ML20148N925

Rev 18 to CPC-2A, Quality Program Description for Operational Nuclear Plants

ML20148N925
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	06/06/1997
From:	English C, Fenech R, Joos D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20148N916	List: ML20148N918 ML20148N925
References
CPC-2A, NUDOCS 9707010004
Download: ML20148N925 (110)

Text

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CONSUMERS ENERGY COMPANY l 1

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SUBJECT:

STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS ENERGY PROGRAM FOR OPERATIONAL NUCLEAR POWER l PLANTS As President and Chief Executive Officer of Consumers Energy, I have the ultimate management authority for the Consumers Enerav Quality Prooram Descriotion for Ooerational Nuclear Power Plants. The Quality Program Description complies with the quality assurance

! requirements contained in Appendix B of 10 CFR 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the additional guidance contained in ANSI N18.7, and to the ANSI N45.2 Series of Standards and corresponding Regulatory Guides within the context of applicability imposed by N18.7. The Quality Program l 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 l to the Sr. Vice President, Nuclear, Fossil and Hydro Operations. I have delegated selected l l portions of the Quality Program to the Vice President, Electric Transmission and Distribution; l Vice President, Information Technology and Operations Services Division; and through a Vice Chairman of Consumers Energy to the Vice President and Secretary. This Quality Program Description describes the Consumers Energy organizations responsible for implementation.

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

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l QUALITY PROGRAM DESCRIPTION

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OPERATIONAL NUCLEAR POWER PLANTS  ;

l REVISION 18 l

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l APPROVED BY: l 1

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EMve Vice residen and Chief Operating Officer Electric '

Da'te l David W. Joos ,

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l Sr. Vice P' resident, N' uclear, Fossil, and Hydro Operations Date Robert A. Fenech VIce President, Electric TranMsion and Distribution W/W9*) ~

Date' Carl L. English l

l 6 - @ 6/Y/77 Vice President, Inforrnation Technologand tions Services Date Kenneth Emery

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S/30/97 Vice President and Secretary ' Date Thomas A. McNish l

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Ptga lii Ray 18 Date: June 6,1997 QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS CONTENTS Section Title Page Statement of Responsibility and Authority i Approval Page il Contents iii 1.0 ORGANIZATION ..................................... ....... 1 2.0 QUALITY PROGRAM ........................................ 10 3.0 D E S IG N C O NTRO L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 4.0 PROCUREMENT DOCUMENT CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS . . . . . . . . . . . . . . . . . . . . . 19 0.0 DOCUMENT CONTROL . . .................................... 22 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES . . . . . . . 24 8.0 IDENTIFICATION AND CONTROL OF ITEMS . . . . . . . . . . . . . . . . . . . . . . . . 26 9.0 CONTROL OF SPECIAL PROCESSES ............................. 27 10.0 I N S P E CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 l 11.0 TEST CONTROL ..................................... ..... 31 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT . . . . . . . . . . . . . . . . . . . 33 13.0 HANDLING, STORAGE AND SHIPPING . . . . . . . . . . . . . . ............. 35 l 14.0 INSPECTION, TEST AND OPERATING STATUS . . . . . . . . . . . . . . . . ..... 36 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS . . . . . . . . . . . . . 37 16.0 CORRECTIVE ACTION . . . . . . . . . ............................. 39 l 17.0 QUALITY RECORDS . . ............................ ......... 40

! 18.0 A U DITS . . . . . . . . . . . . . . . . . . . . . ... ....................... 42 I

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1 APPENDIX A . . . . . .. ... ........ ............. .................... 44 APPENDIX B ....... .......................... .. ......... ......... 71 ,

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APPEN DIX C . . . . . . . . . . . . . . . . . . . .... .. ............................ 74 1

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

APPENDlX E ............... . . ..... .. ....... ................ .. 78 l

FIGURE l l 1 Consumers Energy Corporate Organization . .............................. 9 I

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Paga 1 Rsv 18 Date: June 6,1997 1.0 ORGANIZATION 1.1 REQUIREMENTS l

Consumers Energy is responsible for establishing and implementing the Quality Program, as l described herein, for the operational phase of its nuclear power plants. Although authority for development and execution of some parts of the program is delegated to others, such as contractors and consultants. Consumers Energy retains overall responsibility. l This section of the Quality Program Description (QPD) identifies the Consumers Energy l organizations responsible for activities affecting the quality of safety-related nuclear power plant structures, systems and components and describes the authority and duties assigned to them. It addresses responsibilities for attaining quality objectives; for establishing and main-taining the Quality Program; and for assessing the performance of activities affecting the quality of safety-related items. The control of this Quality Program Description is the responsibility of the Nuclear Performance Assessment Department.

Nuclear Performance Assessment Department (NPAD) functions (audits, surveillances, and independent safety reviews) are performed by personnel within formally designated or-ganizational units that report to the Manager, Nuclear Performance Assessment or members of other organizations as selected by the Manager, Nuclear Performance Assessment. The reporting level of the Nuclear Performance Assessment organization affords sufficient authority and organizational freedom, including sufficient independence from the cost and schedule impacts of Nuclear Performance Assessment organization actions, to enable people in that organization to identify quality problems; to initiate, recornmend, 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:

Paraaraoh Exceotions/Interoretations 1.2.1 2a i 1.2.2 2g 1.2.2.c 2,2b,2c 1.2 IMPLEMENTATION 1.2.1 Source of Authority The President and Chief Executive Officer (see Figure 1, Company Organization Chart) of Consumers Energy is responsible for safe operation of Consumers Energy nuclear power l plants. Authority and responsibility for establishing and implementing the Quality Program for plant operations, maintenance and modifications is delegated through the Executive Vice President and Chief Operating Officer - Electric to the Senior Vice President - Nuclear, Fossil, and Hydro Operations. This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Executive Officer. Other quality-related functions are provided by other organizations as described herein.

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[. Date: June 6,1997 l 1.2.2 - Resnonsibility for Attainino Quality Obiectives at the Nuclear Plants l

! l The Senior Vice President Nuclear, Fossil, and Hydro Operations (NFHO) is responsible to the ,

Executive Vice President and Chief Operating Officer - Electric for operation and maintenance l l of Consumers Energy nuclear power plants. Managers who report to the Vice President, l j

NFHO, are responsible for directing the performance of activities that affect safe plant i operation and/or safety-related functions of structures, systems and components of the operating nuclear power plants in accordance with Quality Program requirements.

a. The Palisades Plant Site Vice President (see Figure 1) is responsible to the Senior Vice President, NFHO for operation and maintenance of the nuclear power plant in such a

! manner as to achieve compliance with Plant licenses, applicable regulations and the l l Quality Program. The Site Vice President delegates to appropriate managers and staff pSrsonnel in his organization responsibility for carrying out applicable controls required by l the Quality Program. Quality Program activities performed on the authority of the Site Vice President include:

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

Preparation, review and approval of procedures and instructions.

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

Maintaining Echelon lli calibration facilities for Portable and Laboratory Measuring and Test Equlpment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE).

Calibration / maintenance of installed plant instrumentation.

! Maintaining a calibration recall system.

l 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 surveillante testing.

Maintaining equipment status control.

l i Maintaining required controls over chemical standards and reagents, i

I Developing, maintaining and implementing site emergency plan.

Conducting a water chemistry program in accordance with technical specifications, t

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

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Date: June 6,1997 Plant site inspection program, including inspection of maintenance, testing and fuel i handling.

Assuring that nonconforming items are identified, segregated and dispositioned. _

Procurement of nuclear fuel and associated services, including source verification at fuel i supplier facilities, iuelinspection upon delivery and review of fuel supplier quality-related documentation l

l Reactor engineering suc h as accident-transient and physics analysis of reloads, reactor I

core and nuclear fuel design and core thermal-hydraulic and nuclear support of plant l modifications and opert tions.  ;

l LDevelopment and utilizr, tion of nuclear plant probabilistic safety assessment models to j evaluate safety and plant reliability improvement I

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

Conducting the inservice inspection program in accordance with technical specifications l and State of Michigan rules.

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, Performing reviews to advise the Site Vice President on matters related to nuclear safety, l I i as specified in Appendix B, Plant Review Committee.

l Accomplishing plant licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accomplishing and/or tracking licensing commitments and coordinating internal action on NRC bulletins, generic letters, etc.

l 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 prepar-l ing, reviewing and approving changes to plant engineering / design documents.

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

Providing, as requested, technical expertise and review capability to Nuclear Plants in the areas of metallurgy, special processes, coatings, electrical, mechanical and civil-structural engineering and application of codes and standards.

Preparation, review and approval of Q-list updates.

Performing analytical studies to appraise the adequacy of electrical supply to safety-I related equipment in nuclear power plants from the principal power supply facilities of the transmission network and onsite power supply.

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Date: June 6,1997 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 surveil-lance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.

Providing for storage and protection of purchased materials and items and items awaiting disposition implementation 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 documents.

b. The Big Rock Point Plant General Manager (see Figure 1) is responsible to the Senior Vice President NFHO for operation and maintenance of the nuclear power plant in such a manner as to achieve compliance with Plant licenses, applicable regulations and the l Quality Program. The Plant General Manager delegates to appropriate managers and staff personnelin his organization responsibility for carrying out applicable controls required by the Quality Program. Quality Program activities performed on the authority l 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.

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

Modifying components, including procurement, installation, inspection and testing l activities when assigned by the Plant General Manager.

Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifications limits.

Maintaining Echelon 111 calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE).

Calibration / maintenance of installed plant instrumentation.

Maintaining a calibration recall 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.

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I Ptge 5 Rav18 Date: June 6,1997 Maintaining equipment status control.

1 Maintaining required controls over chemical standards and reagents.

Conducting a water chemistry program in accordance with technical specifications.

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

Plant site inspection program, including inspection of maintenance, testing and fuel handling.

L Preparation, review, and approval of Q-list updates, l 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 indoctrinatiori and training.

Development and utilization of nuclear plant probabilistic safety assessment models to l evaluate safety and plant reliability improvement. -1 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 surveil-lance or inspection, receiving inspection, and review of supplier quality-related documentation, as well as vendor surveys for urgent procurements.

Providing for storage and protection of purchased materials and items and items awaiting disposition implementation 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 commitments and coordinating internal action on NRC bulletins, generic letters, etc.

Providing evaluation, processmg and status reporting for assigned corrective action documents, including determination of NRC reportability.

l Operating experience reviews including NRC Information Notices.

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

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PIga 6 R;v18 Date: June 6,1997 Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules.

Developing, maintaining ano implementing security, fire protection and emergency plans.

l Performing reviews to advise the Plant General Manager on matters related to nuclear safety, as specified in Arpendix B, Plant Review Committee.

l 1.2.3 Resoonsibilities of the Nuclear Performance Assessment Decartment The Manager, Nuclear Performance Assessment Department, (see Figure 1) is responsible l to the Senior Vice President, NFHO, fot:

Assessment of the effectiveness of the Nuclear Operations Quality Program.

