ML18046A374

Vol 1,Revision 10,to QA Program

ML18046A374
Person / Time
Site:	Palisades, Midland
Issue date:	09/26/1980
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18046A373	List: ML18046A372 ML18046A374
References
CPC-1A, CPC-1A-V1-R10, NUDOCS 8102120049
Download: ML18046A374 (16)

Text

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~ QUALITY 'ASSURANCE PROGRAM POLICY POLICY NO 1

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PAGE 3 OF 41~

ORG.A..NIZATION REVISION . 10 consumers Power DATE 9/26/80 personnel reporting to him, as follows:

(a) Vice President - General Services and reporting to him, to the:

Director - Purchasing Director - Property Protection Manager - Administrative Services (Graphic- Services)

The organization relationship of these positions are shown in Figures 1, 2, 3 & 4.

BASIS DOCUMENTS

a. NRC 10CFR50, Appendix B, Criterion 1, "Organization"

b. AUSI N45.2, Criterion 3, "Organization"

c. ANSI Nl8. 7 J.O POLICY

3. l lt'POJ'ECTS, El'TGINEERHTG & CONSTRUCTION ORGAliJ'IZ.A.TIONAL RESPONSIBILITIES DURING THE DESIGii MJD COI'JSTRUCTION PHASE 3.1.l Environ..~ental Services, Quality Assurance and Testing Environmental Services, Quality Assurance and Testing (ES,~A.&T) is re-sponsible for establishing environmental compliance, QUality assurance and preoperational testing standards for design and construction consistent with CF Co objectives, and for assur.ing the establishment and implementation of policies and procedures to meet these standards.

In performing their assurance-type responsibilities, ES ,Q,A&T personnel have '

no responsibilitity for the cost scheduling effects of their findings; have l the authority and organizational freedom to identify assurance-related l problems, initiate,** recommend or provide corrective action and verify implementa~ion of corrective action; and are independent from the indivi-I

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duals or groups performing the activities being inspected, tested or audited. Ad.di tional assurance-related activities as gi Vf'.n below, are

QUALITY ASSURANCE PROGRAlVl POLICY ORGANIZATION POLICY NO PAGE REVISION 10 1

4 OF 44 lI* -)

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consi.lmers Power DATE 9/26/80 assigned to ES ,QA&T for work performed either by CP Co or by Principal Suppliers, major subcontractors and sub-tier suppliers, or the acti vi ti"es may be delegated to a Principal Supplier's corresponding organization. The decision as to whether or not these activities are to be delegated shall be made with the mutual concurrence of both the PMO and ES, QA&T. Nevertheless ,

ES,Q/'1.&T retains authority* and responsibility for these activities and for assuring their adequate and timely accomplishment. The objective of the assign.~ent of authorities and responsibilities to ES,QA&T is to yield a total assurance program resulting in the attainment of a facility which is desig:ied in accordance with its design basis criteria and which is con-structed in accordance with its drawings and specif:i,.cati.on requirements.

Figure 5 depicts the Environmental Scrvi8es, Quality Assurance and Testing organization. Figures 8 & 9, depict the Section organizations.

Within Environ.1nental Services, Quality Assurance and Testing, there are three Sections. - namely: Quality Assurance Engi:peering & Inspection, Quality Assurance Audit & A.dministration and Testing. Following is a discussion of the responsibilities of each of these Sections.

3.1.1.1 Quality Assurance Engineering and Ins~ection Section The Quality Assura,'1.ce Engineering and Inspection Section is responsible for performing quality assurance engineering, inspec-tion, examination, test and test verification. Mo:ce specifically, for:

a. During the design concept activity:

(1) Preparing the Project Quality Assurance Plan and assuring the Plan's timely issuance with the inutual concurrence of the organizations involved;

b. During the des :i.gn activity:

(1) Participating in the establishment of the Design Plan by establishing the quality assurance aspects of the Plan; (2) Participating, as specified by the Design Plan;

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• I QUALITY ASSURANCE PROGRAM POLICY P.OLICY NO 1 PAGE 7 OF 44 ORGAN'IZATION REVISION 10 consumers Power DATE 9/26/80

( c) The adequacy of the data collection format and con-tent relative to the needs of the Quality Assurance Program regarding quali~y records.

