inspection and testing associated with generating plant modification projects as assigned.

.*. *

• 1.2.3 CPC-2A.R17 Page 7 Rev 17 Date: February 1, 1997 Providing, as requested, technical expertise and review capability to Nuclear Operations in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil-structural engineering and application of codes and standards.

Preparation, review* and approval of Q-list updates. Performing analytical studies to appraise the adequacy of electrical supply to safety-related equipment in nuclear power plants from the principal power supply facilities of the transmission network and onsite power supply. Procurement, including preparation, reviews and approval of purchase requests for spares, .replacement items, consumables, and materials, items and services and submittal of purchase requests to Purchasing.

Planning and execution of vendor source surveillance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.

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

Developing, maintaining and implementing security and fire protection plans. Maintaining the Records Management System including required retention, protection and retrievability.

This includes collecting, storing, maintaining, distributing and controlling plant engineering/design Resoonsibilitv for Attaining Quality Objectives in Fossil and Hydro Operations . The Vice President, Fossil and Hydro Operations (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer*-Electric.

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

• a. The Manager, Equipment Services provides electrical, rotating and stationary equipment expertise, including developing and qualifying procedures for welding and heat treating.

b. The Director, Fuel Supply & Plant Operations maintains the Records Management System including required retention, protection and retrievability*.'

This includes collecting, storing, maintaining, distributing and controlling plant engineering/design documents (Big Rock only). This excludes Big Rock Safeguards information documents, which are maintained at Big Rock. The accuracy, quality, and correctness of Big Rock. documents in the Records Management System are the responsibility of Big Rock Point.

Page 8 Rev 17 Date: February 1, 1997 1.2.4 Responsjbility for Attajnjnq Qualjtv Objectives Outsjde Nuclear Operations and Fossil and Hydro Operations CPC-2A.R17 Certain functions that constitute part of the Nuclear Operations Quality Program are performed by CPCo organizational units outside the Nuclear Operations Department or Fossil and Hydro Operations.

Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization

• responsible for that activity (i.e., the design authority).

a. The Manager, Electric System Operations (see Figure 1) is responsible through the Vice President, Electric Transmission and Disbribution to the Executive Vice President and Chief Operating Officer -Electric for determining settings for electrical protective systems and relay control schemes, and for design, review and recommending changes to electrical protective schemes and associated settings.

b. The Director, Electric Employee Development (see Figure 1) is responsible to the Executive Vice President and Chief Operating Officer -Electric for operating the Skill Centers including*the training, and qualifying of personnel and equipment for welding operations.

c. The Corporate Records Administrator (see Figure. 1) is responsible through the Vfoe President and Secretary for microfilming of specified quality records and plant engineering/design documents.

d. The Manager, Environmental and Techni9al Services (E&TSl is responsible, through the Vice President, Information Technology and Operations Services to the President and Chief Executive Officer.for:

Maintaining the Company's Echelon II calibration facility for calibrating reference

• and secondary standards and general usage portable and laboratory measuring and test equipment

.. Controlling the calibration recall system for Portable and Laboratory M& TE owned by E&TS, and other*departments, as requested.

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

Providing a PL-M&TE Inventory List for Nuclear Operations.

Providing chemistry support to *Nuclear Operations, as requested.

Preparing, reviewing, approving and obtaining additional reviews and approvals if required, of purchase requests for services, equipment and consumables, and submitting such requests to purchasing for procurement action. Conducting performance tests on materials, equipment and systems when requested.

• CPC-2A.R17 Page 9 Rev 17 Date: February 1, 1997 Performing nondestructive examination, and controlling/maintaining NOE equipment.

Providing qualified NOE procedures and equipment and NOE personnel.

Providing chemical and metallurgical analytical services.

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

e. The Manager, Electric Services is responsible, through the Vice President, Electric Transmission and Distribution to the Executive Vice President and Chief Operating Officer -Electric for testing and maintaining electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associated settings.

CPC-2A.R17 Page 10 Rev 17 Date: February 1, 1997

., * .,. CPC-2A.R17

• , Page 11 Rev 17 Date: Febr,uary 1, 1997 Page 12 Rev 17 Date: February 1 , 1997 2.0 QUALITY PROGRAM 2.1 POLICY 2.2 2.2.1 2.2.2 2.2.3 CPC-2A.R17 Policies that define and establish the Consumers Power Company (CPCo) Quality Program for Operational Nuclear Power Plants are stated in the individual sections of this document.

The program is implemented through procedures and instructions responsive to provisions of the Quality Program Description and will be carried out for the life of each plant. Quality controls apply to activities affecting the quality of safety-related structures, systems and components, to an extent based on the importance of those structures, systems, or components to safety. Such activities are performed under suitably controlled conditions, including the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that all applicable prerequisites have been met. Quality Program status, scope, adequacy and compliance with 10 CFR 50, Appendix B are regularly reviewed by CPCo Management through reports, meetings and review of audiUesults.

A preplanned and documented assessment of the nuclear safety performance is conducted as described in Appendix C.

• The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph 2.2.3 2.2.S 2.2.6 . 2.2.9 2.2.10 IMPLEMENTATION . Exceptions/lnteroretations 20a, 20.b 19a 1 , 18a, 20a, 20b 2j, 4a, Sa, Sb, 6a, 7b, 1 Oa, 11 a, 12a, 12b, 12c, 12d, 13a, 17e

• 2e, 2f The President of Consumers Power Company, as.Chief Executive Officer, has stated in a formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy to comply with the provisions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10 CFR SO, Appendix B. The statement makes this Quality Program Description and the associated implementing procedures and instructions mandatory and requires compliance by all responsible organizations and individuals.

It identifies the Management positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness.

The Quality Program at CPCo consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION).

The effectivity and applicability of this Quality Program Description are as follows: **

• 2.2.4 Page 13 Rev 17 Date: February 1, 1997 a. . For Big Rock Point and Palisades, the Quality Program Description became effective on April 1, 1982, with full implementation.

on January 1 , 1983. b. The Quality Program described in this Quality Program Description is intended to apply for the life of CPCo's nuclear power plants. c. The Quality Program applies to activities affecting the quality of safety-related structures, systems, components and related consumables during plant operation, maintenance, testing and all modifications.

Those activities having a direct impact on safety-related items shall be controlled.

Safety-related structures, systems, components and related consumables are identified in Q-Lists, which are developed and maintained for each plant in accordance with the criteria of Regulatory Guide 1.29 as clarified by Items-No.

20a and No. 20b in Part 2 of Appendix A to this Quality Program Description.

This Quality Program Description, organized to present the CPCo Quality Program for Operational Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states CPCo policy for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this Quality Program Description that do not reduce the .commitments previously accepted by the NRC must be submitted to the . NRC at least annually.

Any changes made to this Quality Program Description that do* reduce the .commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation.

The submittal of the changes described above shall be made in accordance with.the requirements of 10.CFR 50.54 . -The program described -in this Quality Program Description will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B. 2.2.5 Documents used for implementing the provisions of the Quality Program Description include the following:

2.2.6 a. Administrative procedures specify the standard methods of accomplishing operational phase activities.

Because the Quality Program is an integral part of the operational phase activities, the methods for implementing Quality Program controls are integrated into these documents.

b. When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50, Appendix B and the contract, and are approved by CPCo prior to the start of work. c. Applicable elements of the operations Quality Program are applied to emergency plans, security plans, radiation and fire protection plans for CPCo nuclear power plants. These plans describe quality controls applicable to associated equipment and activities.

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

CPC-2A.R17

2.2.8 C--PC-2A.R17 Page 14 Rev 17 Date: February 1, 1997 Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which CPCo commits. Appendix A also describes necessary exceptions and clarifications to the requirements of those documents.

The scope of the program and. the extent to which its controls are applied are established as follows:*

a. CPCo uses the criteria specified in Regulatory Guides 1 .26 and 1 .29 in engineering evaluation of an item's function in relation to safe operation and shutdown to identify structures, systems and components to which the Quality Program applies (See Appendix Al. b. This identification by engineering personnel results in the classification of equipment as either safety related or non-safety related, and the inclusion of this classification in an equipment data base. This data base is available for inquiry by individuals involved in plant operation.

The classification of structures, systems and consumables is also identified, documented, and controlled.

c. The extent to which controls specified in the Quality Program are applied to items is determined for each item considering its relative importance to safety. Such determinations are based on data in such documents as the plant safety analysis, plant Technical Specifications and the FSAR/FHSR (See Appendix Al. Activities affecting the quality of safety-related items are accomplished under controlled.

conditions.

Preparations for such activities include confirmation that prerequisites have been met, such as: a. Assigned personnel are qualified.

b. Work has been planned to the proper revisions of applicable engineering and/or technical specifications.

c. Specified equipment and/or tools, if any, are on hand to be used. d. Materials and items are in an acceptable status. e. Systems or structures on which work is* to be performed are in the proper condition for the task. f. Authorized current instructions/procedures for the work are available for use. g. Items and facilities that could be damaged by the work have been protected, as required.

h. Provisions have been made for special controls, processes, tests and verification methods. Development, control and use of computer programs affecting nuclear power plant design and operation at CPCo are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).

• 2.2.9 Page 15 Rev 17 Date: February 1, 1997 Responsibility and authority for planning and implementing indoctrination and training are specifically designated in the CPCo organization (see Section 1.0, ORGANIZATION).

a. The training and indoctrination program provides for ongoing training and periodic refamiliarization with the Quality Program for Operational Nuclear Power Plants. b. Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.58, SNT TC-1A, or the ASME Code, or Section 10.2.3 of this Quality Program Description, as applicable.

c. Personnel who lead audits are qualified in accordance with Regulatory Guide 1.146. Others are either qualified to ANSI N45.2.23 or have detailed expertise in the area being audited. d. Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with applicable

codes, and regulatory guides. e. The training/qualification program for personnel leading audits includes provisions for retraining, reevaluation and recertification to ensure that proficiency is maintained. ,f. Training and qualification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the personnel involved are performing activities to which the training/qualification is relevant.

g. Personnel responsible for performing activities that affect quality are instructed as to the requirements identified in applicable quality related manuals, instructions and procedures.

2.2. 10 Status and adequacy of the quality program are regularly assessed by CPCo ment. The following activities constitute formal elements of that assessment:

a. *Audit reports, including follow-up on corrective action accomplishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT). b. Management teams assess the nuclear safety performance as described in Appendix C. Conclusions and recommendations are reported to the Executive Vice President and Chief Operating Officer -Electric.

Corrective actions in response.

to recommendations are. tracked in the regular corrective action tracking system (see Section 16.0, CORRECTIVE ACTION) . CPC-2A.R17 Page 16 Rev 17 Date: February 1, 1997 3.0 DESIGN CONTROL 3.1 POLICY Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled.

Depending on the type of modification, these activities include design and field engineering; the performance of physics, seismic, stress, thermal, hydraulic, radiation and Safety Analysis Report (SAR) accident analyses; the development and control of associated computer programs; studies of material compatibility; accessibility for inservice inspection and maintenance; and determination of quality standards.

The controls apply to preparation and review of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: paragraph 3.1 3.2.9 3.2.10 Exceptjons/lnteroretations 9a, 13b 15a 13d 3.2 IMPLEMENTATION 3.2.1 Authority and responsibility for modification activities is under the cognizance of the Nuclear Operations Department as described in Section 1.0, ORGANIZATION.