Performance of the offsite safety review functions for 9e 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 Nuclear 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 Site Vice President, the Plant General Manager, or the Senior Vice President NFHO that a plant be snut down if such action appears necessary Assessment programs (plant sites and Corporate Office), including follow-up on corrective action for audit findings.

l Review of performance trends associated with nuclear plant activities including corrective actions.

Analysis of new and/or changed regulatory direction, codes and standards to determine their effect on the Quality Program.

Maintenance of the Quality Program Description for Operational Nuclear Power Plants.

Reporting audit findings relative to follow-up on corrective actions and the effectiveness l of the Quality Program to Consumers Energy Management.

Maintenance / operation, processing and status reporting of the corrective action system (Palisades only).

l Facilitation of Self-Assessment and Quality Verification Programs (PalisaJes only).

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Pago 7 i Rev 18 Date: June 6,1997 l In order to implement these responsibilities, the Manager, NPAD, is provided with "Stop Work" authority wh(reby he can suspend any quality related activity or process which may, in his opinion, adversely affect public safety or the safe operation of Consumers Enurgy nuclear plants. A Stop Work order that would result in plant shutdown is given i 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 respon-sibilities unrelated to Nuclear Performance Assessment that would prevent his attention to Nuclear Performance Assessment matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality considerations in his decisions and recommendations, and has direct access to high enougt levels et Management to obtain resolution of quality problems.

1.2.4 Resoonsibilities of the Eauioment Services Deoartment l The Manager, Equipment Services provides electrical, rotating and stationary equipment l expertise, including developing and qualifying procedures for welding and heat treating.

1.2.5 Resoonsibility for Attainina Quality Obiectives Outside Nuclear. Fossil. and Hvdro Ooerations l

Certain functions that constitute part of the Nuclear Quality Program are performed by Consumers Energy organizational units outside the Nuclear, Fossil and Hydro Operations Department. Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization 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 Distribution to the Executive Vice President ind 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 Executive Manager, Fuels & Power Transactions is responsible to the Executive Vice President and Chief Operating Officer Electric for maintaining the Records Management System including required retention, protection and retrievability. This includes collect-ing, storing, maintaining, distributing and controlling plant engineering / design documents (Big Rock only). lais 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.

c. The Manager, Production Services (see Figure 1) is responsible through the Vice President Electric Transmission and Distribution to the Executive Vice President and Chief Operating Officer - Electric for operating the Skill Centers including the training, and qualifying of personnel and equipment fer welding operations,

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

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P:ga 8 Rav 18 Date: June 6,1997 l e. The Manager, Environmental and Technical Services (E&TS) is responsible, through the Vice President, Information Technology and Operations Services to the President and Chief Executive Officer for:

1 Maintaining the Company's Echelon 11 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.

l l Providing a PL-M&TE inventory List for Nuclear plants.

l l Providing chemistry support to Nuclear plants, as requested.

l Preparing, reviewing, approving and obtaining additional reviews and approvals if required, of purchase requests for services, equipment and consumables, and submitting such requests to purchasing for procurement action.

Conducting performance tests on materials, equipment and systems when requested.

Performing nondestructive examination, and controlling / maintaining NDE equipment.

Providing qualified NDE procedures and equipment and NDE personnel.

Providing chemical and metallurgical analytical services.

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

l f. The Manager, Electric Services is responsible, through the Vice President, Electric Transmission and Distribution to the Executive Vice President and Chief Operating Officer

- Electric for testing and maintaiaing electrical protective devices, performing design verification testing associated with electrical protective schemes, devices and application of associated settings.

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Vice Pressdent Electric Senior Vice President Executive Meneger Manager Transmission & Nuclear, Fossil. & Hydro Fuels & Power Environmental &

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Figure 1 - Company Organizational Chart for Operational Nuclear Power Plants u ____ _ _ _ _ __ _,__ _ _ - -

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2.0 QUALITY PROGRAM l 2.1 REQUIREMENTS l l Policies that define and establish the Consumers Energy Quality Program for Operational Nuclear Power Plants are stated in the individual sections of this document. The program is implemented through procedures and instructions responsive to provisions of the Quality Program Description and will be carried out for the life of each plant.

Quality controls apply to activities affecting the quality of safety-related structures, systems and components, to an extent based on the importance of those structures, systems, or 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 l regularly reviewed by Consumers Energy Management through reports, meetings and review of audit results. A preplanned and documented assessment of the nuclear safety performance is conducted as described in Appendix C.

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

Paraaranh Exceotions/Interoretations l 2.2.3 21 a, 21.b 2.2.5 19a l 2.2.6 1,19,21a,21b 2.2.9 2j, 4a, Sa, 5b, 6a, 7b,10a, l l a,12a,12b,12c,12d,13a,17e 2.2.10 2e, 2f 2.2 IMPLEMENTATION l 2.2.1 The President of Consumers Energy, as Chief Executive Officer, has stated in a formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy to comply with the provisions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10 CFR 50, 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.

l 2.2.2 The Quality Program at Consumers Energy consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION).

2.2.3 The affectivity and applicability of this Quality Program Description are as follows:

a. For Big Rock Point and Palisades, the Quality Program Description became effective on April 1,1982, with full implementation on January 1,1983.

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b. The Quality Program described in this Quality Program Description is intended to apply for the life of Consumers Energy's nuclear power plants.

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c. The Quality Program applies to activities affecting th0 quality of safety-related structures, systems, components and related consumables auring 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.

2.2.4 This Quality Program Description, organized to present the Consumers Energy Quality Program l for Operational Nuclear Power Plants in the order of the 18 criteria of 10 CFR 50, Appendix B, states Consumers Energy requirements for each of the criteria and describes how the controls l pertinent to each are carried out. Any changes made to this Quality Program Description that do not reduce the commitments previously accepted by the NRC must be submitted to the NRC at least annually as specified by 10 CFR 50.71.e. Any changes made to this Quality l Prog am Description that do reduce the commitments previously accepted by the NRC must be submitted to the NRC and receive NRC approval prior to implementation in accordance with the requirements of 10 CFR 50.54.

The program described in this Quality Program Description will not be changed in any way that would prevent it from meeting the criteria of 10 CFR 50, Appendix B.

2.2.5 Documents used for implementing the provisions of the Quality Program Description include the following:

a. Administrative procedures specify the standard methods of accomplishing operational ,

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

b. When Contractors perform work under their own quality assurance programs, these programs are reviewed for compliance with the applicable requirements of 10 CFR 50, Appendix B and the contract, and are approved by Consumers Energy prior to the start of l work,

c. Applicable elements of the operations Quality Program are applied to emergency plans, security plans, radiation and fire protection plans for Consumers Energy nuclear power l plants. These plans describe quality controls applicable to associated equipment and activities.

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

Appendix A to this Quality Program Description lists the ANSI Standards and Regulatory Guides to which Consumers Energy commits. Appendix A also describes necessary excep- l tions and clarifications to the requirements of those documents. The scope of the program and the extent to which its controls are applied are established as follows:

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l a. Consumers Energy 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 A).

. b. This identification by engineering personnel results in the classification of equipment as either safety related or non-safety related, and the inclusion of this classification in an equipment data base. This data base is available for inquiry by individuals involved in plant operation. The classification of structures, systems and consumables is also identified, documented, and controlled.

c. The extent to which controls specified in the Quality Program are applied to items is determined for each item considering its relative importance to safety. Such determina-tions are based on data in such documents as the plant safety analysis, plant Technical Specifications and the FSAR/FHSR (See Appendix A).

2.2.7 Activities affecting the quality of safety-related items are accomplished under controlled conditions. Preparations for such activities include confirmation that prerequisites have been met, such as:

a. Assigned personnel are qualified,

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

c. Specified equipment and/or tools, if any, are on hand to be used.

d. Materials and items are in an acceptable status,

e. Systems or structures on which work is to be performed are in the proper condition for the task.

f. Authorized current instructions / procedures for the work are available for use.

g. Items and facilities that could be damaged by the work have been protected, as required.

h. Provisions have been made for special controls, processes, tests and verification methods.

2.2.8 Development, control and use of computer programs affecting nuclear power plant design and l operation at Consumers Energy are subject to Quality Program design controls (see Section 3.0, DESIGN CONTROL).

2.2.9 Responsibility and authority for planning and implementing indoctrination and training are l specifically designated in the Consumers Energy organization (see Section 1.0, ORGANIZATION).

a. The training and indoctrination program provides for ongoing training and periodic refamiliarization with the Quality Program for Operational Nuclear Power Plants.

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b. Personnel who perform inspection and examination functions are qualified in accordance with requirements of Regulatory Guide 1.58, SNT TC-1 A, or the ASME Code, or Section 10.2.3 of this Quality Program Description, as applicable,

c. Personnel who lead audits are qualifid in accordance with Regulatory Gede 1.146.

Others are either qualified to ANSI N ").2.23 or have detailed expertise in the area being audited.

d. Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with applicable codes, standards and regulatory guides,

e. The training / qualification 5 rogram for personnel leading audits includes provisions for retraining, reevaluation and *ecertification 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 Consumers Energy l ;

Management. The following activities constitute formal elements of that assessment: '

a. Audit reports, including follow-up on corrective action accomplishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).

b. 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 recomrnendations are tracked in the regular corrective action tracking system (see Section 16.0, CORRECTIVE ACTION).

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pig 314 Rrv 18 Date: June 6,1997 3.0 DESIGN CONTROL l 3.1 REQUIREMENTS Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled.

Depending on the type of modificaticn, these activities include design and field engineering; the performance of physics, seismic, stress, thermal, hydraulic, radiation and Safety Analysis Report (SAR) accident analyses; the development and control of associated computer programs; studies of material compatibility; accessibility for inservice inspection and maintenance; and determination of quality standards. The controls apply to preparation and review of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents.

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

Paraaraoh Exceotions/Interoretations 3.1 9a,13b 3.2.9 15a 3.2.10 13d 3.2 IMPLEMENTATION 3.2.1 Authority and responsibility for modification activities is under the cognizance of the Nuclear l Plants as described in Section 1.0, ORGANIZATION. This authority a1d responsibility includes the prepcfation, review, approval and verification of the following design documents: a)

System descriptions; b) Design input and criteria; c) Drawings and sjecifications; and d)

Engineering analyses and associated computer programs.

3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect structures, systems and components are documented. Action is taken to assure that the errors and deficiencies are corrected.

3.2.3 Materials, parts and processes that are essential to safety-related functions are selected and specified, based on the requirer"ents of applicable codes and standards or on known, successful use under similar conditions. This inck, des 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 approvai of " repair" or "use as is" dispositions of nonconformances.)