(3) Preparing and implementing procedures for the inspection, nondestructive examination, tests (wit~in the Section's test jurisdiction) and test verification for preventive and corrective maintenance activities;

g. At any time, prior to or during the performance of the pre-operational, hot functional, major modification and Palisades SGRP tests, and other prerequisites, signifying the pre-requisites actually audited by the application of a G,AE&I signature for each such prerequisite.

h. During the performance of the checkout, preoperational, hot functional, major modification and Palisades SGRP tests, and functional in-service baseline tests,. evaluating compliance with test procedures on an audit and surveillance basis, signifying the test procedural steps actually audited and surveilled by the application of QAE&I signatures adjacent to those steps.

i. Throughout all activities:

( 1) Evaluating the implementation of the Quality Assurance Program and recommending improvements;

( 2) Issuing "Stop Work Order" at any time that Quality Assurance Program commitments are violated if necessary to preclude a safety risk;.

(3) Performing quality audit, as requested.

3.1.1.2 Quality Assurance Audit and Administration Section The Quality Assurance Audit and Administration Section is responsible for performing audits of activities which may impact design and construction quality. More specifically, for:

a. Evaluating the adequacy of quality policies and procedures;

b. Evaluating the degree of compliance with quality policies and procedures ;

c. Obtaining corrective action, as necessary, based on audit findings;

trf:~ QUALITY ASSURANCE PROGRAl\ti POLICY POLICY NO 1

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PAGE 8 OF 44 ORGANIZATION REVISION 10 consumers Power DATE 9/26/80

.. NOTE: Items a, b, and c, above, apply to primary suppliers as

-well as to "in-house" activities.

d . . Performing.departmental administrative functions, especially with regard to budgets, and other special assignments;

.e. Providing quality assurance education, training and indoc-

. trination;

f. Prepexing, releasing and controlling inter and intra-depart-mental quality-related policies and procedures;

g. Issuing "Stop Work Orders" at any time that Quality Assurance Program commitments are violated, if necessary to preclude a r l

safety risk. I 3.1.1.3 Testing S~ction

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The Testing Section is responsible for providing preoperational testing and, upon request, trial operational testing and related technical services. More- specifically, for: . _./;

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a. Preparing Proj_ect Testing Program Manuals for the Palisades ~

SGRP and major modifications prior to the implementation phase;

b. Providing for the preparation, review and approva], of test procedures;

c. Training and certifying ~ualified personnel and assembling other resources necessary to implement testing progra.n;s;

d. Implementing the Palisades SGRP and major modification Testing Programs;

e. Coordinating and providing the evaluation of test results~;

3.1. 2 Miclle.~,'-~ Pro,4 ect Manag:,=ment Organization ConsUiners Power has established* a Project Management Organization to pro-vide effective management of the Mid.land Nuclear Plant Project. The i*1id-land Project Management Organization is shown in Figure 6. The Project Management Organization is headed by a Project Management Office consis-ting of the Vice President - Midland Project assisted by the Midland Project Mo.nager. The Midland Project Office has overall responsibility for all activities relatP.d to design, procurement and com;truction of the Midl3.nd ___/

Plill1t including design, obtaining appropriate licenses and permits, pro-curement, construr::tion, prr;opera.t:ion~.u and hot f'..mctional testing, quality assurance, eost, 0.."1d '"chedulc. 'I'l!cse rer:ponsi~Jil:i.tic~5 include coo~dination _j