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

a) System descriptions; bl Design input and criteria; cl Drawings and specifications; and d) Engineering analyses and associated computer programs.

3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect structures, systems and com.ponents are . documented.

Action is taken to assure that the errors and deficiencies are corrected . . 3.2.3 Materials, parts and processes that are essential to safety-related functions are selected and specified, based on the requirements of applicable codes and standards or on known, successful use under similar conditions.

This includes standard commercial materials, parts and processes.

Alternatively, materials; parts and processes may be qualified for use through qualification testing (see Item 3.2.8). The adequacy of the selected materials, parts and processes is assured through the required design *verifications or approvals.

3.2.4 Exceptions and waivers to or deviations from the engineering (quality) standards (i.e., the required dimensions, material properties, features and other characteristics specified for modifications) are required by procedure and by contract, when applicable, to be documented and controlled. (See, also, Section 15 concerning the approval of "repair" or "use as is" dispositions of nonconformances.)

CPC-2A.R17

• 3.2.5 3.2.6 3.2.7 3.2.8

• CPC-2A.R17 Page 17 Rev 17 Date: February 1, 1997 When modifications involve design interfaces between internal or external design organizations or across technical disciplines, these interfaces are controlled.

Procedures are used for the review, approval, release, distribution and revision of documents involving design interfaces to ensure that structures, systems and components are compatible geometrically, functionally and with processes and environment.

Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses.

Decisions and problem resolutions involving design interfaces are made by the CPCo organization having responsibility for engineering direction of the design effort. Checks are performed and documented to verify the dimensional accuracy and completeness of design drawings and specifications (i.e., the products of a design process).

Modification design document packages are reviewed by either Plant Engineering personnel or by Nuclear Engineering and Construction personnel to assure that the documents that they contain have been prepared, verified, reviewed and approved in accordance with Company procedures and that they contain the necessary quality requirements.

These requirements include the inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results. The extent of and methods for design verification are documented.

The extent of design verification performed is a function of the importance of the item to safety, design complexity, degree of standardization, the state-of-the-a11 and similarity with previously proven designs. Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews. These methods may be used singly or in combination, depending on the needs for the design under consideration.

When design verification is done by evaluating standardized .or previously proven designs, the applicability of such designs is confirmed.

Any differences from the proven design are documented and evaluated for the intended application.

Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated.

This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function.

Qualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented.

Results are evaluated to assure that test requirements have been satisfied.

Modifications shown to be necessary through testing are made, and any necessary retesting or other verification is performed.

Scaling laws are established and verified, when applicable.

Test configurations are clearly documented.

Design reviews are performed by multi-organizational or interdisciplinary groups or by single individuals.

Criteria are established to determine when a formal group review is required and when review by an individual is sufficient .

3.2.9 Page 18 Rev 17 Date: February 1, 1997 Unless otherwise stated, the verification of design addresses all information conveyed by the design document.

When the verification is limited to certain areas or features, the scope or extent and any limitations on the verification are documented.

Persons representing applicable technical disciplines are assigned to perform design verifications.

These persons are qualified by appropriate education or experience but are not directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that: ( 1) He is the only technically qualified individual available, and (2)

• He has not specified a singular design approach, ruled out certain design considerations or established the design inputs for the particular design aspect being verified, and (3) His review is either: a. Approved in advance by the supervisor's management, with documentation of the approval included in the design package, or b. Controlled by a procedure which provides specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification.

Independent audits by Nuclear Performance Assessment cover the frequency, tiveness, and technical adequacy of the use of supervisors as design verifiers to guard. against abuse. 3.2.10 When designs must be released for use before they have been fully completed or before they have been verified, the incomplete or unverified parts of the design and the hold point to which work may proceed are This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function.

Justification for suqh early release is documented.

3.2. 11 -Computer codes used in design are appropriately documented, verified, certified for use and controlled.

Their use is specified.

3.2. 12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original design. Such changes are evaluated for impact. Those that affect fit, form, or function are reviewed and approved by the same, or equivalent, organizations that approved the original design. Information on approved changes is transmitted to all affected organizations.

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• • * *

• Page 19 Rev 17 Date: February 1, 1997 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 POLICY Procurement documents for safety-related structures, systems, components and services define the characteristics of item(s) to be procured, identify applicable regulatory and industry codes/standards requirements and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph 4.2.1 4.2.3 4.2.5 Exceptions/Interpretations 17c, 17d 21, 17a, 17b 17d 4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement planning and for preparation, review and approval of procurement documents are delineated in Section 1 .0, ORGANIZATION.

4.2.2 4.2.3 Procurement request packages are reviewed and approved prior to submittal to the Purchasing and Materials Department.

Review includes verification that the necessary quality requirements are specified.

The responsible project engineer performs bid evaluations . .Supplier selection is described in Section 7.0, CONTROL OF PURCHASED MATERIALS,, EQUIPMENT AND SERVICES.

The contents of procurement documents vary according to the item(s) being purchased and its function(s) in the plant. Provisions of this Quality Program Description are considered for application to suppliers.

As applicable, procurement documents include: a. Scope of work to be performed.

b. Technical requirements, with applicable drawings, specifications, codes and standards identified by title, document number and revision and date, with any required procedures such as special process instructions identified in such a way as to indicate source and need.

• c. Regulatory, administrative and reporting requirements.

d. Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections.

e. A requirement for a documented Quality Program, subject to CPCo review and written concurrence prior to the start of work . CPC-2A.R17 4.2.4 4.2.5 CPC-2A.R17 Page 20 Rev 17 Date: February 1, 1997 f. A requirement for the supplier to invoke applicable quality requirements on subtier suppliers.

g. Provisions for access to supplier and subtier suppliers' facilities and records for inspections, surveillances and audits. h. *Identification of documentation to be provided by the supplier, identification of documents to be compatible with the records system, the schedule of submittals and identification of documents requiring CPCo approval.

Trained, qualified personnel perform and document reviews of procurement request packages to assure that: * \ a. Quality requirements

{see 4.2.3 of this Section) are correctly stated, inspectable, and controllable.

b. Adequate acceptance and rejection criteria are included.

c. The procurement documents have been prepared, reviewed, and approved per the Quality Program requirements.

Changes to the technical or quality requirements in procurement documents are controlled in a manner commensurate with that used for the original requirements.

Those that could affect fit, form, function or the necessary assurance of quality are reviewed and approved by the same, or equivalent, organizations_

that approved the original procurement request packages.

• • *-*

• Page 21 Rev 17 Date: February 1, 1997 5.0 INSTRUCTIONS, PROCEDURES AND. DRAWINGS 5.1 POLICY 5.2 Activities affecting the quality of safety-related structures, systems and components are accomplished using instructions, procedures and drawings appropriate to the circumstances which include acceptance criteria for determining if an activity has been satisfactorily completed.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paraqraoh 5.1 5.2.8 5.2.14 IMPLEMENTATION Exceptions/lnteroretations 9a, 13b 2r, 2s, Sa 6b The authority and responsibility for performing activities affecting the quality of safety-* related structures, systems and components are assigned as described in Section 1 .0, ORGANIZATION.

Management personnel assigned tl)ese responsibilities assure that the instructions, procedures and drawings necessary to accomplish the activity are prepared and implemented.

Instructions, procedures and drawings incorporate ( 1) a description of the activity to b.e accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and/or qualitative (such as workmanship standards) acceptance sufficient to determine that the activity has been satisfactorily accomplished.

Temporary procedures may be* issued to provide management .instructions which have short-term applicability.

Temporary procedures include a designation of the time period during which they may be used, The procedures used by CPCo to control its activities include the following: 1 . Administrative Procedures.

2. System procedures that describe the operation of the plant. 3. Start-up procedures that provide for starting the reactor from hot or cold condition and recovering from reactor trips. 4. Shutdown procedures that provide for controlled reactor shutdown or shutdown following reactor trips. 5. Power operation and load changing procedures that provide for steady state power operation and load changing, including response to unanticipated load changes . CPC-2A.R17 CPC-2A.R17 Page 22 Rev 17 Date: February 1, 1997 6. Process monitoring procedures that provide for monitoring plant system performance and which, as appropriate, identify limits for significant process parameters.

7. Fuel-handling-procedures that provide for activities such as: a. Core alterations

b. Refueling

c. Fuel accountability

d. Receipt and shipment of fuel e. Nuclear safety measures 8. Maintenance procedures that provide for: a. Preparation for maintenance

b. Performance of maintenance

c. Post-maintenance and operability checks and tests d. Use of supporting maintenance documents

9. Radiation control procedures that provide for: --a. Implementation of the radiation control program* including the acquisition of radiation data b. Identification

'of equipment for performing radiation surveys c. Measurement, evaluation and assessment of radiation hazards 10. Calibration ahd test procedures that provide for: a. Periodic calibration and testing of safety-related instrumentation and control systems b. Calibration of portable measuring and test equipment used in activities affecting safety 11. Chemical-radiochemical control procedures that provide for activities including:

a. Sampling and analyses b. Maintenance of coolant quality c. Control of deleterious agents **

• CPC-2A.R17 Page 23 Rev 17 Date: February 1, 1997 d. Control, treatment and management of radioactive wastes e. The control of radioactive calibration sources 12. Emergency procedures that provide guidance for: a. Operations during potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate action he should take b. Identifying symptoms of emergency conditions

c. Monitoring automatic action d. Immediate operator action e. Subsequent operator action 13. Emergency Plan Implementing Procedures

14. Inspection, test and examination procedures that identify:

a. Objectives

b. Acceptance criteria c. Prerequisite and special conditions

d. Limiting conditions

e. Test or inspection instructions

f. Any required special equipment or calibration

g. Hold and Witness points, as appropriate 1 5. Modification procedures that provide for: a. Administrative control and technical support during plant modifications

b. The basis for a consistent method of performing recurring engineering, construction and quality activities c.. Control of the interfaces between CPCo and its suppliers

d. Offsite management control e. Control of onsite quality-related modification activities that assure the Quality Program is implemented and its effectiveness is assessed and reported Page 24 Rev 17 Date: February 1, 1997 6.0 DOCUMENT CONTROL 6.1 POLICY 6.2 6.2.1 6.2.2 CPC-2A.R17 Documents controlling safety-related activities within the scope defined in Section 2.0, QUALITY PROGRAM are issued and changed according to established procedures.

Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for release prior to implementation by authorized personnel*

and are distributed and used at the location where a prescribed activity is performed.

• Changes to controlled documents are reviewed and approved by the same organizations that performed the original review and approval or by other qualified, responsible organizations specifically designated in accordance with the procedures governing these documents.

• Personnel authorized to approve procedures specified by plant Technical Specifications are limited to: 1. For Palisades, an appropriate senior department manager, based on the activities addressed in the specific procedure, predesignated in writing by the Plant General Manager; or 2. For Big Rock Point, the Plant Manager. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD: Paragraph 6.1 6.2.3 IMPLEMENTATION Exceptions/lnteroretations 2h, 2n 2h, 2n, 2s, 1 2b The authority and responsibility for the control of documents are described in Section 1.0, ORGANIZATION.