3.2.5 When modifications involve design interf aces between internal or external design organizations or across technical disciplines, these interfaces are controlled. Procedures are used for the review, approval, release, distribution and revision of documents involving design interfaces to CPC-2A.R18

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l l Page 15 l Rsv 18 Date: June 6,1997 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 i are made by the Consumers Energy organization having responsibility for engineering direction of the design effort. l

! 3.2.6 Checks are performed and documented to verify the dimensional accuracy and completeness

! of design drawings and specifications (i.e., the products of a design process).

l. 3.2.7 Modification design document packages are reviewed by Plant Engineering personnel to e l assure that the documents that they contain have been prepared, verified, reviewed and j approved in accordance with Company procedures and that they contain the necessary quality i

requiremen* These requirements include the inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and j test results.

I 3.2.8 The extent of and methods for design verification are documented. The extent of design a

verification performed is a function of the importance of the item to safety, design complexity, degree of standardization, the state-of-the-art and similarity with previously proven designs.

Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews.

These methods may be used singly or in combination, depending on the needs for the design under consideration.

When design verification is done by evaluating standardized or previously proven designs, the applicability of such designs is confirmed. Any differences from the proven design are documented and evaluated for the intended application.

Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated. This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function. Qualification testing is performed under conditions that simulate the most adverse design conditions, considering all relevant operating modes. Test requirements, procedures and results are documented. Results are evaluated to assure that test requirements have been satisfied. Modifications shown to be necessary through testing are made, and any necessary retesting or other verification is performed. Scaling laws are established and verified, when applicable. Test configurations ,

are clearly documented. )

i Design reviews are performed by multi-organizational or interdisciplinary groups or by single i individuals. Criteria are established to determine when a formal group review is required and when review by an individual is sufficient. '

Unless otherwise stated, the verification of design addresses allinformation conveyed by the l design document. When the verification is limited to certain areas or features, the scope or l extent and any limitations on the verification are documented.

3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience but are not CPC-2A.R18

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• 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 l 4

(2) He has not specified a singular design approach, ruled out certain design considerations i

or established the design inputs for the particular design aspect being verified, and a

(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, effectiveness, and technical adequacy of the use of supervisors as design verifiers to guard against abuse.

i 3.2.10 When designs must be released for use before they have been fully completed or before they l have been verified, the incomplete or unverified parts of the design and the hold point to j which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function. Justification for such early release is documented.

3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their use is specified.

3.2.12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original design. Such changes are evaluated for impact.

Those that affect fit, form, or function are reviewed and approved by the same, or equivalent, organizations that approved the original design. Information on approved changes is transmitted to all affected organizations.

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Pags 17 l l Rav 18 Date: June 6,1997 i t 4.0 PROCUREMENT DOCUMENT CONTROL i i

4.1 REQUIREMENTS l

j Procurement documents for safety related structures, systems, components and services j

define the characteristics of item (s) to be procured, identify applicable regulatory and industry -

j codes / standards requirements and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.

3 The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation

. of the requirements of this section of the QPD:

a e

Paraaraoh Exceotions/Interoretations 4

4.2.1 17c,17d

[ 4.2.3 21,17a,17b j 4.2.5 17d i

{ 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.

i i

Procurement request packages are reviewed and approved prior to submittal to the Purchasing  !

i and Materials Department. Review includes verification that the necessary quality requirements are specified.

) The responsible project engineer performs bid evaluations.

?

i

4.2.2 Supplier selection is described in Section 7.0, CONTROL OF PURCHASED MATERIALS, l EQUIPMENT AND SERVLCES.

4.2.3 The contents of procurement documents vary according to the item (s) being purchased and its

, function (s) in the plant. Provisions of this Quality Program Description are considered for l

$ application to suppliers. As applicable, procurement documents include:

1

a. Scope of work to be performed.

b. Technical requirements, with applicable drawings, specifications, codes and standards i

! identified by title, document number and revision and date, with any required procedures j '";ch as special process instructions identified in such a way as to indicate source and j need.

, c. Regulatory, administrative and reporting requirements.

1 J

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

i i, e. A requirement for a documented Quality Program, subject to Consumers Energy review 3

l and written concurrence prior to the start of work.

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Pagn 18 Rsv 18 Date: June 6,1997

f. A requirement for the supplier to invoke applicable quality requirements on subtier-suppliers.

g. Provisions for access to supplier and subtier suppliers' facilities and records for inspections, surveillances and audits.

l

h. Identification of documentation to be provided by the supplier, identification of documents to be compatible with the records system, the schedule of submittals and l identification of documents requiring Consumers Energy approval.

4.2.4 Trained, qualified personnel perform and document reviews of procurement request packages to assure that;

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 l Quality Program requirements.

4.2.5 Changes to the technical or quality requirements in procurement documents are controlled in a  ;

manner commensurate with that used for the original requirements. Those that could affect fit, form, fr* tion or the necessary assurance of quality are reviewed and approved by the same, or egivalent, organizations that approved the original procurement request packages.

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Paga 19 l Rsv 18 Date: June 6,1997 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS l

l 5.1 REQUIREMENTS l

l Activities affecting the quality of safety-related structures, systems and components are I accomplished using instructions, procedures and drawings appropriate to the circumstances l which include acceptance criteria for determining if an activity has been satisfactorily i completed. l l

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

Paraaraoh Exceotions/Interoretations 5.1 9a,13b 5.2.8 2r, 2s, 8a 5.2.14 6b 5.2 IMPLEMENTATION -

l i

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, l ORGANIZATION. Management personnel assigned these responsibilities assure that the instructions, procedures and drawings necessary to accomplish the activity are prepared and implemented.

Instructions, procedures and drawings incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and/or i qualitative (such as workmanship standards) acceptance criteria sufficient to determine that I the activity has been satisfactorily accomplished. l Temporary proceduros 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 Consumers Energy to controlits activities include the following: l

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.

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Pigs eO Rav 18 Date: June 6,1997

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 4

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 and test procedures that provide for:

a. Periodic calibration and testing of safety-related instrumentation and control systems

b. Calibration of portable measuring and test equipment used in activities affecting safety

11. Chemical-radiochemical contro! procedures that provide for activities including:

a. Sampling and analyses 1

b. Maintenance of coolant quality I

c. Control of deleterious ager.ts 1 1

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d. Control, treatment and management of radioactive wastes

, e. The control of radioactive calibration sources i 12. Emergency procedures that provide guidance for:

i

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 i b. Identifying symptoms of emergency conditions i

c. Monitoring automatic action j d. Immediate operator action I

4

e. Subsequent operator action i

13. Emerpency Plan implementing Procedures l 14. Inspection, test and examination procedures that identify:

a. Objectivos

b. Acceptance criteria

c. Prerequisite and special conditions

d. Limiting conditions

e. Test or inspection instructions

f. Any required special equipment or calibration

g. Hold and Witness points, as appropriate

15. Modification procedures that provide for:

a. Administrative control and technical support during plant modifications

b. The basis for a consistent method of performing recurring engineering, construction and quality activities 1

c. Control of the interfaces between Consumers Energy and its suppliers l

d. Control of onsite quality-related modification activities that assure the Quality l Program is implemented and its effectiveness is assessed and reported CPC-2A.R18

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6.0 DOCUMENT CONTROL

.l 6.1 - REQUIREMENTS Documents controlling safety-related activities within the scope defined in Section 2.0, QUALITY PROGRAM are issued and changed according to established procedures.

Docurnents 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.

l Changes to controlled documents are reviewed and approved by the same organizations that l performed the original review and approval or by other qualified, responsible organizations i 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 Site Vice President; or l 2. For Big Rock Point, he Plant General Manager.

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

Paraaraoh Exceotions/Interoretations 6.1 2h,2n 6.2.3 2h,2n,2s,12b 6.2 IMPLEMENTATION 6.2.1 The authority and responsibility for the control of documents are described in Section 1.0, ORGANIZATION.

6.2.2 Controls are established for approval, issue and change of documents in the following categories:

a. Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes

b. As-built drawings (record drawings) and related documents

c. Procurement documents

d. Instructions and procedures for activities such as f abrication, construction, modification, installation, inspection. test and plant maintenance and operation which implement the Quality Program.

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'l Pagn 23 Rav18 j Date: June 6,1997 I

e. Final Safety Analysis Report / Final Hazards Safety Report 4

f. Reports of nonconformances

g. Plant Technical Specifications

i. 6.2.3 The review, approval, issue and change of the above documents are controlled by:

j. a. Establishment of criteria to ensure that adequate technical and quality requirements are j incorporated, a

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 j quality aspects.

6.2.4 Controlled documents are issued and distributed so that:

a. The documents are available at the work location prior to commencing work

b. Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner 6.2.5 Master lists or equivalent controls are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents. When master lists are used they are updated and distributed to designated personnel who are responsible for maintaining current copies of the lists.

6.2.6 Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.

I i

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Page 24 RIv18 Date: June 6,1997 l 7.0 . CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES l 7.1 REQUIREMENTS Activities that implement approved procurement requests for safety-related material, equipment and services are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic d

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.

4 The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation 4

of the requirements of this section of the OPD:

Paraaraoh Exceotions/Interoretations

, 7.1 2i l 7.2.2 16d

7.2.3 7b,17e 7.2.5 2m, 7e,17f 7.2.6 2m, 9b,13c,13d,17 f 7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in j Section 1.0, ORGANIZATION.

l 7.2.2 Consumers Energy qualifies suppliers by performing a documented evc:uation of their capability to provide items or services specified by procurement documents. To remain l qualified, suppliers involved in active procurements are evaluated continuously and are audited triennially. If an audit is acquired from an external source, the audit is evaluated prior to its use, a

i Supplier evaluation and triennial audits are not necessary when the items or services supplied l 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 l 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.

4

, in the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service.

7.2.3 Supplier activities that affect quality are verified in accordance with written procedures.

2 These procedures provide the method of verifying (such as audit, surveillance or inspection) j CPC-2A.R18 l

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Date: June 6,1997 j and documenting that the characteristics or processes meet the requirements of the l procurement document. For commercial "off the-shelf" items where the requirements for a i

specific quality assurance program appropriate for nuclear applications cannot be imposed in a i practical manner, source verification is used to provide adequate assurance of acceptability I

j unless the quality of the item can be adequately verified upon receipt.

4 7.2.4 Spare and replacement parts are procured in such a manner that their performance and quality are at least equivalent to those of the parts that will be replaced.

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

approved revisions.

i j 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 i

at least equivalent to the original. l 4

c. Where quality requirements for the originalitems 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.

I Evaluation results are documented.

j 2

d. Any additional or modified design criteria, imposed after previous procurement of the

item (s), are identified and incorporated.

4 7.2.5 Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with safety-related procurement require,ments not previously verified by

, source surveillance or inspection and that required supplier furnished documentation is j available. Items inspected are identified as to their acceptance status prior to their storage or-release for installation.