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QUALITY ASSURANCE PROGRAM POLICY POLICY NO l PAGE 23 OF 44 ORGANIZATION REVISION 9 consumers Power DATE 3/l8/80 3.3.6 Fuel Supply Department The organization of the Fuel Supply Department is shown in Figure 3. The quality assurance responsibilities of the Vice President - Fuel Supply are delegated to the Director, Nuclear Fuel Supply, who is iri charge of the specification, acquisition a..~d delivery of nuclear fuel and related services, including uranium concentrates, urani~ conversion, reconversion enriching seririces, nuclear fuel assembly fabrication and reprocessing including storage and transportation. This includes the negotiation and administration of nuclear fuel purchase agreements. He obtains assistance from the Operating Seririces, Nuclear Activities, Plant Staff and QA-NO, as deemed necessar1, in performing the above activities.

3.3.! Grauhic Seririces Section The Graphic Services Sec"tion of the General Services Department is respon-sible for the micrcfilming of quality-related documents that are sent to them.

3.3.8 Management and Budget Denartrnent (Management System Section)

'i'he Management System Section of the Management and B-:.idget Department is resporisible for the development and implementation of a records manage-ment system for quality related documents. The reporting relationship is shown in Figure 19.

3. 1~ RESOLUTION OF CONFLICTS If a difference of opinion arises between Quality Assurance personnel and those of other de:9artments, the dispute is resolved as follows: The Supervisor of the Quality Assurance unit involved first tries to resolve the matter with the orp,an-ization responsible for conducting the activity. If a resolution cannot be obtained, :the matter is referred up through the following management personnel until it is resolved:

a. The appropriate Quality Assurance Director or Manager and the Executive Mana- j ger, Man2.ger, Director or Plant Manager/Gu;)erintendent responsible for per- d forming the activity:

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b. The Vice President responsible for conducting the activity;

c. The Executive Vice President - Energy E-upply (for. operations phase items *onlyJ;

d. The Senior Vice President - Projects, EnBineering and Construction (fqr design' and constructio!'l i terns o.nly); :J

e. The President and Chief Executive Officer of Con~rnmers Power Company .. ii ii

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I QUALITY ASSURANCE PROGRAl\'1 POLICY POLICY riO 1 I PAGE 24 OF* 44 .* --')~

ORGA..t"UZATION 10 REVISION .. ,.. ~

consumers Power DATE 9/26/80 i

I.

Vice President F..lel

• Supply General Services

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QUALITY ASSURANCE PROGRAiVI POLICY POLICY NO 19 0 PROGRAM REVIEW PAGE 1 REVISION OF 9

4 consumers Power DATE 3/18/80 1.0 GENERAL During design and construction 9f the Midland Project, the Manager of Quality Assurance assigns personnel within his organization to review the Quality Assurance Programs of Consumers Power Company's Suppliers and lower-tier suppliers. During I

Midland design and construction, the Palisades SGRP and ma,ior modifications, the Director~ Environmental ServicP.s, Quality Assurance. and Testing assigns personnel within his organization to review the Ouality Assurance Program of Consu.mP.rs Power Company. *During the Palisades SGRP and ma.,jor modifications, QJiality Assurance*

Engineering & Inspection assigns personnel within .

the organization to review the i

Quality Assurance Program of C~ Co's Suppliers and lower-tier Suppliers. During I,

operation,. ma)..ntenance, repair and minor L1odifications, this responsibility is assigned to the Director, Quality Assurance-Nuclear Operations, and off*site and on-site committees established for that purpose. The results of these reviews are

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reported to Consumers Power Vice PresiC).ents responsible for the respective activities *