Control.s are established for approval, issue and change of documents in the following categories:

a. Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes b. As-built drawings (record drawings) and related documents

c. Procurement documents

• 6.2.3 6.2.4 ** 6.2.5 6.2.6 CPC-2A.R17 Page 25 Rev 17 Date: February 1, 1997 d. Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test and plant maintenance and operation which implement the Quality Program. e. Final Safety Analysis Report/Final Hazards Safety Report f. Reports of nonconformances

g. Plant Technical Specifications The review, approval, issue and change of the above documents are controlled by: a. Establishment of criteria to ensure that adequate technical and quality requirements are incorporated.

b. Identification of the organizations responsible for review, approval, issue and revision.

c. Review of changes to documents by the organizations designated in accordance with the procedure governing the review and approval of specific types of documents, including quality aspects. Controlled documents are issued and distributed so that: a. The documents are available at the work location prior to cqmmencing work b. Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner . Master lists or equivalent controls are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents.

When master lists. are used they are updated and distributed to designated personnel who are responsible for maintaining current copies of the lists. Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.

Page 26 Rev 17 Date: February 1, 1997 7 .0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 POLICY 1.2* 7.2.1 7.2.2 7.2.3 e-PC-2A.R17 Activities that implement approved procurement requests for safety-related material, equipment and services are controlled to assure conformance with procurement document requirements.

Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance.

Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant site prior to reliance on equipment, material or services for nuclear safety. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph 7.1 7.2.3 7.2.5 7.2.6 IMPLEMENTATION Exceptions/I nteroretations 2i 7b, 17e 2m, 7e, 17f 2m, 9b, 13c, 13d, 17f Authority and responsibility for implementing the controls outlined herein are described . in Section 1.0, ORGANIZATION.

CPCo qualifies suppliers by performing a documented evaluation of their capability to provide items or services specified by procurement documents.

To remain qualified, suppliers involved in active procurements are reevaluated annually and are audited triennially.

If an audit is acquired from an *external source, the audit is evaluated prior to its use. Supplier evaluation and triennial audits are not necessary when the items or services supplied are all of the following:

a. Relatively simple and standard in design, manufacture and test, and b. Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery, and c. Such that receiving inspection does not require operations that could adversely affect the integrity, function or cleanness of the item. In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service. Supplier activities that affect quality are verified in accordance with written procedures.

These procedures provide the method of verifying (such as audit, surveillance or *

• 7.2.4 7.2.5 7.2.6 CPC-2A.R17 Page 27 Rev 17 Date: February 1, 1997 inspection) and documenting that the characteristics or processes meet the requirements of the procurement document.

For commercial "off-the-shelf" items where the requirements for a specific quality assurance program appropriate for nuclear applications cannot be imposed in a practical manner, source verification is used to provide adequate assurance of acceptability unless the quality of the item can be adequately verified upon receipt. Spare and replacement parts are procured in such a manner that their performance and quality are at least equivalent to those of the parts that will be replaced.

a. Specifications and codes referenced in procurement documents for spare or replacement items are at least equivalent to those for the original items or to properly reviewed and approved revisions.

b. Parts intended as spares or replacements for "off-the-shelf" items, or other items for which quality requirements were not originally specified, are evaluated for performance at least equivalent to the original.

c. Where quality requirements for the original items cannot be determined, requirements and controls are established by engineering evaluation performed by qualified individuals.

The evaluation assures there is no adverse effect on

• interfaces, interchangeability, safety, fit, form, function, or compliance with applicable regulatory or code requirements.

Evaluation results are documented.

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

Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with safety-related procurement requirements not previously verified by source surveillance or inspection and that required supplier furnished documentation is available.

Items inspected are identified as to their acceptance status prior to their storage or release for installation.

Suppliers are required to furnish the following records: a. Applicable drawings and related engineering documentation that identify the purchased item and the specific procurement requirements (e.g., codes, standards, and specifications) met by the item. b. Documentation identifying any procurement requirements that not been met. c. A description of those nonconformances from the procurement requirements dispositioned "accept as is" or "repair. n d. Quality records as specified in the procurement requirements.

The acceptability of these documents is evaluated during source and/or receipt inspection.

7.2.7 CPC-2A.R17 Page 28 Rev 17 Date: February 1 , 1997 Supplier's certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure that they are valid. The results of these evaluations are documented.

• *

• 8.0 8.1 IDENTIFICATION AND CONTROL OF ITEMS POLICY Page 29 Rev 17 Date: February 1, 1997 Safety-related materials, parts and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD: Paragraph 8.2.2 8.2.3 Exceptions/lnteroretatjons 7d, 7g 7a 8.2 IMPLEMENTATION 8.2.1 Controls are established that provide for the identification and control of materials (including consumables), parts and components, (including partially fabricated assemblies).

Responsibility for the identification and control of items is .described in Section 1.0, ORGANIZATION.

8.2.2 8.2.3 Items are identified by physically marking the item, its storage area or its container or by maintaining records traceable to the item. The method of identifjcation is such that the quality of the item is not degraded.

Items are traceable to applicable drawings, specifications, or other pertinent documents to ensure that only correct and acceptable items are used. Verification of, traceability is

• performed and documented prior to release for fabrication, assembly, or installation . CPC-2A.R17 Page 30 Rev 17 Date: February 1 , 1997 9.0 CONTROL OF SPECIAL PROCESSES 9.1 POLICY Special processes affecting safety-related structures, systems, and components are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph Exceptions/lnteroretations 9.2.1 6c, 13e 9.2 IMPLEMENTATION 9.2.1 Processes subject to special process controls at CPCo are those for which full verification or characterization by direct inspection is impossible or impractical.

Such processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement, and nondestructive examination.

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

9.2.3 .. Special process procedures are prepared by personnel with expertise in the discipline involved.

The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.

9.2.4 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations.

Certification is based on examination results. Personnel qualification is kept current by performance of the special process(es) and/or reexamination at time intervals specified by applicable codes, specifications, and standards.

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

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

9.2.6 Qualification records are maintained in accordance with Quality Program Description Section 17. 9.2. 7 The Nu.clear Assessment Department audits/assesses special process activities, including qualification activities to assure they are satisfactorily performed.

CPC-2A.R17

• *

• 10.0 10.1 10.2 10.2.1 INSPECTION POLICY Page 31 Rev 17 Date: February 1, 1997 Activities affecting the quality of safety-related structures, systems, and components are inspected to verify their conformance with requirements.

Inspections are accomplished by independent verification or process monitoring as necessary.

Verification points are used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: . Paragraph 10.2.2 10.2.3 10.2.7 10.2.10 IMPLEMENTATION Exceptjons/lnteroretations 2p, 2q 2j, 6a 2j, 6a 2j Organizational responsibilities are as described in Section 1.0, ORGANIZATION.

10.2.2 Inspections are applied to procurement, maintenance, testing, fuel handling, and inservice -inspection to verify that items and activities conform to specified requirements.

Work authorizing documents (e.g.; procedures, instructions, maintenance work orders) are reviewed in accordance with established criteria to do the following as necessary:

a. Determine the need for inspection(s).

b. Identify the inspection organization or personnel.

c. Identify independent verification points. d. Determine how and when the inspections are to be performed.

e. Specify measuring and test equipment of the necessary accuracy for performing inspection.*

f. Provide for documentation of inspection results to provide adequate objective evidence of acceptability.

Independent verification is performed at each operation where it is necessary to verify conformance with requirements.

Process monitoring is used in whole or in part where direct inspection alone is impractical or inadequate . CPC-2A.R17 Page 32 Rev 17 Date: February 1, 1997 10.2.3 Training and qualification programs for personnel who perform inspections, including nondestructive examination, are established, implemented, and documented in accordance with Section 2.0, QUALITY PROGRAM, and plant or offsite procedures.

These programs meet the requirements of applicable codes and standards.

The Plant General Manager/Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility.

For activities performed at Palisades that are under the cognizance of Nuclear Services, the Manager, Nuclear Projects and Construction is responsible for review and concurrence of such programs.

Training and qualification programs for E&TS personnel who perform inspections, including nondestructive examination, are documented in E& TS procedures.

Training and qualification programs for System Maintenance and Construction Services (SM&CS) personnel who perform inspections are documented in SM&CS procedures.

Qualifications and certifications of inspection and NOE personnel are maintained.

10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists*

and are either provided or concurred with by the organization that performs the

• inspection planning.

They (procedures, etc) provide for the following as appropriate:

a. Identification of applicable revisions of required instructions, drawings and specifications.

b. Identification of characteristics and activities to be inspected.

c. Inspection methods (independent verification or process *monitoring).

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

e. Identification of personnel responsible for performing the inspection.

f. Acceptance and rejection criteria.

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

10.2.5 Independent verification points are designated when confirmation is needed that critical characteristics are acceptable before _the work can be allowed to proceed further. Independent verifications are performed, and work is released for further processing or use, by assigned verification personnel.

Independent verification points may be waived only by the organization that performs the inspection planning.

10.2.6 Independent verifications are performed and documented in accordance with the written instructions provided.

The results are evaluated by designated personnel in order to ensure that the results substantiate the acceptability of the item or work. Evaluation and review results are documented.

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• **

• * "* Page 33 Rev 17 Date: February 1, 1997 Independent verification should be designated when the activity/task being verified is necessary to ensure critical characteristics are in conformance with requirements and/or the verification is result of codes, standards, regulations, or commitments.

10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:

a. Qualifications of the independent verifier are equal to or better than the minimum qualifications for persons who can be authorized to perform the task; and b. The work is within the skills of CPCo personnel-and/or is addressed by CPCo procedures.

c. If work involves breaching a pressure retaining item, the quality of the work can be demonstrated through a functional test. When a, b, and c are not met, inspections will be out by individuals certified in accordance with ANSI N45.2.6. The verification is performed by individuals other than the person(s) performing or directly supervising the work. 10.2.8 For independent verification, when acceptance criteria are* not met, corrected areas are to be reverified.

Results of independent verification are documented and retained for the purposes of performance trending and analysis.

10.2.9 The independent verifier has the authority to stop work if inspection criteria are not met. Resolution of disagreements between the verifier and worker is resolved by plant management.

10.2.10 Contractors may be used as independent verifiers in accordance with Section 10.2. 7 provided:

a. The work is performed using the. CPCo Quality Program and procedures.

b. Individuals are trained and qualified in accordance with Section 10.2.3. Otherwise, contractors must be certified to ANSI N45.2.6 to perform inspections.

CPC-2A.R17 Page 34 Rev 17 Date: February 1, 1997 11 .0 TEST CONTROL 11.1 POLICY 11.2 11.2.1 Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems, and components will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria.

The test program includes qualification (as applicable), acceptance, pre-operational, start-up, surveillance, and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions are specified and met. Test results are documented and evaluated.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD: Paragraph.

Exceptions/lnteroretations 11.2.2 2k, 17g IMPLEMENTATION Organizational responsibilities for testing are described in Section 1.0, ORGANIZATION.

11.2.2 Tests are performed in accordance with programs, procedures, afld criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

• a. Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0, DESIGN CONTROL. b. Acceptance tests of equipment and components to assure their proper operation prior to delivery or to pre-operational tests. c. Pre-operational tests to assure proper and safe operation of systems and equipment prior to start-up tests or operations.

d. Start-up tests, including precritical, criticality, low-power, and power ascension tests, performed after refueling to assure proper and safe operation of systems and equipment.

e. Surveillance tests to assure continuing proper and safe operation of systems and equipment.

f. Maintenance tests after preventive or corrective maintenance.