! 7.2.6 Suppliers are required to furnish the following records:

).

a. Applicable drawings and related engineering documentation that identify the purchased l

item and the specific procurement requirements (e.g., codes, standards, and I

) specifications) met by the item.

i l i b. Documentation identifying any procurement requirements that have not been met.

i

c. A description of those nonconformances from the procurement requirements f dispositioned " accept as is" or " repair."

(

d. Quality records as specified in the procurement requirements.

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

i 7.2.7 Supplier's certificates of conformance are periodically evaluated by audits, independent 4

inspections, or tests to assure that they are valid. The results of these evaluations are j documented.

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Pcgs 26 Rsv 18 Date: June 6,1997 8.0 IDENTIFICATION AND CONTROL OF ITEMS l 8.1 REQUIREMENTS Safety-related materials, parts and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is msintained either on the items, their storage areas or containers, or on records traceable to th9 items.

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

Paraaraoh Exceotions/Interoretations 8.2.2 7d,79 8.2.3 70 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).

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

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

]

I 8.2.3 Items are traceable to applicable drawings, specifications, or other pertinent documents to '

ensure that only correct and acceptable items are used. Verification of traceability is performed and documented prior to release for fabrication, assembly, or instaliation.

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l Pags 27 Rzv18 l Date: June 6,1997 i

9.0 CONTROL OF SPECIAL PROCESSES 9.1 REQUIREMENTS l

Special processes affecting safety-related structures, systems, and components are controlled and are accomplished by qualified personnel using qualified procedures and equipment in  !

l accordance with applicable codes, standards, specifications, criteria, and other special require-ments.

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

Paraaraoh Exceotions/Interoretations 9.2.1 6c,13e j

1 9.2 I

IMPLEMENTATION l l

9.2.1 Processes subject to specie' process controls at Consume's Energy are those for which full l I verification or characterization by direct inspection is impossible or impractical. Such l processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement, and nondestructive examination.

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

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

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

9.2.4 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations. Certification is based on examination results. Personnel qualification is kept current by performance of the special process (es) and/or reexamination at time intervals specified by applicable codes, specifications, and standards. Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals requires recertification.

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

9.2.6 Qualification records are maintained in accordance with Quality Program Description Section 17.

9.2.7 The Nuclear Performance Assessment Department audits / assesses special process activities, l including qualification activities to assure they are satisfactorily performed.

l

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10.0 INSPECTION l 10.1 REQUIREMENTS Activities t.ifecting 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:

Paraaraoh Exceotions/Interoretations 10.2.2 2p,2q 10.2.3 2j, 6a 10.2.7 2j, 6a 10.2.10 2j 10.2 IMPLEMENTATION 10.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION, 10.2.2 Inspections are applied to procurement, maintenance, modification, testing, fuel handling, and inservice inspection to verify that items and activities conform to specified requirements.

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

a. Determine the need for inspection (s).

b. Identify the inspection organization or personnel,

c. Identify independent verification points,

d. Determine how and when the inspections are to be performed,

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

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

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

Process monitoring is used in whole or in part where direct inspection alone is impractical or inadequate, l

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Piga 29 Rsv 18 Date: June 6,1997 10.2.3 Training and qualification programs for personnel who perform inspections, including nondestructive examination, are established, implemented, and documented in accordance with Section 2.0, QUALITY PROGRAM, and plant or offsite procedures. These programs meet the requirements of applicable codes and standards. The Site Vice President / Plant General Manager is responsible for review and concurrence with plant training and qualification programs that are under his direct responsibility.

Training and qualification programs for E&TS personnel who perform inspections, including l

i nondestructive examination, are documented in E&TS procedures, I

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

l Qualifications and certifications of inspection and NDE personnel are maintained.

10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists and are either provided or concurred with by the organization that performs the inspection planning. They (procedures, etc) provide for the following as appropriate:

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

b. Identification of characteristics and activities to be inspected.

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

1

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

l

e. Identification of personnel responsible for performing the inspection,

f. Acceptance and rejection criteria. l

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 or-genization that performs the inspection planning.

10.2.6 Independent verifications are performed and documented in accordance with the writt! n instructions provided. The results are evaluated by designated personnelin order to ensure that the results substantiate the acceptability of the item or work. Evaluation and review results are documented, independent verification should be designated when the activity / task being verified is l necessary to ensure critical characteristics are in conformance with requirements and/or the verification is result of codes, standards, regulations, or commitments.

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Pigs 30 Rav18 Date: June 6,1997 1

1 10.2.7 Independent verification may be performed by individuals in the same organization as that which performed the work provided:

3 a. Qualifications of the independent verifier are equal to or better than the minimum

qualifications for persons who can be authorized to perform the task; and

b. The work is within the skills of Consumers Energy personnel and/or is addressed by Consumers Energy procedures, i

l c. If work involves breaching a pressure retaining item, the quality of the work can be demonstrated through a functional test. l When a, b, and c are not met, inspections will be carried out by individuals certified in i j accordance with ANSI N45.2.6.

The verification is performed by individuals other than the person (s) performing or directly supervising the work.

4

, 10.2.8 For independent verification, when acceptance criteria are not met, corrected areas are to be j 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 criteris are not met.

Resolution of disagreements between the verifier and worker is resolved by plant management.

i 10.2.10 Contractors may be used as independent verifiers in accordance with Section 10.2.7 provided:

! l a. The work is performed using the Consumers Energy Quality Program and procedures.

b. Individuals are trained and qualified in accordance with Section 10.2.3.

Otherwise, contractors must be certified to ANSI N45.2.6 to perform inspections.

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Pags 31 Rav18 Date: June 6,1997 11.0 TEST CONTROL 11.1 REQUIREMENTS l

Testing is performed in accordance with established programs to demonstrate that safety-related structures. systems, and components will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification (as applicable), acceptance, pre-operational, start-up, surveillance, and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions are specified and met. Test results are documented and evaluated.

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

Paraaraoh Exceotions/Interoretations 11.2.2 2k,17g 11.2 IMPLEMENTATION ,

l 11.2.1 Organizational responsibilities for testing are described in Section 1.0, ORGANIZATION.

11,2.2 Tests are performed in accordance with programs, procedures, and criteria that designate when tests are required and how they are to be performed. Such testing includes the ]

following:

a. Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0, DESIGN CONTROL.

b. Acceptance tests of equipment and components to assure their proper operation prior to delivery or to pre-operational tests,

c. Pre-operational tests to assure proper and safe operation of systems and equipment prior to start-up tests or operations,

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

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

f. Maintenance tests af ter preventive or corrective maintenance.

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

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

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b. Test prerequisites such as calibrated instrumentation, adequate test equipment, and instrumentation including accuracy requirements, completeness of the item to be tested, l 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 7 the plant engineering organization, or the offsite technical organization, as applicable 1

When acceptance criteria are not met, corrected areas are to be retested.

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Pcgs 33 Ray 18 Date: June 6,1997 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT i 12.1 REQUIREMENTS l

Measuring and testing equipment used in activities affecting the quality of safety-related i

systems, components and structures are properly identified, controlled, calibrated, and adjusted at specified intervals to maintain accuracy within necessary limits.

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

Paraoraoh Exceotions!lnteroretations j

j 12.2.3 2o,9c

12.2.4 2o, 9c l 12.2.5 10c 12.2.8 10b I

l 12.2 IMPLEMENTATION 12.2.1 The authority and responsibility of personnel establishing, implementing and assuring effectiveness of calibration programs is described in Section 1.0, ORGANIZATION.

12.2.2 Procedures are established for measuring and test equipment utilized in the measurement, inspection and monitoring of structures, systems and components. These procedures describe calibration technique and frequency and maintenance and control of the equipment.

12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration source.

12.2.4 Consumers Energy uses a system of labels to be attached to measuring and test equipment to l l display the next calibration due date. Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.

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

- Calibration of M&TE is against standards that have an accuracy of at least four times the ,

required accuracy of the equipment being calibrated or, when this is not possible, have an j accuracy that assures the equipment being calibrated will be within required tolerance and the  !

basis of acceptance is documented and authorized by responsible management.

l Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.

12.2.6 Calibrating standards have greater accuracy than standards being calibrated. Calibrating standards with the same accuracy may be used if it can be shown to be adequate for the CPC-2A.R18

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Pzgn 34 Rsv 18 Date: June 6,1997 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.

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Pagn 35 Rav 18 Date: June 6,1997 13.0 HANDLING, STORAGE AND SHIPPING 13.1 REQUIREMENTS l

Activities with the potential for causing contamination or deterioration that could adversely l affect the ability of a safety-related itern to perform its intended safety functions, and

activities necessary to prevent undetected or uncorrectable damage are identified and con-l trolled. These activities include cleaning, packaging, preserving, handling, shipping, and storing. Controls are effected through the use of appropriate procedures and instructions implemented by suitably trained personnel.

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

Paraoraoh Exceotions/Interoretations 13.2.2 7a, 7c, 7d, 7f, 7g, 7h 13.2 IMPLEMENTATION 13.2.1 The authority and responsibility of personnelimplementing and assuring the effectiveness of material cleaning, handling, storing, pack aging, preserving, and shipping activities is described in Section 1.0, ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storing, pack aging, preserving, 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:  !

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.

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P:gs 36 Rsv 18 Dats: Jun3 6,1997 14.0 INSPECTION, TEST AND OPERATING STATUS l 14.1 REQUIREMENTS Operating status of safety-related structures, systems, and components is indicated by tagging of valves and switches, or by other specified means,in such a manner as to prevent '

j 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 requirement: of this section of the QPD:

Paraaraoh Exceotions/Interoretations 14.1 2r 14.2.5 2i 14.2 IMPLEMENTATION 14.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION. -

14.2.2 For modification activities, including item f abricction, installation and test, procurement documents, service contracts, and procedures specify the degree of control required for the indication of inspection and test status of structures, systems, and components.

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

14.2.4 The sequence of inspections, tests and other operations important to safety are controlled by procedures. Changes in the approved sequence are subject to the same review and approval as the original, or as specified in administrative procedures if the original organization no longer exists.

14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems, and g components is clearly identified and documented to preven'. inadvertent use.

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' Pigs 37 l Rsv 18 j I

Date: June 6,1997 'l 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS l

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15.1 REQUIREMENTS l

Safety-related materials, parts, or components that do not conform to requirements are i

controlled in order to prevent their inadvertent use Nonconforming items are identified,

documented, segregated when practical, and dispositioned. Affected organizations are notified of nonconformances 1

! The following exce.ntionsEnterpretations in Appendix A, Part 2, are relevant to implementation j of the requirementa of thm section of the QPD:

Paraaraoh Exceotions/Interrtentigng  ;

i 15.1 21 i

j 15.2 IMPLEMENTATION i

15.2.1 Items, services, or activities that are deficient in characteristic, documentation, or procedure, which rendct 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 I 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 originalinspection planning authority.

d. Items that have the disposition of " repair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as-built condition.