2. 0 BliSIS DOCUMENTS

a. NRC 10 CFR 50, Appecdix B, Criterion 2, Quality Assurance Program

b. il.NSI Nl8. 7

c. ANSI N45.2, Criterion 2, Quality Assurance Program 3 .O POLICY 3 .1 REVIEW DURING 'l'HE DESIGN .A.ND CONSTRUCTION PHASE During the Palisades SGRP and major modifications, the Director, Environmental I Services, QJ.lality Assurance & Testing monitors design and procurement activities. j and maintains surveillance over construction and installation activities. During I de.sign and construction of the Midland Project, the Midland Quality Assurance Manager monitors design and procurement activities and maintains surveillance over constructlonj and installation. Quality Assurance personnel, or Quality Assurance personnel under Contract to Consumers Power perform the following functio.ns:

a. Review and approval of Consumers Power Principal Suppliers Quality Assurance Programs prior to commencement of activity.

b. QJ.lality Assurance audits and surveillance of Suppliers to assure that the requirements contained in design and procurement documents, speci-fications, and Quality Assurance Programs are met.

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QUALITY ASSURANCE PROGRAivi POLICY POLICY MO 19 PAGE 2 Of 4 .-*~

consumers Power PROGRAM REVIEW REVISlmJ 10 DATE 9/26/80 I-* "

c. Re\riew of spec~fications, drawings, procedures, inspection checklists and other pertinent documents for Quality Assurance requirements.

d. Quality Assurance audits.and surveillance at the nuclear plant site to*

evaluate the performance of contractors and subcontractors in implementing their Duality Assurance Programs *

. e. Witnessing the performance of work activities aad of construction and installation tests and inspections to assure that specified requirements are met and that required records are maintained. *

f. Audits of the Consumers Power departments to assure that they are -complying with the CJ:uality Assurance Program for Nuclear Power Plants and Department or Plant Procedures.

go Reviei-1 of non-conforming conditions to detect trends requiring corrective action.

'['hese reviews, audits and surveillances are documented and reported to management personneJ.. a.nd to the responsible department 'heads in accordance with Qua,lity Assurance Program Policy No 20, "Program Reporting.n

• 3. 2 TIE VIEW DUTI.ING T"rlE OPERATIONS PH.ASE I~ addition to auc:its conducted by the Quality Assurance Department.- Nuclear O]?erati.onn-$ Consumers Power has established the on-site Plant Review Committee (PRC) and the off-site Safety and Audit Re-\':i.ew Board (SARE) for the purpose of reviewing safety-related aspects of plant operations, maintenance, modifications and technica.l.

matters involved in operating a nuclear power -plant. Quality Assurance - Nuclear O:perations, alao performs ~udits in these areas and submits the results for review.

Minutes and. re:pcrt::i of the activities of these review groups are routinely sent to Q

departments chc-.rr.:;ed with implementing the Quality Assurance Program. The functions and  ;.~esponsibili ties of these committees are as follows:

a. Safety and Audit Review Board (S.4.RB)

• SARE is responsible for maintaining a continuing critical examination of safety-related plant activities, including observation of plant operation, evaluations of procedures and certain contemplated actions, and investi-gations of abnormal conditions to verify that such activities do not

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constitute an unreviewcd safety question:. ..../

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• QUALITY ASSURANCE PROGRAlVI POLICY POLICY NO 19 PAGE 3 OF 4 PROGRAM REVIEW REVISION 9 consumers Power DATE 3/18/80 In cases where an issue, report or problem is reviewed, evaluated or investigated by SARB, its findings and recommendations are communicated in writing to the Vice President - Nuclear Operations and the apprcpriate working level of Management. A written charter is prepared and approved by the Vice President - Nuclear Operations *which designates the membership, authority and rules ~or conducting the meetings. Boa.rd membershipj quali-fications, meeting frequency, quorum, responsibilities, authority and records are in accordance with the nuclear plant Technical SpecificationsQ be Plant Re~riew Corr,mi ttee (PRC)

The PRC is an advisory group composed of plant superviscriJ personnel, con-stituted for the purpose of :reviewing day-to.,,,day activities and determining the effect on operational. safety. The PRC recommends to the Plant Manager/

Suparintendent approval or disapproval of proposals considered by the Committee and makes tentative determinations as to whether or net prc:?Osals involve unreviewed safety questions. Board membership, qualifications, meeting fraquency, quorum, respcnsibilitiesJ authority and records are in accordance with the nuclear pla.nt Technical S:pecifications.