11.2.3 Test procedures and instructions include provisions for the following, as applicable:

CPC-2A.R17

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

• * *

• CPC-2A.R17 Page 35 Rev 17 Date: February 1, 1997 b. Test prerequisites such as calibrated instrumentation, adequate test equipment, and instrumentation including accuracy requirements, completeness of the item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storage. c. Instructions for performing the test. d. Mandatory inspection hold points for witness by the appropriate authority.

e. Acceptance and rejection criteria.

f. Methods of documenting or recording test data. and results. g. Assuring that test prerequisites have been met. h. Verification of completion of modification activities.

Test procedures and instructions are reviewed for technical content and quality aspects, by the plant engineering organization, or the offsite technical organization, as applicable When acceptance criteria are not met, corrected areas are to be retested .

Page-36 Rev 17 Date: February 1, 1997 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 POLICY 12.2 12.2.1 Measuring and testing equipment used in activities affecting the quality of safety-related systems, components and structures are properly identified, controlled, calibrated, and adjusted at specified intervals to maintain accuracy within necessary limits. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD: Paragraph 12.2.3 12.2.4 12.2.5 12.2.8 IMPLEMENTATION Exceptjons/lnteroretatjons 2o,9c 2o, 9c 10c 10b The authority and responsibility of personnel establishing, implementing and assuring effectiveness of calibration programs is described in Section 1.0, ORGANIZATION.

12.2.2 Procedures are established for measuring and test equipment utilized in the measurement, inspection and monitoring of structures, components.

These procedures describe calibration technique and frequency and maintenance and control of the equipment.

12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration source. 12.2.4 CPCo uses a system of labels to be attached to measuring and test equipment to display the next calibration due date. Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date. 12.2.5 Measuring.

and test equipment (M&TE) and installed plant instrumentation is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

CPC-2A.R17 Calibration of M& TE is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and the basis of acceptance is documented and authorized by responsible management.

Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being calibrated.

Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements.

The basis for this acceptance is documented and is approved by responsible management . * * *

• Page 37 Rev 17 Date: February 1, 1997 12.2.6 Calibrating standards have greater accuracy than standards being calibrated.

Calibrating standards with the same accuracy may be used if it can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible management.

12.2. 7 Reference and transfer standards are traceable to nationally recognized standards; where national standards do not exist, provisions are established to document the basis for calibration.

12.2.8 When measuring and testing equipment used for inspection and test is found to be outside of required accuracy limits at the time of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration.

The results of evaluations are documented.

Retests or reinspections are performed on suspect items . CPC-2A.R17 Page 38 Rev 17 Date: February 1, 1997 13.0 HANDLING, STORAGE AND SHIPPING 13.1 POLICY 13.2 13.2.1 Activities with the potential for causing contamination or deterioration that could adversely affect the ability of a safety-related item to perform its intended safety functions, and activities necessary to prevent undetected or uncorrectable damage are identified and controlled.

These activities include cleaning, packaging, preserving, handling, shipping, and storing. Controls are effected through the use of appropriate procedures and instructions implemented by suitably trained personnel.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph Exceptions/lnteroretations 13.2.2 7a, 7c, 7d, 7f, 7g, 7h IMPLEMENTATION The authority and responsibility of personnel implementing and assuring the effectiveness of material cleaning, handling, storing, pack-aging, preserving, and shipping activities is described in Section 1.0, ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storing, preserving, and shipping of materials, components and systems in accordance with design and procurement requirements.

These procedures include, but are not limited to, the following functions:*

CPC-2A.R17

a. *Cleaning, to assure that required cleanliness levels are achieved and maintained.

b. Packaging and preservation, to provide adequate protection against damage or deterioration.

When necessary, these procedures provide for special environments such as inert gas atmospheres, specific moisture content levels, and temperature levels. c. Handling, to preclude damage or safety hazards. d. Storing, to minimize the possibility of loss, damage to or deterioration of items in storage, including consumables such as chemicals, reagents, and lubricants.

Storage procedures also provide methods to assure that specified shelf lives are not exceeded.

• *

• • Page 39 Rev 17 Date: February 1 , 1997 14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 POLICY 14.2 14.2.1 Operating status of safety-related structures, systems, and components is indicated by tagging of valves and switches, or by other specified means, in such a manner as to prevent inadvertent operation.

The status of inspections and tests performed on individual items is clearly indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests. The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the OPD: Paraqraoh 14.1 14.2.5 IMPLEMENTATION Exceptions/lnteroretatjons 2r 2i Organizational responsibilities are as described in Section 1.0, ORGANIZATION.

14.2.2 For modification activities, inc.luding item fabrication, installation and test, procurement documents, service contracts, and procedures specify the degree of control required for the indication of inspection and test status of structures, and components.

14.2.3 Application and removal of inspection and welding stamps and of such status indicators as tags, markings, labels, etc, are controlled by procedures.

14.2.4 The *sequence of inspections, tests and other operations important to safety are controlled by procedures.

Changes in the approved sequence are subject to the same review and approval as the original, or as specified in administrative procedures if the original organization no longer exists. 14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems, and components is clearly identified and documented to prevent inadvertent use. CPC-2A.R17 Page 40 Rev 17 Date: February 1, 1997 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 15.1 POLICY Safety-related materials, parts, or components that do not conform to requirements are controlled in order to prevent their inadvertent use. Nonconforming items are identified, documented, segregated when practical, and dispositioned.

Affected organizations are notified of nonconformances The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraoh Exceptions/lnteroretations 15.1 2i 15.2 IMPLEMENTATION 15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which render the quality unacceptable or indeterminate, are identified as nonconforming and any further use is controlled.

Nonconformances are documented and dispositioned, and notification is made to affected organizations.

Personnel authorized to disposition, conditionally release, and close out nonconformances are designated.

The authority and responsibility for the implementation of activities related to the processing and control of nonconforming materials, parts, _or components are described in Section 1.0, ORGANIZATION.

a. Nonconforming items are identified by marking, tagging, or segregating or by documented administrative controls.

Documentation describes the

• nonconformance, the disposition of the nonconformance and the inspection requirements.

It also includes signature approval of the disposition.

b. The original inspection planning authority reviews the disposition of nonconformances, and documents concurrence with the acceptance, conditional release or repair of a nonconforming item. c. Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the original inspection planning authority.

d. Items that have the disposition of "repair" or "use as is" require documentation justifying acceptability.

The changes are recorded to denote the as-built condition.

15.2.2 Dispositions of conditionally released items are closed out before the items are relied upon to perform safety-related functions.

15.2.3 Prior to the initiation of preoperational testing on an item, all nonconformances are corrected or dispositioned and evaluated for impact upon the item or the testing program. CPC-2A.R17

,, * * *

• 15.2.4

• CPC-2A.R17 Page 41 Rev 17 Date: February 1, 1997 Nonconformance reports are analyzed to identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management for review and assessment .

Page 42 Rev 17 Date: February 1, 1997 16.0 CORRECTIVE ACTION 16.1 POLICY Conditions adverse to quality of safety-related structures, systems, components, or activities, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconformances are identified promptly and corrected as soon as practical.

For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude repetition.

In these cases, the condition, cause and corrective action taken is documented and reported to appropriate levels of management for review and assessment.

16.2 IMPLEMENTATION 16.2.1 The responsibility and authority for the control of corrective action are described in Section 1.0, ORGANIZATION.

16.2.2 Controls are established to assure that conditions adverse to quality are identified and. documented and that appropriate remedial action is taken. 16.2.3 For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded.

Corrective action includes determining the cause and extent of the condition, and taking appropriate action to preclude problems in the future. The controls also assure that corrective action is implemented in a timely manner. CPC-2A.R17

• 17 .0 QUALITY RECORDS 17.1 POLICY Page 43 Rev 17 Date: February 1, 1997 Records that furnish evidence of activities affecting the quality of safety-related structures, systems and components are maintained.

They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraph 17.1 17.2.5 17.2.8 17.2 IMPLEMENTATION Exceptions/lnteroretations 14b 14c 14a, 14c 17 .2.1 Responsibilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION.

17 .2.2 Documents that furnish evidence of activities affecting quality are generated and controlled in accordance with the procedures that govern those Upon completion, these documents are considered records. These records include: a. Results of reviews, inspections, surveillances, tests, audits, and material analyses b.

• Qualification of personnel, procedures, and equipment

c. Operating logs d. Maintenance and modification procedures and related inspection results e. Reportable occurrences

f. Records required by the Plant Technical Specifications

g. Nonconformance reports h. Corrective action reports i. Other documentation such as drawings, specifications, procurement documents, calibration procedures, and reports 17 .2.3 Inspection and test records contain the following where applicable:

a. A description of the type of observation CPC-2A.R17

b. The date and results of the inspection or test c. Information related to conditions adverse to quality d. Inspector or data recorder identification

e. Evidence as to the acceptability of the results f. Action taken to resolve any discrepancies noted Page 44 Rev 17 Date: February 1, 1997 17 .2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times. Permanent records are maintained for the life of the item. Appendix E identifies retention periods for certain specific records. 17 .2.5 Temporary storage of completed documents during processing to become records is in special fire-resistant file cabinets.

17 .2.6 Only authorized personnel may issue corrections or supplements to records. 17 .2. 7 Traceability between the record: and the item or activity to which it applies is provided.*

17.2.8 CPC-2A.R17 Records are stored in remote, dual facilities to prevent damage, deterioration, or loss due to natural or unnatural causes. Records that can only be stored as originals, such as radiogi"aphs and some strip charts are retained in a four-hour

{ire-rated-facility . * * *

• 18.0 AUDITS 18.1 POLICY Page 45 Rev 17 Date: February 1, 1997 A comprehensive system of audits is carried out to provide independent assessment of performance and effectiveness of the Quality Program to achieve nuclear safety, including those elements of the program implemented by suppliers and contractors.

Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are documented and are reviewed by management.

Follow-up action is taken where indicated.

The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Paragraoh 18.2.2 18.2.3 18.2.9 18.2 IMPLEMENTATION Exceotions/lnteroretations 3a, 3b, 16a, 16b 16c 2e 18.2.1 Responsibility and authority for the audit program is described in Section 1.0, ORGANIZATION.

18.2.2 Internal audits are performed in accordance with established schedules that reflect the. status and importance to safety of the activities being performed.

Audits are conducted in accordance with frequencies stated in Appendix D, Audit Frequencies.

18.2.3 Audits of suppliers and contractors are scheduled based on the status and safety importance of the activities being performed as well as performance of the suppliers and contractors and are initiated early enough to assure effective quality during design, procurement, manufacturing, construction, installation, inspection, and testing. 18.2.4 Principal contractors are required to audit their suppliers based on performance and on a schedule based on the status and safety importance of the activities being performed.

Such audits shall be initiated early enough to assure an effective Quality Program on the part of their suppliers.

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

18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities and items, and review of documents and records to confirm that the Quality Program is effective and properly implemented.

18.2. 7 Audit procedures and the scope, plans, checklists, and results of individual audits are documented . CPC-2A.R17 Page 46 Rev 17 Date: February 1, 1997 18.2.8 Personnel selected for auditing assignments have experience or are given training commensurate with the needs of the audit and have no direct responsibilities in the areas audited. 18.2.9 Audit data are analyzed by the Nuclear Performance Assessment Department.

The resulting audit reports identify any quality deficiencies and assess the effectiveness of the Quality Program in the area audited. The reports are distributed to the responsible management of both the audited and auditing organizations.