15 2.2 Dispositions of conditionally released items are closed out before the items are relied upon to perform safety-related functions.

15.2.3 Prior to the initiation of preoperational testing on an item. ell nonconformances are corrected or dispositioned and evaluated for impact upon the item or the testing program.

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Pag 3 38 Rsv 18 Date: June 6,1997 15.2.4 Nonconformance reports are analyzed to identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management for review and assessment.

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s Pcga 39 Rgv 18 Date: June 6,1997 16.0 CORRECTIVE ACTION 16.1 REQUIREMENTS l

Conditions adverse to quality of safety-related structures, systems, components, or activities, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconformances are identified promptly and corrected as soon as 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 similar problems in the future. The controls also assure that corrective action is implemented in a timely manner.

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Paga 40 Rav 18 Date: June 6,1997 4

1 17.0 QUALITY RECORDS

- l 17.1 REQUIREMENTS Records that furnish evidence of activities affecting the quality of safety related structures, systems and comportents 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:

Paraaraoh Exceotions/Interoretations 17.1 14b 17.2.5 14c 17.2.8 14a,14c 17.2 IMPLEMENTATION 17.2.1 Responsibilities for the identification and control of Quality records are described in Section 1.0, ORGANIZATION.

17.2.2 Documents that furnish evidence of ar.tivities affecting quality are generated and controlled in accordance with the procedures that govern those activities. Upon completion, these documents are considered records. These records include:

a. Results of reviews, inspections, surveillances, tests, audits, and material analyses

b. Qualification of personnel, procedures, and equipment

c. Operating logs

d. Maintenance and modification procedures and related inspection results

e. Reportable occurrences l

f. Records required by the Plant Technical Specifications

g. Nonconformance reports j

h. Corrective action reports

1. Other documentation such as drawings, specifications, procurement documents, I calibration procedures, and reports l 17.2.3 Inspection and test records contain the following where applicable:

a. A description of the type of observation

b. The date and results of the inspection or test CPC-2A.R18

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! c. Information related to conditions adverse to quality

d. Inspector or data recorder identification e

e. Evidence as to the acceptability of the results f f. Action taken to resolve any discrepancies noted i

17.2.4 When a document becomes a record, it is designated as permanent or nonpermanent and then i transmitted to fiie. Nonperrnanent records have specified retention times. Permanent records 1

are maintained for the life of the item. Appendix E identifies retention periods for certain

. specific records.

t 17.2.5 Temporary storage of completed documents during processing to become records is in special l l fire-resistant file cabinets.

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17.2.6 ' Only authorized personne! may issue corrections or supplements to records, l

1 17.2.7 Traceability between the record and the item or activity to which it applies is provided.

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l 4 17.2.8 Records are stored in remote, dual facilities to prevent damage, deterioration, or loss due to 4

natural or unnatural causes. Records that can only be stored as originals, such as radiographs 4

and some strip charts are retained in a four hour fire-rated facility.

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PIga 42 1 Rsv 18 Date: June 6,1997 j 18.0 AUDITS l

l 18.1 REQUIREMENTS I

A comprehensive system of audits is carried out to provido 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 per-forrned 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 i of the requirements of this section of the QPD:

l Paraaraoh Exceotions/Interoretations j I

18.2.2 3a,3b,16a,16b 18.2.3 16c 18.2.9 2e 18.2 IMPLEMENTATION 18.2.1 Responsibility and authority for the audit program is described in Section 1.0, ORGANIZATION, 18.2.2 Internal audits are performed in accordance with established schedules that reflect the status and importance to safety of the activities being performed. Audits are conducted in l accordance with frequencies stated in Appendix D, Audit Frequencies. I 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

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is effective and properly implemented.

i l 18.2.7 Audit procedures and the scope, plans, checklists, and results of individual audits are j' documented, r

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I 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 i audited.

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! 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.

1 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 j 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 fol.

i Iow-up includes re-audits when necessary. For Vendor Audits, such follow up shall be

. performed by the organization performing the audit.

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Ptgs 44 Rsv 18 Date: June 6,1997 QPD MANUAL APPENDlX A. PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS I l The Consumers Energy Quality Program complies with the regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2.

l. Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

2. 10 CFR, Part 50.55a - Codes and Standards.

3. Regulatory Guide 1.8 - (9/80 Draf t) - Personnel Qualification and Training - Endorses ANSI /ANS 3.1 -(12/79 Draft) .s.pplication limited as described in exceptions 4a and Sa of Appendix A, Part 2).

4. Regulatory Guide 1.26 - (2/76, Rev 3) - Quality Group Classification, and Standards for Water ,

Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants.

l S. Regulatory Guide 1.29 - (9/78, Rev. 3) - Seismic Design Classification, j

6. Regulatory Guide 1.30 (Safety Guide 30) - (8/11/72) - Quality Assurance Requirements for the Installation, inspection, and Testing of Instrumentation and Electrical Equipment - Endorses ANSI N45.2.4 - 1972.

7. Regulatory Guide 1.33 (2/78, Rev 2) - Quality Assurance Program Requirements (Operation) -

Endorses ANSI N18.7 - 1976.

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 for water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.

11. Regulatory Guide 1 58-(9/80, Rev I) - Qualification of Nuclear Power Plant Inspection, Examination, and Tes'ing Personnel - Endorses N45.2.61978.

12. Regulatory Guide 1.64 - (6/76, Rev 2) - Quality Assurance Requirements for the Design Of Nuclear Power Plants - Endorses N45.2.11 1974.

13. Regulatory Guide 1.74 - (2/74) - Quality Assurance Requirements Terms and Definitions -

Endorses ANSI N45.2.10 - 1973.

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1. Rsv 18 Date: June 6,1997 14, Regulatory Guide 1.88 - (10/76, Rev 2) - Collection, Storage, and Maintenance of Nuclear Power j Plant Quality Assurance Records - Endorses N45.2.9 1974.

15. Regulatory Guide 1.94 - (4/76, Rev 1) - Quality Assurance Requirements for Installation, i

j Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -Endorses ANSI N45.2.5 - 19'74.

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 Po?ition 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 111 G.,111 J. and ill O.

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). l CPC-2A.R18

Pag:e 46 Rsv 18 Date: June 6,1997 QPD MANUAL APPENDIX A. PART 2 l CONSUMERS ENERGY EXCEPTIONS TO OPERATING PHASE STANDARDS AND REGULATORY GUIDES

1. General Reauirement j

Certain Regulatory Guides invoke or imply Regulatory Guides and standards in addition to the standard each primarily endorses. l Certain ANSI Standards invoke or imply additional standards.

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

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

2. N18.7 General Exceotion/interoretation l Consumers Energy has established an organizational unit, Nuclear Performance Assessment Department, for independent review activities.

The standard numeric and qualification requirements may not be met by the Nuclear Performance 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 Reauirement "The Plant Manager shall have overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety."

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Pagn 47 Rav 18 Date: June 6,1997 Exceotion/Interoretation Since Consumers Energy has more than one nuclear unit and more than one organization providing l services to these units, overall responsibility cannot be centralized in a single on-site position.

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

2b. N18.7, Sec 4.3.1 Reauiremerit l " 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:. ."

l Exceution/lnteroretation L

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 Reauirement "The following subjects shall be reviewed by the independent review body:"

Excention/Interoretation Subjects requiring review will be as specified in Appendix C, Independent Safety Review.

2d. N18.7. Sec 4.3.4(3)

Recuirement Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.

Exceotion/interoretation

. The Nuclear Performance Assessment Department will not review Technical Specification Changes after NRC approval prior to implementation. The basis for this position is that all Technical Specification changes are reviewed prior to submittal to the NRC.

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I 2e. N18.7. Sec 4.5

, Reauirement i Written reports of audits specified in ANSI N18.7 shall be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited.

Exceotion/lnteroretation

) 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.

i Some of the audits required during the operational phase are in areas other than those requiring

independent review in accordance with ANSI N18.7, Section 4.3.4.

4 2f. N18.7. Sec 4.5

l Reauirement Periodic review of the audit program shall be performed by the independent review body or by a i

management representative at least semiannually to assure that audits are being accomplished in accordance with requirements of technical specifications and of this standard.

4 Excention/Interoretation 1

j 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 ,

Ssfety Review. l

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2g. N1gl, Sec 5.2.1 Reauirement "The responsibilities and authorities of the plant operating personnel shall be delineated."

I Exceotion/interoretation i

On-site personnel not directly associated with operating activities, as defined in ANSI N18.7, Section 2.2, are not considered to be operating personnel.

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Pags 49 Rav 18 Date: June 6,1997 2h. N18.7. Sec 5.2.2 ,

l Reauirement i

" 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 1 the procedures. At least one of these individuals shall be the supervisor in charge of the shift and '

hold a senior operators license on the unit affected."

Exceotion/Interoretation Consumers Energy considers that this requirement applies only to procedures identified in Plant l 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; 1

b. The change is approved by two members (or designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator License; and

c. The change is documented, subsequently reviewed by the PRC within 30 days of issuance and approved by:

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1. Appropriate

• senior Palisades department manager predesignated by the Site Vice President; or

2. The Big Rock Point Plant General Manager. l Determination of the appropriate senior Palisades department manager is based on the activities addressed in the specific procedure, and will be predesignated in writing by the Palisades Plant Site Vice President. l

21. N18.7. Sec 5.2.6 Reauirement "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 rnaterial 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."

Exceotion/Interoretation Consumers Energy initiates appropriate corrective action when it is discovered that documentary l evidence does not exist for a test or inspection which is required to verify equipment acceptability. This action includes a technical evaluation of the equipment's operability status.

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l 3 Paga 50 Rev 18 i Date: June 6,1997 I

i- 2j. N18.7. Sec 5.2.7 a

i Raouirement -

l The following standards contain useful guidance concerning design and construction-related activities associated with modifications and shall be applied to those activities occurring during i

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 j j

Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of '

] Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, l N45.2.5-1974 [7]; American National Standard Qualifications uf 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 i

Power Plants Mt5.2.8-1975 [8]; American National Standard Quality Assurance Requirements for the Desip- har Power Plants, N45.2.11 1974 [9); and American National Standard Quality Assurancs foi . Nctive Coating Applied to Nuclear Facilities N101.4-1972 [10). Considerable l

care is required in assessing which operational phase activities are comparable in nature and

{ extent to activities normally associated with design and construction.

Excention/ Clarification

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' l i Work that is within the skills of Consumers Energy personnel and is covered by Consumers Energy

procedures may be inspected by independent verifiers qualified in accordance with Section 10.2.3 i and 10.2.7 and 10.2.10, rather than ANSI N45.2.6.