During operations, maintenance, repair and minor modifications, the Director, Quality Assurance - Nuclear O:perations, monitors procurement activities and maintains surveillance over safety-related plant operating conditions~ Nuclear Operations personnel, or Quality Assurance personnel under Contract to Consumers Power, conduct reviews, audits and surveillances similar to those J)reviously identified in Paragra~h 3.1 of this Policy. The results are documented and reported to the Vice President ~ Nuclear Operations, in accordance wi*th Quality Assurance Program Policy No 20,. 11Progra.'Il Reporting."

3. 3 REVIEW OF CORPORATE GUft.L ITY ASSURANCE PROGRAM The review of the Consumers Power Cori:>orate Nuclear Quality Assurance Program is performed at least once every*24 months by an audit as described in Section 3.l of (tuality Assurance Program Policy No 18, "Audi.ts." The audit is documented and reported to the Senior Vice President - Projects, Engineering & Construction, the Director, Environmental Services, Quality Assurance & Testing, the Vic~ Presiden*t - Midland Proj ectl) the Executive Manager or Transmission, Pl.ant ModUications & Project Services, the I I

QUALITY ASSURANCE PROGRAl\!l POLICY POLICY NO 19

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• PROGRAM REVIEW REVISION 10 consumers Power DATE 9 /26/80 Vice President - Nuclear Operations, and the Executive Vice President - Energy Supply for th~ir responsibility areas. It is the responsibility of the Executive Vice President - Energy Supply and the .Senior Vice President - Projects, Engineering

& Construction to evaluate and approve recommendations there from and to inform the President a..'1.d Chief Executive Office of the company in accordance with Quality Assurance Program Policy No 20, "Program Reporting~"

I Approved by:

&~c-~~~QI Q,,,,~dd 1/,5

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      ~r}ic.:._* vice Pr2sident.GiA -~ _,,-,_

0 Executj t~ Vicj=- President i Vi"Ce President II Projects, Engineering 1 _,....._.,. " ;Enprgy Supply . / Midland .Proj,,ct

           & Construction                                       I                               ,o.)/"'~/~
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   ~ . . I /1./;/IL{ ,  / J ..!..vv              /f
    * -*-* Vice President Nuc1ear Operations

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e* QUALITY ASSURANCE PROGRAM POLICY POLICY NO 20 PAGE 1 OF 6

                                                 .PROGRAM REPORTING REVISION      9 consumers Power                                                                                       DATE    3/18/80 1.0       GENERAL Reports of nonconforming conditicns, departures from normal operations, special nualear material status and transfers, changes in facilities and procedures, and nuclear plant status are prepared by Consumers Power Company and suopitted to the NRC and..... to the responsible departments according to the requirements set forth in Title

. 10 Code of Federal Regulations, applicable ANSI Standards, Regulator;;- Guides and the Plant Technical Specifications. Consumers Power Company requires suppliers: (a) to report potential;Ly significant nonconformances to Consumers Power Compa_ny for determina-tion of 10 CFR 50.55(e) reportability to the HRC; and (b) to comply with 10 CFR 21. 2 .O BASIS DOCl'MENTS

a. NRC 10 CFR 19, "Notices, Instructions and :S.eports to Workers; Inspections"

b. HRC 10 CFR 20, "Standards for Protection Against Radiation" j

c. NRC 10 CFR 21, "Reporting of Defects and Noncompliance"

d. NRC 10 CFR 50, Appendix B, Criterion 16, "Corrective !-1.ction"

e. NRC 10 CFR 50.55, "Conditions of Construction Permits", Paragr_aph (e)