18.2.10 Management of the audited organization identifies and takes appropriate corrective action to correct observed deficiencies and to prevent recurrence of any significant conditions adverse to quality. Follow-up for internal audits is performed by the Nuclear Performance Assessment Department to ensure that appropriate corrective action.is taken and is effective.

Such follow-up includes re-audits when necessary.

For Vendor Audits, such follow-up shall be performed by the organization performing the audit . CPC-2A.R17

• *

• QPD MANUAL APPENDIX A. PART 1 Page 47 Rev 17 Date: February 1, 1997 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Power Company Quality Program complies with the regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2. I. Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. 2. 10 CFR, Part 50.55a -Codes and Standards.

3. Regulatory Guide 1 .8 -(9/80 Draft) -Personnel Qualification and Training -Endorses ANSI/ANS 3.1 -(12/79 Draft). 4. Regulatory Guide 1.26 -(2/76, Rev 3) -Quality Group Classification, and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants .. 5. Regulatory Guide 1.29 -(9/78, Rev. 3) -Seismic Design Classification.

6. Regulatory .Guide 1 .30 (Safety Guide 30) -(8/11 /72) -Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Equipment

-Endorses ANSI N45.2.4 -1.972. 7. Regulatory Guide 1 .33 -(2/78, Rev 2) -Quality Assurance Program Requirements (Operation)

-Endorses ANSI N 18. 7 -1976. 8. Regulatory Guide 1 .37 -(3/16/73)

-Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants -Endorses ANSI N45.2. 1 -1973. 9. Regulatory Guide 1.38 -(5/77, Rev 2) -Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for water-Cooled Nuclear Power Plants -Endorses ANSI N45.2.2 -1972. 10. Regulatory Guide 1.39 -(9/77, Rev 2) -Housekeeping Requirements forWater-Cooled Nuclear Power Plants -Endorses ANSI N45.2.3 -1973. 11. Regulatory Guide 1 .58 -(9/80, Rev I) -Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel

-Endorses N45.2.6 1978. 12. Regulatory Guide 1.64 -(6/76, Rev 2) -Quality Assurance Requirements for the Design Of Nuclear Power Plants -Endorses N45.2.11 -1974. 13. Regulatory Guide 1. 74 -(2/74) -Quality Assurance Requirements Terms and Definitions

-Endorses ANSI N45.2.10 -1973 . CPC-2A.R17 Page 48 Rev 17 Date: February 1, 1997 14. Regulatory Guide 1 .88 -( 10/76, Rev 2) -Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records -Endorses N45.2.9 -1974. 15. Regulatory Guide 1.94 -(4/76, Rev 1) -Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -Endorses ANSI N45.2.5 -1974. 16. Regulatory Guide 1 .116 -(5/77) -Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems -Endorses ANSI N45.2.8 -1975. 17. Regulatory Guide 1 .123 -(7 /77, Rev 1) -Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants -Endorses N45.2.13 -1976. 18. Regulatory Guide 1 .144 -(9/80, Rev I) -Auditing of Quality Assurance Programs for Nuclear Power Plants -Endorses N45.2.12 -1977. 19. Regulatory Guide 1 .146 -(8/80) -Qualification of Quality Assurance program Audit Personnel for Nuclear Power Plants -Endorses N45.2.23 -1978. 20. Branch Technical Position ASB9.5.1 (Rev 1) Guidelines for Fire Protection for Nuclear Power Plants. 21. 10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, Sections Ill G., Ill J. and Ill 0. 22. ANSI/ANS 3. 1-1987, Selection, Qualification, and Training of Personnel for Nuclear Power. Plants application.

limited as described in Appendix C of this document).

CPC-2A.R17

• *

• QPD MANUAL APPENDIX A. PART 2 Page 49 Rev 17 Date: February 1, 1997 CPCO EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES 1. General Requirement Certain Regulatory Guides invoke or imply Regulatory Guides and standards in addition to the standard each primarily endorses.

Certain ANSI Standards invoke or imply additional standards.

Exceptjon/lnteroretation The CPCo commitment refers to the Regulatory Guides and ANSI Standards specifically identified in Appendix A, Part 1. Additional Regulatory Guides, ANSI Standards, and similar documents implied or referenced in those specifically identified are not part of this commitment.

Imposition of these Regulatory Guides on CPCo suppliers and subtier_ suppliers will be on a case-by-case basis depending upon the item or service to be procured.

2. N18.7 General Exceptjon/lnteroretation Consumers Power Company has. established an organizational unit, Nuclear Performance Assessment Department, for independent review activities.

The standard numeric and qualification requirements may not be met by the Nuclear Performance Assessment Department staff. Procedures will be established to specify how NPAD will acquire necessary expertise to carry out its review responsibilities in accordance with Appendix C, Independent Safety Review. 2a. N18.7, Sec 3.4.2 Requirement "The Plant Manager shall have overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."

• CPC-2A.R17 Exception/Interpretation Page 50 Rev 17 Date: February 1, 1997 Since CPCo has more than one nuclear unit and more than one organization providing services to these units, overall responsibility cannot be centralized in a single on-site position.

Instead, responsibilities are as designated within the Quality Program Description.

2b. N18.7,Sec4.3.I Requirement "Personnel assigned responsibility for independent reviews shall be specified in both number and technical disciplines and shall collectively have the experience and competence required to review problems in the following areas: ... " Exceotion/lnteroretation The Nuclear Performance Assessment Department will not have members specified by number or by technical disciplines and its members may not have the experience and competence required to review problems in all areas listed in this section; however, the Nuclear Performance Assessment Department will function as described in Appendix C, Independent Safety Review, and will acquire the services of personnel having such experience and competence as necessary.

2c. N18.7, Sec 4.3.4 Requirement "The following subjects shall be reviewed by the independent review body:" . Exception/I nteroretation Subjects requiring review will be as specified in Appendix C, Independent Safety Review. 2d. fil..al., Sec 4.3.4(3) CPC-2A.R17 Requirement Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is identical to *a previously reviewed proposed change. Exceptjon/lnteroretation The Nuclear Performance Assessment Department will not review Technical Specification Changes after NRC approval prior to implementation.

The basis for this position is that all Technical Specification changes are reviewed prior to submittal to the NRC. -.

Page 51 Rev 17 Date: February .1 , 1997 2e. .M1JL.1., Sec 4.5 Requirement Written reports of audits specified in ANSI NIB. 7 shall be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited. Exception/Interpretation The Nuclear Performance Assessment Department shall review or arrange for reviews of those audits over which it has cognizance, in accordance with Appendix C, Independent Safety Review. Some of the audits required during the operational phase are in areas other than those requiring independent review in accordance with ANSI NIB. 7, Section 4.3.4. 2f. !ilU, Sec 4.5 Requjrement Periodic review of the audit program shall be performed by the independen't review body or by a management representative at least semiannually to assure that audits are being accomplished in accordance with requirements of technical and of this standard.

Exception/lnteroretatjon Audits of operational nuclear safety related facility activities are performed under the cognizance of the Nuclear Performance Assessment Department as described in Appendix C, Independent Safety Review. 2g. N1 B.7. Sec 5.2.I CPC-2A.R17 Requjrement "The responsibilities and authorities of the plant operating personnel shall be delineated." Exception/lnteroretatjon On-site personnel not directly associated with operating activities, as defined in ANSI NIB. 7, Section 2.2, are not considered to be operating personnel.

Page 52 Rev 17 Date: February 1, 1997 2h. Sec 5.2.2 Requirement "Temporary changes, which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures.

At least one of these individuals shall be the superviso.r in charge of the shift and hold a senior operators license on the unit affected." Exception/Interpretation CPCo considers that this requirement applies only to procedures identified in Plant Technical Specifications and to Security and Emergency Plans implementing procedures.

Temporary changes to these procedures may be made provided:

a. The intent of the original procedure is *not altered; b. The change is approved by two members (or designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator License; and c. The change is documented, subsequently reviewed by the PRC within 30 days of issuance and approved by:

• 1 . Appropriate*

senior Palisades department manager predesignated by the Plant General Manager; or 2. The Big Rock Point Plant Manager. Determination of the appropriate senior Palisades department manager is based on the , activities addressed in the specific procedure, and will be predesignated in writing* by the Palisades Plant General Manager. 2i. N18.7, Sec 5.2.6 CPC-2A.R17 Requirement "In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14 .. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions." Exceptjon/lnteroretatjon CPCo initiates appropriate corrective action when it is discovered that documentary evidence does not exist for a test or inspection which is required to verify equipment acceptability.

This action includes a technical evaluation of the equipment's operability status.

Page 53 Rev 17 Date: February 1, 1997 2j. filLJ, Sec 5.2. 7 Requirement The following standards contain useful guidance concerning design and construction-related activities associated with modifications and shall be applied to those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during initial plant design and construction:

American National Standard Installation, Inspection and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power Generation Station, N45.2.4-1972 (IEEE 336-1972)

[6]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, N45.2.5-1974*

[7]; American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973

[5]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for Construction Phase of Nuclear Power Plants, N45.2.8-1975

[8]; American National Standard Quality Assurance Requirements for the Design of Nuclear Power Plants, N45.2.11 1974 [9]; and American National Standard Quality Assurance for Protective Coating Applied to Nuclear Facilities N101 .4-1972 [ 10] .. Considerable care is required in assessing which operational phase activities are comparable in nature and extent to activities normally associated with design and construction.

Exception/Clarification

-Work that is within the skills of CPCo personnel and is covered by CPCo procedures may be inspected by independent verifiers in accordance with Section 10.2.3 and 10.2. 7 and 10.2.10, rather than ANSI N45.2.6. 2k. .tilJL.1., Sec 5.2.8 CPC-2A.R17 Requirement "A surveillance testing and inspection program ... shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections.

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

Page 54 Rev 17 Date: February 1 , 1997 21. N18.7, Sec 5.2.13.1 Requirement "To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 -1971. n Exception/lnteroretation To the extent necessary, procurement documents require that the supplier have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.

2m. N18.7, Sec 5.2.13.2 Requirement ANSI NIB. 7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at. the nuclear power plant site prior to installation or use of such items. Exceptjon/lnterpretatioO The required documentary evidence is available at the site prior to but not necessarily prior to installation.

This aUows installation to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

2n. N18.7, Sec 5.2.15 CPC-2A.R17 Requirement Plant procedures shall be reviewed by an individual knowledgeable in.the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable.

Exception/I nteroretatio n Consumers Power has in place programmatic procedure preparation, review and usage controls that ensure procedures are technically and administratively correct and make a biennial review program unnecessarily duplicative.

These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusual incidents occur, when plant modifications are made, and when significant deficiencies are identified.

In addition, procedures may be reviewed because industry experience reviews or self-assessments identify deficiencies or opportunity for improvement.

Revisions are made as necessary.

Because of their critical nature, non-routine procedures, such as Emergency Operating Procedures, Off-Normal Procedures, Special Operating Procedures, Special Test Procedures, Fuel Handling Procedures, Emergency Plan Implementing Procedures, and others where use Page 55 Rev 17 Date: February 1, 1997 would be dictated by a particular event are reviewed at least every two years and revised as appropriate.

In addition, procedures that have not been used or reviewed for two years are reviewed prior to use to determine if changes are necessary or desirable.

An assessment performed at least every two years includes examination of selected plant procedures to determine procedure acceptability and verify that the procedure review and revision controls are effectively implemented.