4 j 2k, N18.7. Sec 5.2.8 i Reauirement

"A surveillance testing and inspection program...shall include the establishment of a master j surveillance schedule reflecting the status of all planned inplant surveillance tests and i inspections."

Exceotion/Interoretation l

l- Separate master schedules may exist for different programs such as ISI, Pump and Valve Testing, and Technical Specificatlon Surveillance Testing.

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Paga 51 Rav18

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Date: June 6,1997 I

21. N18.7., Sec 5.2.13.1 l l

I Reauirement "To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 - 1971."

l l Exceotion/Interoretation I

! l To the extent necessary, procurement documenta require that the supplier have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other l nationally recognized codes and standards.

2m. N18.7. Sec 5.2.13.2 Reauirement ANSI N18.7 and N45.2.13 specify that where required by code, regulation, or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

1 I

Exceotion/Interoretation 1 The required documentary evidence is available at the site prior to use, but not necessarily prior to l installation. This allows installation to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

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

Excention/interoretation Consumers Power has in place programmatic procedure preparation, review and usage controls that ensure procedures are technically and administratively correct and make a biennial review program unnecessarily duplicative. These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusualincidents occur, when plant modifications are mado, 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.

l Because of their critical nature, non-routine procedures, such as Emergency Operating Procedures,

! Off-Normal Procedures, Special Operating Procedures, Special Test Procedures, Fuel Handling Procedures, Emergency Plan Implementing Procedures, and others where use would be dictated j by a particular event are reviewed at least every two years and revised as appropriate.

l

! CPC-2A.R18

Pags 52 Rsv 18 Date: June 6,1997 in addition, procedures that have not been used or reviewed for two years are reviewed prior to use to determine if changes are necessary or desirable.

l 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 Reauirement Records shall be made and equipment suitably marked to indicate calibration status. I Exceotion/interoretation See item 9c.

2p. N18.7. Sec 5.2.17 Reauirement For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities (see also Section 5.2.7)

Exceotion/Interoretation Maintenance and modification activities which are within the skills of Consumers Energy maintenance personnel and is carried out using Consumers Energy procedures may be inspected by independent verifiers qualified in accordance with Sections 10.2.3,10.2.7, and 10.2.10 of this program description.

2q. N18.7. Sec 5.2.17 Reauirement if 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.

Exceotion/Interoretation l Consumers Energy uses the terminology " independent verification points" as equivalent to hold points.

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Pagn 53 Rsv18 Date: June 6,1997 l

l 2r. N18.7, Sec 5.3.5(3)

Reauirement i

instructions shall be included, or referenced (in maintenance procedures), for returning the equipment to its normal operating status.

Exceotion/Interoretation ,

l - At Consumers Energy, equipment is returned to its normal operating status,i.e., declared l l operable, by licensed Operations Department personnel, not Maintenance personnel. Operations l personnel verify and document equipment operability through second levelline-up verification or

! appropriate functional testing.

2s. N18.7, Sec 5.3.5(4)

Raouirement This section requires that where sections of documents such as vendor manuals, operating and l

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.

l  !

Exceotion/Interoretation i i

Such documents are reviewed by appropriately qualified personnel prior to use to ensure that, when used as instructions, they provide proper and adequate information to ensure the required )

quality of work. Maintenance procedures which reference these documents receive the same i level of review and approval as operating procedures.  !

1 3a. RG 1.33. Sec C4a I

Reauirement The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility i equipment, structures, systems, or method of operation are to be audited at least once per six l months. I 1

Exceotion/Interoretation l 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.

l l

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Pzga 54 R:v18 Date: June 6,1997 3b. RG 1.33. Sec C4b Reauirement I l

The conformance of facility operations to provisions contained within the Technical Specifications i and applicable license conditions-at least once per 12 months.

l l

Exceotion/Interoretation l

Consistent with guidance presented in NRC letters dated March 29,1983 (RLSpessard to l JMTaylor) and January 30,1984 (JGPartlow to RLSpessard), Consumers Energy interprets the commitment to audit Technical Specification / license conditions contained in 18.2.2 of this QPD, and in Appendix D, Audit Frequencies, as follows:

l Consumers Energy maintains a matrix that identifies all applicable Technical Specification line items to be audited. The matrix is updated annually to conform to approved Technical Specification changes. During each 12 month period, a selected sample of line items, with the exception of the onsite and offsite review committee which are audited every 24 months,is audited:

1. Limiting 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 sliline items are covered within a maximum period of 5 years. The audit period for any of the above elements may be reduced depending on Technical Specification compliance history.

4a. ANS 3.1. General Exceotion/interoretation The commitme , (12/79, draf t) is D (o the requirements that apply to the training and qualificatic,r forming indeps iuality assurance functions, except for Lead Auditors. Lead t. .ained and no ' (egulatory Guide 1.146 (8/80)/ ANSI 45.2.23-1978. Other pers, 'ined designated in plant Technical Specifications.

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Pegs 55 Rav18 Date: June 6,1997 Sa. RG 1.8. C.3.1, General Exceotion/interoretation The commitment to Regulatory Guide 1.8 (9/80, draft) is limited to the requirements that apply to the training and qualification of persons performing independent quality assurance functions, except for Lead Auditors. Lead Auditors are trained and qualified to Regulatory Guide 1.146 (8/80)/ ANSI N45.2.23-1978. Other personnel are trained and qualified as designated in plant Technical Specifications.

Sb. RG 1.8, C1.2.2  !

, Reauirement 1

! "When an individual is hired to temporarily function as a plant employee, such as for contracted 1

services, evidence of previous education, experience, and training should be provided and l reviewed by the appropriate professional-technical group leaders. The appropriate grouo 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."

1 Excention/Interoretation l Consumers Energy understands that this requirement applies both to Consumers Energy l l employees from another site and to contract personnel who are temporarily assigned to a nuclear i

power plant either as replacements for regular employees or to augment the staff during outages.

1 Consumers Energy employees so assigned possess the required qualifications as a prerequisite to l

] 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 j unescorted access receive the site general orientation as embodied in General Einployee Training, i

j 6a. N45.2.1. Sec 2.4 s

Reauirement i .

1 i '

Those personnel who perform inspection, examination, or testing activities required by this j 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.

Excention/Interoretation 1

j Consumers Energy certifies its inspectors in accordance with Paragraph 10.2.7 of CPC-2A unless

' l the work is comparable in nature and extent to original construction (See item 2j).

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I l Pzga 56 l l Rsv 18 l Date: June 6,1997 i.

6b. N45.2.1. Sec 3.1 Reauirement N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items  ;

be so classified. i Exceotion/interoretation Instead of using the cleanness level classification system of N45.2.1, the required cleanness for l specific items and activities is addressed on a case-by-case basis, l

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.

Sc. N45.2.1. Sec 5 Reauirement

" Fitted and tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed."

Excention/Interoretation l l Consumers Energy sometimes uscs other nonhalogenated material, compatible with the parent material, since plastic film is subject to damage and does not always provide adequate protection.

7a. N45.2.2. General Reouirement N45.2.2 establishes requirements and criteria for classifying safety-related items into protection levels.

Exceotion/Interoretation Instead of classifying safety-related items into protection levels, controls over the packaging, shipping, handling, and storage of such items are established on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

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Pigs 57 1

Rsv 18 Date: June 6,1997 7b. N45.2.2. Sec 2.4 9

Reauirement f "...Offsite inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N45.2.6."

Exceotion/interoreta' ion I

i i

i i'

Offsite inspection, examination, or testing activities are audited or inspected by persons qualified l and certified in accordance with ANSI N45.2.23-1978, as endorsed by Reg Guide 1.146, or by  ;

personnel meeting the requirements of 10.2.7, respectively. Monitoring activities not involving l audit or inspection may be conducted by persons trained and qualified to effectively carry out such tasks, but not necessarily certified to either ANSI N45.2.23, N45.2.6 or Paragraph 10.2.7.

7c. N45.2.2, Sec 3.4.1 and Appendix A, 3.4.1(4) and (5)

Reauirement

' "(4) ...However, preservatives for inaccessible inside surfaces containing reactor coolent water shall be indicated to facilitate touch up.

f (5) The name of the preservative used shall be the water flushable type." l i Exceotion/Intercretation l

Based on comparison of these statements to ANSI /ASME NQA-21983, Consumers Energy l j believes the intent was to establish the following as requirements:

i "(4) ...However, preservatives for inaccessible inside surfaces of pumps, valves, and pipe for i systems containing reactor coolant water shall be the water flushable type.

I i (5) The name of the preservative used shall be provided to facilitate touch-up." ,

j i 7d. N45.2.2, Sec 3.9 and Appendix A 3.9 i

Reauirement "The item and the outside of containers shall be marked."

(Further criteria for marking and tagging are given in the appendix.)

Exceotion/interotetation These requirements were originally written for items packaged and shipped to construction projects. Ful! compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, increase the probability of damage to the item. The requirements are implemented to the extent necessary to assure traceability and integrity of the item.

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Pzgs 58 Rsv 18 '

Date: June 6,1997 l 78. N45.2.2. Sec 5.2.2 Reauirement "The inspections shall be performed in an area equivalent to the level of storage."

Exceotion/Interoretation Receiving inspection area environmental controls may be less stringent than storage environmental 3 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 Reouirement "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall not be

< permitted."

4 Exceotion/Interoretation Packaged food for emergency or extended overtime use may be stored in material stock rooms.

The packaging assures that materials are not contaminated. Food will not be "used" in these areas.

7.

9 N45.2.2. Sec 6.3.4 Reauirement "Allitems and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxes."

Exceotion/Interoretation See N45.2.2, Section 3.9 (Exception 7d.).

7h. N45.2.2, Sec 6.4.1 Reoui;ement i

" inspections and examinations shall be performed and documented on a periodic basis to assure j that the integrity of the item and its container...is being mated." ,

Exceotionlinteroretation i

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 q documented in accordance with material storage procedures which identify the characteristics to l be inspected and include the required frequencies. These procedures are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.

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Pags 59 Rav 18

Date: June 6,1997

8a. N45.2.3. Sec 2.1 i

Reauirement f Cleanness requirements for housekeeping activities shall be established on the basis of five zone 1 designations.

j Exceotion/interoretation i instead of the five level zone designation system referenced in ANSI N45.2.3, Consumers Energy l 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 '

i 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,  ;

i personnel safety, fire prevention and protection, radiation control, and security. The procedures  !

' and instructions make use of standard janitorial and work practices to the extent possible.

However, in preparing these procedures, consideration is also given to the recommendations of Section 2.1 of ANSI N45.2.3.

i ,

4 9a. N45.2.4. Sec 2.2 Reauirement l

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 j specified documents.

f Exceotion/Interoretation During the operations phase, this requirement is considered to be applicable to modifications and j initial start-up of electrical equipment. For routino or periodic inspection and testing, the

! prerequisite conditions will be achieved as necessary.