f. NRC 10 C:F'.R 59, 11.t\ut.ho.rization o!, Changes, Tests and E;cperimcnts"

g. NRG 10 CFR 70.52, riReports of Accidental Criticality or Loss of' Special Nuclear I I*f3terial"

h. NRC 10 CFR 70.53, "Material Status Reports"

i. NRC 10 CFR 70 .54, "Nuclear Material 'rransfer Reports"

j. NRC Regulatory Guide No. 1.16, "Reporting of Operating Information"

k. PJISI :Nl8.7, Section 4, "Review and Audit 11

1. Plant Tecln1ical Specifications

m. ANSI N45 .2_, Crite::.-ion 17, "Corrective Action" 3.0 POLICY 3.1 REPORTING DURING THE DESIGN Al'ID COl'TSTRUCTION FRASE FOH NEW FACILITIES, MAJOR MODIFICATIONS AND THE P .ALISADES SGRP

3. l. l REPORTS BY ENVIRONMENT.AL SERVICES, Q.UAL ITY .ASSURANCE & TESTING Environmental SerYices, Quality Assurance and Testing prepares and issues a monthly status report to the Senior Vice President - Projects, Engi-neering & Construction. Q~ality Assurance Audit & Administration performs audits of the Quality Assurance Program and reports the results of the audits to the Director, Environmental Serrices, Q.uali ty Assurance & Testing; to the

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QUALITY ASSURANCE PROGRAM POLICY POLICY NO 20 PAGE 2 OF 6

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10 , .>I _PROGRAM REPORTING REVISION cons1Jmers rower DATE 9/26/80 to the Vice President - Midland Project (for Midland Project related activities}, to the Executive Manager - Transmission, Plant Modifications and Proj_ect Services (for related activities) and to other members of management who have either functional or line responsibilities, or both, for the audited area or activity. These reports summarize quality-related problems and nonconformances and describe the status of their resolution, I The Director - Environmental Services, Quality Assurance & Testing conduc\s 11

        . biannua1 status meetings with the officer in charge and with the heads of depart-

• ments involved in implementing the Quality Assurance Program.

Each "bienuiUID, a major audit of the Quality Assurance Program is conducted and reported to the Senior Vice President - Projects, Engineering & Ccnstri.1ction. The Senior Vice President - Projects, Engineering & Construction is respon-sible for transmitting pertinent quality-related problems and nonconforman.ces

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to the President and Chief Executive Officer. .j 3 .1. 2 REPOR'l.1 8 BY MIDLAND PROJECT QUALITY ASSURJiJ~CE Midland Project Quality Assurance prepares and issues a monthly status repo:;_~t to the Vice President - Midland Project *who in turn issues a monthly sta~us report to the Senior Vice President - Projects, Engineering & Construction. 4:'t Result~ of audits l'~rf'ormed by .Midland P:::-oj ect Q,uali ty Assurance are reported to the Vice Presider.t - Midland Project, Director - Environmental Services, Quality Assurance & Testing and to other members of management who have either functional or line respc:-i.sib:i..li ties for the audited area or activity. These reports smrunarize q_uali ty-related problems .and non conformances and describe "V!ie status of their resolution. The Midland Proj ec:t Quality Assurance :Men ager con-ducts q_uarterly status meetings with the officer in charge,* the Midland Project Manager, the Director - Environmental Services, Quality Assurance & Testing, and other personnel as applicable. 3.1. 3 REPORTING SIGNIFICANT CONDITIONS TO THE NRC Significant nonconformances are recorded *on nonconformance reports an3. are controlled in accorda.rice with Q.uality Assurance PrograJn Policies No 15, "Control of Nonconforming Items" and No 16, "Corrective Action." Each such nonconform=-i

l QUALITY ASSURANCE PROGRAM POLICY POLICY NO 20 PAGE 3 OF 6 PROGRAM REPORTING REVISION 10 r.onsumers Power DATE 9/26/80 occurring during the design and construction of the Midland Project is promptly reviewed by the Midland Project Quality Assurance Department or, when occurring during preoperational testing, by Midland Pro,ject Testing to determine its reportability to the NRC under the req_uirements of 10 CFR 50.55(e) and 10 CFR 21. Each nonconformance report originated during the design and construction of a

           ~    ~ajar   modification, to an existing operating plant, or the Palisades SGRP is transmitted to the Plant rVlanager;'Superintendent for review and evaluation as the NRC reportability in accordance with the requirements given in Paragraph 3.2.2 of this Policy.