Identified deficiencies are corrected in accordance with Section 16.0 of this QPD. , , 2o. N18.7, Sec 5.2.16 Requirement Records shall be made and equipment suitably marked to indicate calibration status. Exceotjon/lnteroretation See Item 9c. 2p. N18.7, Sec 5.2.17 Requirement For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities (see .also Section 5.2.7) Exception/lnteroretatjon Maintenance and modification activities which are within the skills of CPCo maintenance personnel and is carried out using CPCo procedures may be inspected by independent verifiers in accordance with Sections 10.2.3, 10.2.7, and 10.2.10 of this program description.

2q. N18.7, Sec 5.2.17 CPC-2A.R17 Requirement If mandatory inspection hold points are required, the specific hold points shall be indicated in appropriate documents.

Information concerning inspection shall be obtained from the related design drawings, specifications, and/or other controlled documents.

Exceptjon/lnteroretatjon CPCo uses the terminology "independent verification points" as equivalent to hold points.

Page 56 Rev 17 Date: February 1, 1997 2r. N18.7, Sec 5.3.5(3) Requirement Instructions shall be included, or referenced (in maintenance procedures), for returning the equipment to its normal operating status. Exceotjon/lnterpretation At CPCo, equipment is returned to its normal operating status, i.e., declared operable, by licensed Operations Department personnel, not Maintenance personnel.

Operations personnel verify and document equipment operability through second level line-up verification or appropriate functional testing. 2s. N18.7, Sec 5.3.5(4) Requjrement This section requires that where sections of documents such as vendpr manuals, operating and maintenance instructions, or drawings are incorporated directly or by reference into a. maintenance procedure, they shall receive the same level of review and approval as. operating procedures.

Exceptjonllnteroretation

• such documents are reviewed by appropriately qualified personnel pr-ior to use to ensure that, when used as instructions, they provide proper and adequate information to ensure .the required quality* of work .. Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures.

3a. RG 1.33, Sec C4a CPC-2A.R17 Requirement The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six months. Exceptjon/lnterpretation Performance trends are reviewed by the Nuclear Performance Assessment Specialists.

In addition, the corrective action system is audited in accordance with Appendix D, Audit Frequencies.

Page 57 Rev 17 Date: February 1, 1997 3b. RG 1 .33. Sec C4b .. 4a.

• CPC-2A.R17 Requirement The conformance of facility operations to provisions contained within the Technical Specifications and applicable license conditions-at least once per 12 months. Exception/Interpretation Consistent with guidance presented in NRC letters dated March 29, 1983 (RLSpessard to JMTaylor) and January 30, 1984 (JGPartlow to RLSpessard), Consumers Power Company interprets the commitment to audit Technical Specification/license conditions contained in 18.2.2 of this QPD, and in Appendix D, Audit Frequencies, as follows: Consumers Power Company maintains a matrix that identifies all applicable Technical Specification line items to be audited. The matrix is updated annually to conform to' approved Technical Specification changes. During each 12 month period, a selected sample of line items, with the exception of the onsite and offsite review committee which are audited every .24 months, is audited: 1 . Limiting Conditions for Operation

2. Limiting Safety System Settings 3. Reactivity Control Systems 4. Power Distribution Limits 5. Instrumentation

6. Reactor Coolant System 7. Emergency Core Cooling System . 8. Containment Systems 9. Plant Systems 10. Electrical*

Power Systems 11 . Refueling Operations

12. Special Tests 13. Onsite Committee

14. Offsite Committee

15. Administrative Controls Audits are scheduled so that all line items are covered within a maximum period of 5 years. The audit period for any of the above elements may be reduced depending on Technical Specification compliance history. ANS 3.1, General Exception/lnteroretation The commitment to ANS 3.1 (12/79, draft) is limited to the requirements that apply to the training and qualification of persons performing independent quality assurance functions, except for Lead Auditors.

Lead auditors are trained and qualified to Regulatory Guide 1 . 146 (8/80)/ANSI 45.2.23-1978.

Other personnel are trained and qualified as designated in plant Technical Specifications .

Page 58 Rev 17 Date: February 1, 1997 5a. fili.!...ft, C.3.1, General Exception/I nteroretation The commitment to Regulatory Guide 1.8 (9/80, draft) is limited to the requirements that apply to the training and qualificatoin of persons performing independent quality assurance functions, except for Lead Auditors.

Lead Auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978.

Other personnel are trained and qualified as designated in plant Technical Specifications.

5b. RG 1 .8, Cl.2.2 Requirement "When an individual is hired to temporarily function as a plant employee, such as for contracted services, evidence of previous education, experience, and training should be provided and reviewed by the appropriate professional-technical group leaders. The . appropriate group leaders should then determine the content for that individual's training, including plant-specific training.

As a minimum, each individual should receive General Employee Training." Exception/lnteroretatjoo CPCo understands that this requirement applies both to CPCo employees from another site and to contract personnel who. are temporarily assigned to a nuclear power plant either as replacements for regular employees or to augment the staff during outages. CPCo employees so assigned possess the required qualifications as a prerequisite to the assignment and the review is waived. The qualifications of contract personnel are reviewed and arrangements made for any necessary training.

Temporarily assigned personnel requiring unescorted access receive the site general orientation as embodied in General Employee Training.

6a. N45.2.1. Sec 2.4 CPC-2A.R17

'Requirement Those personnel who perform inspection, examination, or testing activities required by this standard shall be qualified in accordance with ANSI N45.2.6 Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants. Exception/lnteroretation CPCo certifies its inspectors in accordance with Paragraph 10.2. 7 of CPC-2A unless the work is comparable in nature and extent to original construction (See Item 2j).

• 6b. N45.2.1. Sec 3.1 Requirement Page 59 Rev 17 Date: February 1, 1997 N45.2.1 establishes criteria for classifying items into "cleanness levels," and requires that items be so classified.

Exception/lnteroretation Instead of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activities is addressed on a case-by-case basis. Cleanness is maintained, consistent with the work being performed, so as to prevent the introduction of foreign material.

As a minimum, cleanness inspections are performed prior to system closure. Such inspections are documented

.. 6c. N45.2.1, Sec 5 Requjrement "Fitted and tack-welded joints (which will not be immediately sealed by welding) shall be

• wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed.

n Exceptjon/lnteroretatjon CPCo sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film is subject to d;:image and does not always provide adequate protection.

7a. N45.2.2, General Requirement N45.2.2 establishes requirements and criteria for classifying safety-related items into protection levels. Exception/lnteroretatjon Instead of classifying safety-related items into protection levels, controls over the packaging, shipping, handling, and storage of such items are established .on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function . CPC-2A.R17 Page 60 Rev 17 Date: February 1, 1997 I 7b. N45.2.2, Sec 2.4 Requirement " ... Offsite inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N45.2.6." Exception/Interpretation Offsite inspection, examination, or testing activities are audited or inspected by persons qualified and certified in accordance with ANSI N45.2.23-1978, as endorsed by Reg Guide 1 .146, or by personnel meeting the requirem*ents of 10.2. 7, respectively.

Monitoring activities not involving audit or inspection may be conducted by persons trained and qualified to effectively carry out such tasks, but not necessarily certified to either ANSI N45.2.23, N45.2.6 or Paragraph 10.2. 7. I 7c. N45.2.2, Sec 3.4.1 and Appendix A, 3.4.1 (4) and (5) Requjrement

"(4) ... However, preservatives for inaccessible inside surfaces containing reactor coolant water shall be indicated to facilitate touch up. (5) The name of the preservative used shall be the water flushable type." Exceptjon/lnteroretation . Based on comparison of these statements to ANSl/ASME NQA-2 1983, CPCo believes the intent was to establish the following as requirements: . "(4) ... However, preservatives for inaccessible inside surfaces of pumps, valves, and pipe for systems containing reactor coolant water shall be the water flushable type. (5) The name of the preservative used shall be provided to facilitate touch-up." I 7d. N45.2.2, Sec 3.9 and Appendix A 3.9 CPC-2A.R17 Requirement "The item and the outside of containers shall be marked." (Further criteria for marking and tagging are given in the appendix.) , Exceptjon/loteroretatjon These requirements were originally written for items packaged and shipped to construction projects.

Full compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, increase the probability of damage to the item. The Page 61 Rev 17 Date: February 1, 1997 requirements are implemented to the extent necessary to assure traceability and integrity of the item. 7e. N45.2.2, Sec 5:2.2 Requirement "The inspections shall be performed in an area equivalent to the level of storage." Exception/lnteroretation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item. However, such inspections are performed in a manner and in an environment which do not endanger the required quality of the item. 7f. N45.2.2, Sec 6.2.4 Requjrement "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall not be permitted." Exception/lnteroretatjon Packaged food for emergency or extended overtime use may be in material stock rooms. The packaging assures that materials are not contaminated.

Food will not be in these areas. 7g. N45.2.2, Sec 6.3.4 Requirement "All items arid their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes." Exception/lnteroretation See N45.2.2, Section 3.9 (Exception 7d.). 7h. N45.2.2, Sec 6.4.1 CPC-2A.R17 Requirement "Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the item and its container

... is being maintained."

Exception/lnteroretation Page-62 Rev 17 Date: February 1 , 1997 The requirement implies that all inspections and examinations of items in storage are to be performed on the same schedule.

Instead, the inspections and examinations are performed and documented in accordance with material storage procedures which identify the characteristics to be inspected and include the required frequencies.

These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item. Ba. N45.2.3. Sec 2.1 Requirement Cleanness requirements for housekeeping activities shall be established on the basis of five zone designations.

Exceptjon/lnteroretation Instead of the five-level zone designation system referenced in ANSI N45.2.3, CPCo bases its controls over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved.

The controls are effected through procedures or instructions which, in the case of maintenance or modifications work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation . control, and security.

The procedures and instructions make use of S!andard janitorial and work practices to the extent possible.

However, in preparing these procedures, consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3. 9a. N45.2.4. Sec 2.2 ReqLijrement Section 2.2 establishes prerequisites which must be met before the installation, inspection, and testing of instrumentation and electrical equipment may proceed. These prerequisites include personnel qualification, control of design, conforming and protected materials, and availability of specified documents

.. Exception/lnteroretation

• During the operations phase, this requirement is considered to be applicable to modifications and initial start-up of electrical equipment.

For routine or periodic inspection and testing, the prerequisite conditions will be achieved as necessary.

I 9b. N45.2.4, Sec 2.2(5) CPC-2A.R17 Requirement Section 2.2(5) of ANSI N45.2.4 lists documents which are to be available at the construction site. * * *

• i; -**

• Exceotion/Clarification Page 63 Rev 17 Date: February 1, 1997 All of the documents listed are not necessarily required at the plant site for installation and testing. CPCo assures that they are available to the site as necessary.

9c. N45.2.4, Sec 6.2.1 Requirement "Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration .and identity of person that performed the calibration.

n Exception/loteroretation Frequently, physical size, and/or location of Installed Plant Instrumentation (IPI) mandates that calibration labels or tags not be affixed to IPI. Instead, each instrument is uniquely identified and is traceable to its calibration record. A scheduled calibration program assures that each instrument's calibration is current. 1 Oa. N45.2.5, Sec 2.4 Requirement "Persons charged with engineering managerial responsibility of the i!lspection and testing organization at the site in either a resident or, non-resident capacity shall be certified for Level Ill capability." Exception/lnteroretation

.. This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activity in the areas of concrete and structural steel which do not generally occur at an operating plant. At Consumers Power, persons having engineering managerial responsibility for inspections and tests* may be certified to Level Ill, or may meet other qualification criteria established for the position, including, but not limited to, nuclear power and r:nanagement experience.