I j 9b. N45.2.4. Sec 2.2(5) 4 I Reauirement i Section 2.2(5) of ANSI N45.2.4 lists documents which are to be available at the construction site.

1 l Exceotion/ Clarification 1

All of the documents listed are not necessarily required at the plant site for installation and testing. Consumers Energy assures that they are available to the site as necessary. l 4

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j 9c. N45.2.4. Sec 6.2.1 4 l Reauirement

" Items requiring calibration shall be tagged or labeled on completion, indicating date of calibration and identity of person that performed the calibration."

Exceotion/interoretation Frequently, physical size, and/or location of installed Plant Instrumentation (IPI) mandates that calibration labels or tags not be affixed to IPl. Instead, each instrument is uniquely identified and is traceable to its calibration record.

A scheduled calibration program assures that each instrument's calibration is current.

10a. N45.2.5, Sec 2.4 Reauirement

" Persons charged with engineering managerial recponsibility of the inspection and testing organization at the site in either a resident or non-resident capacity shall be certified for Level ill capability."

Exceotion/Interoretation This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activity in the areas of concrete and structural steel which do not generally l occur at an operating plant. At Consumers Energy, persons having engineering managerial responsibility for inspections and tests' may be certified to Level til, or may meet other qualification criteria established for the position, including, but not limited to, nuclear power and management experience. For major modifications involving significant concrete or structural steel l

'"'rk, the services of a properly qualified Level lli individual will be obtained in at least an advisory l

( i >acity.

l within the scope of N45.2.5 10b. N45.2.5. Sec 2.5.2 Reauirement "When discrepancies, malfunctions, or inaccuracies in inspection and testing equipment are found during calibration, all items inspected with that equipment since the last previous calibration shall be considered unacceptable until an evaluation has been made by the responsible authority and appropriate action taken."

Exceotion/Interoretation l Consumers Energy uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The N18.7 requirements are more applicable to an operating plant.

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Pegs 61 Rsv 18 Date: June 6,1997 10c. N45.2.5. Sec 5.4 Reauirement

" 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 "

Exceotion/Interoretation Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Section 5.2.16. Calibration intervals are based on use and calibration history rather than as per N45.2.5 11a. N45.2.8. Sec 1.2 Reauirement "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."

Excention/Interoretation See 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 1.58. Sec C.1 Reauirement "However, for qualification of personnel (1) who approve preoperational, start-up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start up and operational tests, the guidelines contained in Regulatory Guide 1.8, Personnel Selection and Training, should be followed in lieu of the Guidelines of ANSI N45.2.6 -

1978."

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! Paga 62 i Rsv 18 I

Date: June 6,1997 l J

1

Excention/interoretation

?

l Consumers Energy endorses this position, as also_ stated in 11a, 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 l throughout the operations phase of Consumers Energy Nuclear Plants.

12 b.' RG 1.58. Sec C.5 Reauirement

)

"In addition, the individual should be capable of reviewing and approving inspection, examination ']1 and testing procedures and of evaluating the adequacy of such procedures to accomplish the j inspection, examination and test objectives."

l Excention/Interoretation j While a Level 111 individual should be capable of reviewing and approving inspection, examination l

- and testing procedures and of evaluating the adequacy of such procedures to accomplish the l inspection, examination and test objectives, this is not construed by Consumers Energy as requiring personnel who review, approve or evaluate such procedures to be certified as Level lli I personnel.

12.c. BQ..L51, Sec C.6 Reauirement "Since only one set of recommendations is provided for the education and experience of 'j 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."

Exceotion/Interoretadgn 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 I recommendations, and more significantly, upon satisfactory completion of capability testing prior to certification. It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.

12.d RG 1.58, Sec C.10 Reauirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experience should result in documented evidence (i.e., procedure and record of written test) demonstrating that the individualindeed does have comparable or equivalent competence to that which would be gained from having the required education and experience."

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Paga 63 Rav18 Date: June 6,1997 Exceotionllnteroretation We will maintain documented objective evidence that demonstrates that an individual does have

" comparable" or " equivalent" competence to that which would be gained from having the required education and experience. However, this may take the form of documentation other than

" procedures and records of written test" such as documentation of oral tests and on-the-job performance demonstrations.

13a. N45.2.8. Sec 2.7 Reauirement Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6.

I Exceotion/Interoretation See Exception / Interpretation 2j, lla, 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 l Technical Specifications. i 13b. N45.2.8. Sec 2.9  !

&auirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and  !

testing of mechanical equipment may proceed. These preiequisites include personnel and procedure qualification, control of design, material selection and fabrication, and availability of specified documents.  ;

Exceot. ion /Interoretation ]

i 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 l Reauirement  ;

Section 2.9e of N45.2.81:sts documents relating to the specific stage of installation activity which are to be available at the construction site.

Excention/Interoretatica All of the documents 1isted are not necessarily required al the plant site for installation and testing. Consumers Energy assures that they are avaliable 19, the site as necessary. l s

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Pggs 64 Rav 18 1 Date: June 6,1997 13d. N45.2.8, Sec 2.9e Reauirement Evidence that engineering or design changes are documented and approved shall be available at  ;

~

the construction site prior to installation.

Exceotion/Intercretation Equipment may be installed before final approval of engineering or design changes. How0ver, the system is not declared operable until such changes are documented and approved.

13e. N45.2.8. Sec 4.5.1 Reauirement

" Installed systems and components shall be cleaned, fS::hed, and conditioned according to the requirements of ANSI N45.2.1 Special attention shall eo given to the following requirements:...."

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

4 Excention/Interoretation ,

f

. Systems and components are cleaned, flushed and conditioned as determined on a case-by-case basis. Measures are taken to help preclude the need for cleaning, flushing, and conditioning through good practices during maintenance or modification activities.

14a. ((4LL2, Sec 5.4, item 2 R.ac uirement

(

i l Re ,ords shall not be stored loosely. They shall be firmly attached in binders or placed in folders or er,velopes for storage on shelving in containers. Steel cabinets are preferred.

Exceotion/Interoretation 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 ,

I

{ Raouirement "A list shall be maintained designating those personnel who shall havt .iccess to the files."

l.  ;

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l Psgs 65 I Rev 18 Date: June 6,1997 1 1

EXc30 tion /Interoretation Rule.s 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 tre authorized access. It should be noted that duplicate files and/or microforms exist for general use and backup.

14c. RG 1.88. C2 Reauirement "Two methods of protection of quality assurance records from the hazards of fire are descrLed 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 protectiot 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 Subdivicion 5.6...When NFPA 232- )

1975 is used, quality assurance records should be classified as NFPA Class 1 records...."

i' Exceotion/interoretation Consumers Energy adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent l storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Class 1 records (usually NFPA Class C,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Class 350).

15a. RG 1.64. C2 Reauirement "Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design...."

Exceotion/Interoretation l Consumers Energy follows the requirements of ANSI N45.2.11-1974, Section G.1, and the l guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of 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 ,

I technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks.

16a. RG 1.144. Sec C3a(1)

Reauirement 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 nuclea. safety and occur in facility CPC-2A.R18

Pigs 66 Rav18 Date: June 6,1997 i

equipment, structures, systems, or method of operation are to be audited at least once per six j months.

i I

Exceotion/Interoretation i

, See Item 3a for the exception to this requirement.

16b. RG 1.144, Sec C3a(2)

Reauirement

~

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.

Exceotion/Interoretation Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.

16c. RG 1.144, Sec C3b(1) 1 Reauirement

) This section identifies procurement contracts which are exempted from being audited.

Exceotion/Interoretation l In addition to the exemptions of RG 1.144, Consumers Energy considers that Authorized Inspection Agencies, NationalInstitute of Standards and Technology or other State and Federal l Agencies which may provide services to Consumers Energy are not required to be audited.

16d. RG 1.144. Sec C.3.b(2), second paragraph 4

Reauirement 4

A documented evaluation of the supplier should be performed annually. Where applicable, this evaluation should take into account (1) review of supplier-furnished documente such as

certificates of conformance, non-conformance notices, and corrective actions, (2) results of 4

previous source verifications, audits and receiving inspections, (3) operating experience of identical or similar products furnished by the same supplier, and (4) results of audits from otner sources (e.g., customer, ASME or NRC Audits).

Exceotion/Interoretation Consumers Energy will review the information described in the second paragraph of section C.3.b(2) of Regulatory Guide 1.144, Revision 1,1980, as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of

- performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary 4

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Pagn 67 Rsv 18 Date: June 6,1997 (including corrective actions, adjustments of supplier audit plans, and input to third party auditing

{ entities as warranted). In Oddition, results are reviewed periodically to determine if, as a whole, they constitute a significant nondition adverse to quality requiring additional action.

3

17a. N45.2.13. Sec 3.2.2 i

! Reauirement '

l N45.2.13 requires that technical requirements be specified in procurement documents bv reference to technical requirement documents. Technical requirement documents are to be i prepared, reviewed and released under the requirements established by ANSI N45.2.11. I i

Exceotion/interoretation For replacement parts and materials, Consumers Energy follows ANSI N18.7, Section 5.2.13, l

Subitem 1, which states; "Where the originalitem or part is found to be commercially 'off the

shelf' or without specifically identified QA requirements, spare and replacement parts may be

similarly procured, but care shall be exercised to ensure at least equivalent performance."

l

17b. N45.2.13, Sec 3.2.3 Reauirement

" Procurement documents shall require that the supplier have a documented quality assurance l prograin that implements portions all of ANSI N45.2 as well as applicable quality assurance i program requirements of other notionally recognized codes and standards."

?

i Exceotion/Interoretation i

Refer to item 21.

j 17c. N45.2.13. Sec 3.3(a) i Reauirement Reviews of procurement documents shall be performed prior to release for bid and contract award, j Exceotion/interoretation 2

I Documents may be released for bid or contract award before completing the necessary reviews.

j 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.

f 17d. N45.2.13. Sec 3.3(b)

Reauirement 8

CPC 2A.R18

)

Page 68 Rav18 Date: June 6,1997

" Changes made in the procurement documents as a result of the bid evaluations or precontract negotiations shall be incorporated into the procurement documents. The review of such changes and their effects shall be completed prior to contract award."

Excention/Interoretation

'! i This requirement applies only to quality related changes (i.e., changes to the p.ocurement '

i document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems 1 through 5.) The timing of reviews will be the same as for review of the original procurement document.

17e. N45.2.13. Sec 7.5 i

)

Reauirement

" Personnel responsible for performing verification activities shall be qualified in accordance with 4

ANSI N45.2.6 as applicable."

Exceotion/Interoretation l Consumers Energy 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 accordance with Paragraph 10.2.7. However, personnel performing source surveillances may not be certified to any of those requirements.

17f._ N45.2.13, Sec 10.1 Reauirement "Where required by code, regulation or contract requirement, documentary evidence thai nems conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods."