As applicable, nonconforn1ances which a.re reportable under 10 CFR 5a°.55(e) a,re orally reported to the NRC by Mid.J,.and Project Q.u.ali ty Assurance within 24 hours after their occurrence. Each such oral report is followed within 30 days by a written report to the NRC from the _officer in charge. Also, as e.pplicabl~, nonccnformances which are reportable U.11.der 10 CFR 21 are orally reported to th~

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( . Irnc by Midland Project Quality Assurance within 2 days 2.fter their evaluation.

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               *Each such oral report is :followed within     5 days by a written report to the NRC from the officer in charge.

3. l. 4 SUPPLIER RE..<U'ONSIBILITIES Constuners Power C0nr9any requires sm.Jpliers to report each potentially significant noncon:formance to the responsible 'tu.ali ty Assurance, organizati_on and to the organization having project management responsibility. Each such nonconfor.rn.a.nce is reviewed and evaluated for reportability to the lIBC in accor-dance witn the process described in Paragraph 3.1.3, above. In addition, Consumers Powe+ Company requires suppliers to comply with 10 CFR 21 for all procurements issued by Consumers Power Company after January 6, 1978, in accordance with the provisions delineated in 10 CFR 21.

3. 2 REPORTING DURING THE OPERATIONS PHASE 3.2.l QUALITY PROG.ltfl1*1 STATUS REPOR'IS The Director, G;llality Assiu*ance - Nuclear Operations, prepares and issues a monthly status report to the Vice President - Nuclear Operations, and I

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QUALITY ASSURANCE PROGRAM POLICY POLICY NO 20 PAGE 4 OF 6 .

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PROGRAi~ REPORTING REVISION 9 co11sumers Power DATE 3/18/80 I he to the Executive Vice President - Energy Supply. The report summarizes qu.ality-related problems and nonconformances, describes the status _of resolution, and makes recommendations for required actions. In addition, the Quality Assurance - Nuclear Operations Departffient conducts ~uarterly status meetings

       *with the Yice President - Nuclear Q:pe:i:ations and the Consumers Power departmerits invol vetl in    ii'D}?lem~nting   the Quali t~* Asstu'tmce Frog.cam for Operations.

3. 2. 2 EVENT REPOHTHJG Reportable events D:!C.un*ing at the plant site as defined by the Technical Specifications, violations of or events defined as reporta"ble in Title 10 Code of.Federal Regulations, undesirable trends in _performance or a radioactive releEise h~ycr.d specified limits are docu.'!:ented by the Supervisor of the area or acti*,*ity involved. 'l'he condition or event is reviewed by the Plant lfanager/Super-intenclent or his designated representative to assure that actions taken are in compliance with the Technical Specifications and Title 10 Code of Fe0. eral Regu-

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lations. Documentation of the event and actions taken are provided by the Plant :_._,J Man::i.ger/Superintendent. He reports pro:rnptly to the Vice President - lfuclear Operatior::s arid to the NRC as required by the Technical Specifications or Title

                                                                                                                                .I 10 Gode of Federal Regulations.              Appropriate corrective action is taken according to Policy 16, "Corrective Action."              Resolution of these events, including co:i:recti ve action, is reported to t:he Vice President -            ~iuclear      Operations and the N:8C as required by the Technical S:i:iecifications and Title 10 Code of Federal Regulations.