For major modifications involving significant concrete or structural steel work, the services of a properly qualified Level Ill individual will be obtained in at least an advisory capacity.

• within the scope of N45.2.5 1 Ob. N45.2.5. Sec 2.5.2

• Requirement "When discrepancies, malfunctions,-or inaccuracies-in inspection and testing equipment are found during calibration, all items inspected-with that equipment since the last previous calibration shall be considered unacceptable until an evaluation has been made by the responsible authority and appropriate action taken. n CPC-2A.R17 Exceotjon/I nteroretation Page 64 Rev 17 Date: February 1, 1997 CPCo uses the requirements of NIS.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The NIB. 7 requirements are more applicable to an operating plant. I 1 Oc. N45.2.5, Sec 5.4 Requirement I "Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more often if deemed necessary.

Impact torque wrenches used for inspection must be calibrated at least twice daily." Exception/lnteroretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI NIB. 7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45*.2.5 11 a. N45.2.6. Sec 1.2 Requirement "The requirements of this standard apply to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt_of items at the construction site, during construction, during preoperational and start-up testing, and during. operational phases of nuclear power plants. n Exception/lnteroretation se*e Exception/Interpretation 2j for those inspectors who must be certified to this standard.

Others are qualified to Paragraph 10.2. 7 of CPC-2A. Qualification of plant personnel who are involved with testing associated with plant operation is provided in specific plant specifications.

In addition, personnel participating in inspection-or testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 but need only be trained to the extent necessary to perform the assigned function.

12a. RG l.5B. Sec C.I cPC-2A.R17 Requirement "However, for qualification of personnel (I) who approve preoperational, start-up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start-up and operational tests, the guidelines contained in Regulatory Guide l.B, Personnel Selection and Training, should be followed in lieu of the Guidelines of ANSI N45.2.6 -197B."

• Exceotion/lnteroretation Page 65 Rev 17 Date: February 1, 1997 CPCo endorses this position, as also stated in 11 a, above, except that offsite support organizations involved in testing may apply ANSI N45.2.6. Some of these departments have already developed their qualification programs based on ANSI N45.2.6, and provide services throughout the operations phase of CPCo Nuclear Plants. 12b. RG 1.58, Sec C.5 Requirement "In addition, the individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives." Exception/lnteroretation While a Level Ill individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequa_cy of such procedures to accomplish the inspection, examination and test objectives, this is not construed by CPCo as requiring personnel who revieyv, approve or evaluate such procedures to be certified as Level Ill personnel.

12c. RG 1 .58, Sec C.6 Requirement "Since only one set of recommendations is provided for the education and experience of personnel, a commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be followed." Exception/Interpretation The education and experience recommendations given in ANSI N45.2.6, Section 3.5 will be treated as such, since our qualification and certification program is based upon these recommendations, and more significantly, upon satisfactory completion of capability testing prior to certification.

It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons. I2.d RG 1.58, Sec C. 10 Requirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experience should result in documented evidence (i.e., procedure and record of written test) demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience.

n CPC-2A.R17

..

Exceptjon/lnterpretation Page 66 Rev 17 Date: February 1, 1997 We will maintain documented objective evidence that demonstrates that an individual does have "comparable" or "equivalent" competence to that which would be gained from having the required education and experience.

However, this may take the form of documentation other than "procedures and records of written test" such as documentation of oral tests and on-the-job performance demonstrations.

13a. N45.2.8, Sec 2.7 Requirement Section 2. 7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6. Exceptjon/lnteroretation See Exception/Interpretation 2j, 11 a, and 12a. Test personnel who are part of the plant

• staff need not be certified to N45.2.6, provided they meet applicable qualification criteria of plant Technical Specifications.

13b. N45:2.8, Sec 2.9 Requirement

-Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel . and procedure qualification, control of .design, material selection and fabrication, and availability of specified documents.

Exceptjon/lnteroretation . During the operations phase, this requirement is considered to be applicable to modifications of mechanical equipment.

For routine or periodic inspection and testing, the prerequisites will be achieved as necessary.

13c. N45.2.8, Sec 2.9e CPC-2A.R17 Requirement Section 2.9e of N45.2.8 lists documents relating to the specific stage of installation activity which are to be available at the construction site. Exception/Interpretation All of the documents listed are not necessarily required gt the plant site for installation and testing. CPCo assures that they are available 1Q the site as necessary.

• *

• 13d. N45.2.8, Sec 2.9e Requirement Page 67 Rev 17 Date: February 1, 1997 Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation.

Exceptjon/lnterpretatjon Equipment may be installed before final approval of engineering or design changes. However, the system is not declared operable until such changes are documented and approved.

13e. N45.2.8, Sec 4.5.1 Requjrement "Installed systems and components shall be cleaned, flushed, and conditioned according to the requirements of ANSI N45.2.1 Special attention shall be given to the following requirements:

.... " (Requirements are given for chemical conditioning, flushing and process controls.)

Exception/lnteroretation . Systems and components are cleaned, flushed and conditioned as de}ermined on .a case basis. Measures are taken to help preclude the need for cleaning, flushing, and conditioning through good practices during maintenance or modification activities.

14a. N45.2.9, Sec 5.4, Item 2 Requirement Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers.

Steel cabinets are preferred.

Exceptjon/lnteroretation Records are suitably stored in steel file cabinets or on shelving in containers.

Methods other than binders; folders or envelopes (for example, dividers or electronic media) may be used to organize the records for storage .. 14b. N45.2.9, Sec 6.2 Requjremeot "A list shall be maintained designating those personnel who shall have access to the files." CPC-2A.R17 Exceotion/I nteroretatjon Page 68 Rev 17 Date: February 1 , 1997 Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms exist for general use and backup. 14c. RG 1 .88, C2 Requirement "Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974.

NFPA No 232-1975 ... also contains provisions for records protection equipment and records handling techniques that provide protection from the hazards of fire. This standard, within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the fire protection provisions listed in Subdivision 5.6 ... When NFPA 232-1975 is used, quality assurance records should be classified as NFPA Class 1 records .... " Exceptjon/lnteroretatjon CPCo adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Class 1 records (usually NFPA Class C, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Cl_ass 350). 15a. RG 1.64, C2 Reglijrement "Regardless of their title, individuals performing design verification should not (I) have immediate supervisory responsibility for the individual performing the design .... " Exceotion/I nteroretation CPCo follows the requirements of ANSI N45.2. 11-1974, Section G.1, and the guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9; herein). This approach is necessary to allow small organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks. 16a. RG 1 .144. Sec C3a(I) CPC-2A.R17 Regujrement This section requires that for operational phase activities, RG 1.33 "Quality Assurance Program Requirements (Operations)" are to be followed.

One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies that affect nuclear safety and * * *** *

• *

• Page 69 Rev 17 Date: February 1, 1997 occur in facility equipment, structures, systems, or method of operation are to be audited at least once per six months.

• Exception/lnteroretation See Item 3a for the exception to this requirement.

16b. RG 1 .144, Sec C3a(2) Requirement Applicable elements of an organization's quality assurance program (for "design and construction phase activities")

should be audited at least annually or at least once within the life of the activity, whichever is shorter. Exception/Interpretation Since most modifications are straightforward, they are not audited individually.

Instead, selected controls over modifications are audited periodically.

16c. RG 1 .144, Sec C3b(I) Requirement This section identifies procurement contracts which are exempted frqm being audited. Exception/lnteroretation In addition to the exemptions of RG 1 .144, CPCo considers that Authorized Inspection Agencies, National Institute of Standards and Technology or other State and Federal Agencies which. may provide services to CPCo are not required to be audited. 17a. N45.2.13.

Sec 3.2.2 Requirement N45.2.13 requires that technical requirements be specified in procurement documents by reference to technical requirement documents.

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

Exceptjon/lnteroretatjon For replacement parts and materials", CPCo follows ANSI NIS. 7, Section 5.2.13, Subitem I, which states: "Where the original item or part is found to be commercially

'off the shelf' or without specifically identified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance." CPC-2A.R17 Page 70 Rev 17 Date: February 1, 1997 17b. N45.2.13, Sec 3.2.3 Requirement "Procurement documents shall require that the supplier have a documented quality assurance program that implements portions all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards." Exception/Interpretation Refer to Item 21. I 17c. N45.2.13, Sec 3.3(a) Requirement Reviews of procurement documents shall be performed prior to release for bid and contract award. Exception/lnteroretatjon Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is put into service or before work has progressed beyond the point where it would be impractical to reverse the action taken .. I 17d. N45.2.13, Sec 3.3(b) Requirement "Changes made in the procurement documents as a result of the bid evaluations or

• precontract negotiations shall be incorporated into the procurement documents.

The review of such changes and their effects shall be completed prior to contract award." Exception/lnteroretation This requirement applies only to quality related changes (i.e., changes to the procurement document provisions identified in ANSI NIB'. 7, Section 5.2.13.1, Subitems I through 5.) The timing of reviews will be the same as for review of the original procurement document.

I 17e. N45.2.13,Sec7.5 CPC-2A.R17 Requirement "Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as applicable." * * *

• Exceotion/lnteroretatjon Page 71 Rev 17 Date: February 1, 1997 Consumers Power qualifies audit personnel according to N45.2.23.

Thus, personnel performing source verification audits may not be certified according to N45.2.6. Personnel performing inspection as part of source verification will be certified to N45.2.6 or qualified in allowance with Paragraph 10.2.7. However, personnel performing source surveillances may not be certified to any of those requirements.

17f. N45.2.13, Sec 10.1 Requirement "Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods." Exception/lnteroretation Refer to Item 2m. 17g. N45.2.13, Sec 10.3.4 (as modified by RG 1.123, C6e) Requjrement "Post-installation.test requirements and acceptance documentation s_hall be mutually *established by the purchaser and supplier." ---Exception/lnteroretation In exercising its ultimate responsibility for its quality program, CPCo establishes installation test requirements, giving due consideration to supplier recommendations.

18a. RG 1.26, General Requirement RG 1.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are not.) Exception/lnteroretation RG 1.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety-related determinations.

Regulatory Guide 1.29, subject to Exception/Interpretation 20a, is used to determine what systems and equipment included in the Quality Program . CPC-2A.R17 Page 72 Rev 17 Date: February 1, 1 . 19a. Branch Technical Position ASB9. 5. 1 and 10 CFR 50 Appendix R. Sections Ill G .. Ill J .. and Ill 0., General Exceptjon/lnteroretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 Appendix R except for the specific exemptions approved by the NRC. 20a. RG 1.29. Sec C, Regulatory Position Requirement The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category I and should be designed to withstand the SSE: Exception/Interpretation Both CPCo nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on criteria available prior to Revision 3 of this Regulatory Guide being issued.* The specific design criteria and seismic designations are ,reflected in the FHSR and FSAR,

• respectively, and in other docketed analysis.

Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29. The criteria of this Regulatory Guide are used at CPCo primarily in identification of systems, structures, and components to which the Quality Program is applied (see 20b, below). 20b. RG 1.29, General Requirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B. Exception/lnteroretation The pertinent quality requirements for these systems, structures and components will be determined in a graded manner using tools such as the plant specific*

Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies. 21. ANSI/ANS 3.1 -1987 CPC-2A.R17 Execption/lnteroretation The commitment to ANSI/ANS 3.1-1987 is limited to requirments that apply to persons performing the independent safety review function as specified in Appendix C to this QPD . * * *

• *

• QPD MANUAL APPENDIX B PLANT REVIEW COMMITTEE

!PRC) Page 73 Rev 17 Date: February 1, 1997 B1. FUNCTION The Plant Review Committee (PRC) shall function to advise the Plant General Manager/Manager on all matters related to nuclear safety. B2. COMPOSITION B3. The Palisades PRC is composed of nine regular members. The qualification level for PRC members shall be at least equivalent to those described in Section 4.4 of ANSI N18.1-1971.

The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments.

The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Plant General Manager. The Big Rock Point PRC is composed of nine regular members from the Big Rock Point staff. The PRC members shall meet or exceed the minimum qualifications described in Sections . 4.2 and 4.4 of ANSI N18.1-1971 for comparable positions.

The PRC shall include

• representatives from the Operations, Chemistry/Health Physics, Maintenance, Engineering, and Safety and Licensing Departments.

The member shall be designated in administrative procedures by the Plant Manager who is the Chairman of the PRC. The Plant Manager shall . also. designate an Alternate.Chairman in writing. . ALTERNATES Alternate members of the PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis. No more than two alternates shall participate .as voting members at any one time in PRC activities.

B4. MEETING FREQUENCY The PRC shall meet at least once per calendar month with special meetings as required.

B5. QUORUM A quorum of the Palisades PRC shall consist of the Chairman or alternate and four members or alternates.

A quorum of the Big Rock Point PRC shall consist of the Chairman or alternate Chairman and four members or alternates . CPC-2A.R17 Page-74 Rev 17 Date: February 1, 1997 86. RESPONSIBILITIES CPC-2A.R17 The PRC shall be responsible for nuclear safety review of: a. All procedures and programs specified by the Technical Specifications and changes thereto, and any other procedures or changes thereto as determined by the Plant General Manager/Manager to affect nuclear safety; all proposed tests or experiments that affect nuclear safety; all proposed changes or modifications to plant systems or equipment that affect nuclear safety. b. All proposed changes to Operating License and Technical Specifications.

c. Results of investigations of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and recommendations to prevent recurrence and be forwarded to the Vice President

-NOD l;lnd to the Manager, Nuclear Performance Assessment Department (NPAD)). d. Plant operations to detect potential safety hazards. e. Reports of special reviews and investigations as requested by the Plant General Manager/Manager or NPAD. f. Site Emergency Plan and implementing procedures.

g. All reportable events as defined in 10 CFR 50.72 and 50.73. h. All items identified under 89.3 below as significant to nuclear safety (Palisades only). !. Monthly reports from Safety/Design Review (Palisades only). j. Nuclear industry operating experience.

k. Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Plant Manager and to the Manager, Nuclear Performance Assessment Department (Big Rock Point only). PRC review of the above items may be performed by routing, subject to the requirements of 87. below. The Palisades PRC may delegate review of item a. to Safety/Design Review staff, as described in 89. below. * * *

• 7

• 87. AUTHORITY The PRC shall: Page 75 Rev 17 Date: February 1 , 1997 a. Recommend in writing to the Plant General Manager/Manager approval or disapproval of items considered under 86.a. through

j. above. b. Render determinations in writing with regard to whether or not each item considered under 86.a, b, c, f (Palisades only) and h above constitutes an unreviewed safety question.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President Nuclear Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC and the Plant General Manager/Manager; however, the Plant General Manager/Manager shall have responsibility for the resolution of such disagreements.

The PRC Chairman may recommend to the Plant General Manager/Manager approval of those items identified in 86. above based on a routing review provided the following conditions are met: (1) at least five PRC members including the Chairman and no more than 2 alternates, shall review the item, concur with determination as to whether or not the item constitutes an unreviewed safety question, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the PRC Chairman determines that the comments are significant, the item . (including comments and resolutions) be recirculated to all r.evie_wers for additional comments.

The item shall be reviewed at a PRC meeting in the event that: ( 1) Comments are not resolved; or (2) the Plant General Manager/Manager overrides the recommendations of the PRC; or (3) a proposed change to the Technical Specifications involves a safety a limiting safety system setting or a limiting condition for operation; or (4) the item was reportable to the NRC. 88. RECORDS 89. The PRC shall maintain written minutes of each PRC meeting and shall provide copies for Independent Safety Review. TECHNICAL SUPPORT FOR PRC The Safety/Design Review organization shall function to examine proposed changes in design or operation and such other matters as the Palisades PRC may assign to identify issues significant to nuclear safety and recommend nuclear safety improvements.

89.1 The Safety/Design staff responsible for the review function shall be an experienced technical staff meeting the qualifications of Technical Specifications.

89.2 The Safety/Design Review staff may provide nuclear safety review as delegated by Palisades PRC for: CPC-2A.R17 Page 76 Rev 17 Date: February 1, 1997 a. Procedures, programs and changes thereto identified in the Technical Specifications and any additional procedures and changes thereto identified by the Plant General Manager/Manager as significant to nuclear safety. b. All proposed tests or experiments.

c. All proposed changes or modifications to plant systems or equipment.

d. The Site Emergency Plan and implementing procedures.

89.3 The Safety/Design Review staff shall determine those issues significant to nuclear safety which require review by the Palisades Plant Review Committee from items considered under 89.2a. through d. above. For those items not referred to PRC, Safety/Design Review shall recommend in writing to plant management approval or disapproval of items considered under 89.2. 89.4 Reports of Safety/Design Review activities pursuant to 89 shall be submitted monthly to PRC. CfiC-2A.R17

• , * . . *

• QPD MANUAL APPENDIX C INDEPENDENT SAFETY REVIEW Page 77 Rev 17 Date: February 1, 1997 The following exceptions/interpretations in Appendix A, Part 2, are relevant to implementation of the requirements of this section of the QPD: Apoendjx C Exceptjons/I nteroretatjo ns 2c, 2d, 2e, 2f, 21 C1. FUNCTION The Independent Safety Review Group (ISRG) shall function to provide independent review of activities in the areas of: a. Nuclear power plant operation

b. Nuclear engineering

c. Chemistry and radiochemistry

d. Metallurgy

e. . Nondestructive testing f. Instrumentation and control g. Radiological safety h. Mechanical and electrical engineering

!. Administrative controls and quality assurance practices

j. Emergency Planning k. Training C2. COMPOSITION The ISRG shall include the Manager, NPAD, who reports to the Vice President

-NOD, and a full-time staff of persons reporting to the Manager, NPAD and designated as Nuclear Performance Specialists for the ISR function.

The Manager, NPAD, and the Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4. 7 of ANSI/ANS 3.1-1987.

The ISRG shall have no direct responsibility for activities subject to its review. C3. CONSULTANTS If sufficient expertise is not available within the ISRG to review particular issues, the ISRG shall have the authority to utilize consultants or other qualified organizations for expert advice. C4. RESPONSIBILITIES C4.1 REVIEW The !SRG shall review: CPC-2A.R17 Page 78 Rev 17 Date: February 1, 1997 a. The safety evaluations for: 1) changes to procedures, equipment or systems, and 2) tests for experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59. c. Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59. d. Proposed changes to Technical Specifications or the Operating License. e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f. Significant operating abnormalities or deviations from normal and expected of unit equipment that affects nuclear safety. g. All reportable events having nuclear safety significance.

h. All recognized indications of an unanticipated deficiency in some aspect of design or* operation of structures, systems, or components that could affect nuclear safety. I. Reports and meeting minutes of the Plant Review Committee.

-j.. Fire Protection Program and Implementing Procedure Changes (Palisades only). k. Reports of audits performed as specified in Appendix D. ISRG review of the subjects in C4 above shall be performed by an assigned Nuclear Performance Specialist selected on the basis of technical expertise relative to the subject being reviewed.

If the assigned Nuclear Performance Specialist determines the need for interdisciplinary review, a committee consisting of the Manager, NPAD, or his designate, and at least four Nuclear P.erformance Specialists, shall be assigned.

Such committee shall meet as conditions requiring interdisciplinary review arise, but no less than twice yearly. C5 AUTHORITY The ISRG shall report. to and advise the Vice-President, NOD, of significant findings associated with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.

I C6 RECORDS CPC-2A.R17 Records of ISRG activities shall be maintained.

Reports shall be prepared and distributed as indicated below: a. The results of reviews performed pursuant to C4 above shall be reported to the President, NOD, at least monthly.

CPC-2A.R17 Page 79 Rev 17 Date: February 1, 1997 b. A report assessing each plant's overall nuclear safety performance shall be provided to senior Consumers Power Company management annually.

OPP MANUAL APPENQIX D AUDIT FREQUENCIES Page 79 Rev 17 Date: February 1, 1997 D1. AUDITS CPC-2A.R17 Audits of operational nuclear safety related activities are performed by the NPAD staff under the cognizance of Nuclear Performance Specialists.

These audits encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 1 2 months. b. The performance, training and qualifications of the entire facility staff at least once per 12 months. c. The performance of activities required by the Quality Program Description for Operational Nuclear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50, Appendix B at least once per 24 months. d. The Site Emergency Plan and implementing procedures at least once per 12 months. -e. The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 12 months. f. Any other area of plant operation considered appropriate by or the Vice President

-Nuclear Operations.

g. The plant Fire Protection Program and implementing procedures at least once per 24 months. h. An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

• I. An inspection and audit of the fire protection and loss prevention program to be an outside qualified fire consultant at intervals no greater_ than 3 years. j. Radiological environmental monitoring program and the results thereof at least once per 12 months. k. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months. I. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months. Audit reports encompassed by D1. above shall be forwarded to the Manager, NPAD, and Management positions responsible for the areas audited within thirty (30) days after completion of the audit.

"'-* QPD MANUAL APPENDIX E RECORD RETENTION Page 80 Rev 17 Date: February 1, 1997 E1. In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated:

E2. The following records shall be retained for at least five years: a. Records and logs of facility operation covering time interval at each power level. b. Records and logs of-principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety. c. All reportable events as defined in 10 CFR 50. 72 and 50. 73. d. Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications.

e. Records of changes made to the procedures required by Plant Technical Specifications.

f. Records of radioactive shipments.

g. Records of sealed source leak tests and results. h. Records of annual physical inventory of all source material of record. E3. The following records shall be retained for the duration of the Facility Operating License: a. Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Palisades Final Safety Analysis Report or Big Rock Point Final Hazards Summary Report. b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c. Records of quarterly radiation exposure for all individuals entering radiation control areas. d. Records of gaseous and liquid radioactive material released to the environs.

e. Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles. f. Records of inservice inspections performed pursuant to Plant Technical Specifications.

g. Records of Quality Assurance activities required by the Quality Program Description.

CPC-2A.R17 CPC-2A.R17 Page 81 Rev 17 Date: February 1 , 1997 h. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59. I. Records of meetings of the PRC and reviews performed by NPAD according to Appendix C. j. Records of monthly facility radiation and contamination surveys. k. Records of secondary water sampling and quality (Palisades only). I. Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specifications.

This shall include the date at which the service life commences and associated installation and maintenance records (Palisades only). m. Records for environmental qualifications which are covered under the provisions of 10 CFR 50.49 (Big Reick Point only). n. Records of training and qualifications for members of the plant staff. o. Records of reactor tests and experiments.

p. Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM (Palisades only). . * *