3 .2. 3 REPOTIT1TG CHAITGES IN FACILITIES OH PHOCZ:DlJP..8.S, TESTS A.I'll EXPEf-G1-E1Tl'S Safet:e -related char:ges to plHr.t facilities or procerJ.u. res during operation:::; i.e._, plant modifications and the ccnduct of tests and experirn.ents not covered

     'by the Plant Safety Analysis Heport, are .rev-iewed by appropriate Management, Plant Revi01-1 Committee (PRC) and the Safety and Audit Review Board (SARE)           ..

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                                                                                                         ...... '-',J implications according to the re g_uirements set forth in 10 CFR. 50. 59 <.u:.d t!:ie Teci1!1ical Specifications.            Results of these revie;;s are docu:m:nted b~r the Plc;nt Staff. The Plant Hanar;er/Superintendent directs the preparation of a report de-scribing the cbane;es, tests and experiments and a summary of the evaluatj_on of each case.      Chan~~es   to the facility or procedurr-::s, as described in the FSJ\Il, summaries of the        safc~y evnlu~tions   are reported s.t le:e.:3t annually 01* upon   requc!s1.~.
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QUALITY ASSURANCE PROGRAiVI POLICY POLICY NO 20 ,/\ *PAGE 5 *. OF 6 <.. __./ PROGRAM REPORTING REVISION 9 consumers power DATE 3/18/80 3.2.4 SPECIAL NUCLEAR MATERIAL (SNM) STATUS The Plant Manager/Superint.endent directs the preparation of NRC Form 742, in accordance with Plant Procedures and 10 CFR 70.53. This report identifies the SI%I material received, produced, possessed, transferred, consumed, disposed of'

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or lost and is filed in accordance with 10 CFR 70.53. HRC Form 741 is the.princi:;:ial document supportinc;.the transaction of receiving S:Nl'-1 by Consumers Power or shipping SN"M by Consumers Power. 'rhe Plant Manager/Superintendent directs the* preparation of Form 741 and, as the responsible Consumers Power Official, signs the form, both upon receipt and shipr:ient off-site of SNM. Copies of' the form are distributed, according to Plant Procedures and the re g_uirement s of 10 CFR 70. 54. 3 . 2. 5 Al'ITTUJ'.L OPEHATING REPORrS, E1TllIROT-ll*BNTAL EOHITORIHG :REPORTS AND SPECIAL REPORTS Annual Operating Reports, Emriro:r.mental ~-~onitorine: Reports and Special Reports are prepared accord:i.~g to the requirements of the '.I'echnical Specifications by ti1e Plant or General Office Sta.ff 2s directed by the Nu.clear Licensing I J;dministrator. These re9ori:s are approyed *oy him for sn"'.:Jmittal to the HRC. I

3. 2. 6 SlJPPLIER EESPONSIBILITIES Consi.;..'llers Power Company req_uires suppliers of safety-related items and I

               ~ervices     during the operations phase to comply         i~ith  10 CFR 21.

3. 2. 7 REPORTING OF AUDITS OF CORPORATE Q.UALIT'l ASSURANCE PROGRAM Every t1-ro years, a major audit of the Consi.uners Power Corporate Q,uality Assurance Program is conducted and reported to +,he Vice President - nuclear Oper::i.tions and Executive Vice President - Energy Supply. ':!?he report smmnarizes quality-related problems and noncon.form:i.nces, describes re0olutions, arrd nUJ.kes reconi. menda tions of where Q.uali ty Assurance Program Policies or Procedures might be improved. It is the responsibility of the Executive Vice President - Energy SL1?ply to evaluate and approve recommendations therefrom and to inform the President and Chief Executive Officer of Pertinent audit results,

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POUCY NO 20 QUALITY ASSURANCE PROGRAiv1 PDLICY 6 6 PROGRAM REPORTING r? ~ .*

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Vice President Nucle,'.:c Operations I I I I I

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