Exceotion/Interoretation Refer to item 2m, 17g. N45.2.13. Sec 10.3.4 (as modified by RG 1.123, C6e)

Reauirement

" Post-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."

Exceotion/Interoretation l In exercising its ultimate respor :bility for its quality program, Consumers Energy establishes post-installation test requirements, giving due consideration to supplier recommendations.

I CPC-2A.R18

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Pagn 69 Rev 18 Date: June 6,1997 f

18a. ANSI N45.2.231978. Section 2.3.4 Reauirement The prospective lead auditor shall have participated in a minimum of five (5) quality assuranco audits within a period of time not to exceed three (3) years prior to the date of qualification, one 1

audit of which shall be a nuclear quality assurance audit within the year prior to his qualification. j 7

Exceotion/interoretation r

The prospective lead auditor shall demonstrate his ability to properly implement the audit process 4 l defined by this Standard and Consumers Energy program / procedure, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear quality assurance audit within the year preceding date of certification.  ;

19a. RG 1.26, General l

1 Reauirement I 1

RG 1.26 establishes a system for classifying pressure boundary items into four quality groups, j 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.) j Exceotion/Interoretation j 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 l Exception / Interpretation 21a, is used to determine what systems and equipment are included in

] the Quality Program.

. 20a. Branch Technical Position AS99.5.1 and 10 CFR 50 Anoendix R. l Sections til G.. ll1 J.. and ill O., General l

Exceotion/Interoretation I Fire protection measures, equipment and the indr.idual 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.

21a. RG 1.29. Sec C, Regulatory Position l j

Reauirement I The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category 1 and should be designed to withstand the SSE.

Exceotion/Interoretatica i

Both Consumers Energy nuclear plants (Big Rock Point and Palisades) were designed, constructed l and licensed based on criteria available prior to Revision 3 of this Regulatory Guide being issued.

4 The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respec-

CPC-2A.R18

Page 70 Rav18 Date: June 6,1997 tively, and in other docketed analysis. Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.

The criteria of this Regulatory Guide are used at Consumers Energy primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 21b, below).

l 21b. RG 1.29. General Reauirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B. ,

Exceotion/Interoretation The pertinent quality requirements for these systems, structures and components will be determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.

l 22. ANSf/ANS 3.1 -1987 Excentionllnteroretation The commitment to ANSl/ANS 3.1 1987 is limited to requ.rements that apply to persons ,

performing the independent safety review function as specified in Appendix C to this QPD.

CPC-2 A.R18

4 Pags 71 Rsv 18 Date: June 6,1997 i

4 QPD MANUAL l

' APPENDIX g PLANT REVIEW COMMITTEE (PRC)

B1. FUNCTION The Plant Review Committee (PRC) shall function to advise the Site Vice President / Plant General l 3 Manager on all matters related to nuclear safety.

i B2, COMPOSITION The Palisades PRC is composed of nine regular members. The qualification level for PRC members shall be at least equivalent to those described in Section 4.4 of ANSI N18.1-1971. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The Chairman, Alternate Chairmen, and members shall be designated in administrative procedures by the Site Vice President.

l The Big Rock Point PRC is composed of nine regular members from the Big Rock Point staff. The PRC members shall meet or exceed the minimum qualifications described in Sections 4.2 and 4.4 of ANSI N18.1-1971 for comparable positions. The PRC shallinclude representatives from the Operations, Chemistry / Health Physics, Maintenance, Engineering, and Safety and Licensing Departments. The members shall be designated in administrative procedures by the Plant l Manager who is the Chairman of the PRC. The Plant Manager shall also designate an Alternate Chairman in writing.

83. ALTERNATES 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.

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

B5. QUORUM A quorum of ~he Palisades PRC sheil 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.

86. RESPONSIBILiljES The PRC shall be responsible for nuclear safety review of:

a. All procedures and programs specified by the Technical Specifications and changes thereto, and any other procedures or changes thereto as determined by the Site Vice President / Plant l General Manager to affect nuclear safety; all proposed tests or experiments that affect nuclear safety; all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

CPC-2A.R18

Pign 72 Rav 18 Date: June 6,1997

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 - NFHO and to the Manager, Nuclear Performance Assessment Department (NPAD)).

d. Plant operations to detect potential safety hazards.

l e. Reports of special reviews and investigations as requested by the Site Vice President / Plant General Manager or NPAD.

4

+

f. Site Emergency Plan and implementing procedures,

g. All reportable events as defined in 10 CFR 50.72 and 50.73.  ;

j h. All items identified under 89.3 below as significant to nuclear safety (Palisades only).

1

1. Monthly reports from Safety / Design Review (Palisados only).

J. Nuclear industry operating experience.

k. Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the  !

corrective action to prevent recurrence and the forwarding of these reports to the Plant l l General Manager and to the Manager, Nuclear Performance Assessment Department (Big Rock Point only). 4 I

PRC review of the above items may be performed by routinn, subject to the requirements of B7. I below. The Palisades PRC may delegate review of item a. to Safety / Design Review staff, as described in 89. below.

B7. AUTHORITY The PRC shall:

a. Recommend in writing to the Site Vice President / Plant General Manager approval or disapproval of items considered under B6.a. through j. above.

b. Render determinations in writing with regard to whether or not each item considered under 4

l B6.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 Senior Vice President - Nuclear, Fossil, and Hydro Operations and to the Nuclear Performance Assessment Department of any disagreements between the PRC and the Site Vice President / Plant General Manager; however, the Site Vice President / Plant General Manager shall have responsibility for the resolution of such disagreements.

l The PRC Chairman may recommend to the Site Vice President / Plant General Manager approval of those items identified in B6. above based on a routing review provided the following conditions CPC-2A.R18

l Pega 73  !

Rsv 18 Date: June 6,1997 1

I are met: (1) at least five PRC members including the Chairman and no more than 2 alternates, shall review the item, concur with determination as to whether or not the item constitutes an unreviewed safety question, and provide written comments on the item; (2) all comments shall be resolved to the satisfaction of the reviewers providing the comments; and (3) if the PRC Chairman determines that the comments are significant, the item (including comments and resolutions) shall be recirculated to all reviewers for additional comments.

l l

The item shall be reviewed at a PRC meeting in the event that: (1) Comments are not resolved; or l (2) the Site Vice Presidant/ Plant General Manager overrides the recommendations of the PRC; or l l (3) a proposed change to the Technical Specifications involves a safety limit, a limiting safety l system setting or a limiting condition for operation; or (4) the item was reportable to the NRC.  !

88. RECORDS l The PRC shall maintain written minutes of each PRC meeting and shall provide copies for Independent Safety Review.

B9. TECHNICAL SUPPORT FOR PALISADES PRC The Safety / Design Review organization shall function to examine proposed changes in design or operation and such other matters as the Palisadas PRC may assign to identify issues significant to nuclear safety and recommend nuclear safety improvements.

B9.1 The Safety / Design staff responsible for the review function shall be an experienced technical staff l meeting the qualifications of Technical Specifications.

B9.2 The Safety / Design Review staff may provide nuclear safety review as delegated by Palisades PRC l for: -

a. Procedures, programs and changes thereto identified in the Technical Specifications and any additional procedures and changes thereto identified by the Site Vice President as significant l to nuclear safety.  !

I

b. All proposed tests or experiments.

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

d. The Site Emergency Plan and implementing procedures.

B9.3 The Safety / Design Review staff shall determine those issues significant to nuclear safety which require review by the Palisades Plant Review Committee from items considered under B9.2a. ]

through d. above. For those items not referred to PRC, Safety / Design Review shall recommend in j writing to plant management approval or disapproval of items considered under 89.2.

89.4 Reports of Safety / Design Review activities pursuant to 09 shall be submitted monthly to PRC.

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i Pags 74 Rsv 18 Date: June 6,1997 QPD MANUAL 2

APPENDIX C INDEPENDENT SAFETY REVIEW

] The following exceptions / interpretations in Appendix A, Part 2, are relevant to implementation of

the requirements of this section of the QPD

i Accendix C Exceotions/Interoretations 2c, 2d, 2e, 2f, 21 j 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 i b. Nuclear engineering i c. Chemistry and radiochemistry

d. Metallurgy

e. Nondestructive testing i f. Instrumentation and control

g. Radiological safety

h. Mechanical and electrical engineering i I. Administrative controls and quality assurance practices i J. Emergency Planning

k. Training f

C2. COMPOSITION i

l The ISRG shallinclude the Manager, NPAD, who reports to the Vice President - NFHO, and a full-time staff of persons reporting to the Manager, NPAD and designated as Nuclear Performance Specialists for the ISR function. The Manager, NPAD, and the Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4.7 of ANSI /ANS 3.1-1987. The ISRG shall have no direct responsibility for activities subject to its review.

C3. CONSULTANTS s

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 I

4 4

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Pags 75 Rav18 Date: June 6,1997 a

C4.1 REVIEW l

The ISRG shall review:

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. l 1

c. Proposed tests or experiments which involve an unreviewed safety question as defined in 10

. CFR 50.59. l

d. Proposed changes to Technical Specifications or the Operating License.

I

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 performance of unit equipment that affects nuclear safety.

l

g. All reportable events having nuclear safety significance.

h. All recognized indications of an unanticipated deficiency in some aspect of design or I operation of structures, systems, or components that could affect nuclear safety.

1. 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 l Specialist selected on the basis of technical expertise relative to the subject being reviewed. If the assigned Nuclear Performance Specialist determines the need for interdisciplinary review, a committee consisting of the Manager, NPAD, or his designate, and at least four Nuclear Performance Specialists, shall be assigned. Such committee shall meet as conditions requiring interdisciplinary review arise, but no less than twice yearly.

C5 AUTHORITY The ISRG shall report to and advise the Vice President, NFHO, of significant findings associated l with those areas of responsibility specified in C4 above and Appendix D, Audit Frequencies.

C6 RECORDS Records of ISRG activities shall be maintained. Reports shall be prepared and distributed as indicated below:

4 CPC-2A.R18

Pags 76 R:v18 Date: June 6,1997 l 4

, a. The results of reviews performed pursuant to C4 above shall be reported to the Vice-l President, NFHO, at least monthly,

b. A report assessing each plant's overall nuclear safety performance shall be provided to senior l Consumers Energy management annually, l

l l

1 1

1 4

1 i

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i l

Pigs 77

! RIv18

! Date: June 6,1997 l QPD MANUAL APPENDIX D l AUDIT FREQUENCIES l

D1. AUDITS Audits of operational nuclear safety related activities are performed by the NPAD staff under the cognizance of Nuclear Performance Specialists. These audits encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months,

b. The performance, training and qualifications of the entire facility staff at least once per 12 months,

c. The performance of activities 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 NPAD or the Vice President -

NFHO.

l

g. The plant Fire Protection Program and implementing procedures at kaast once per 24 months.

h. An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

l. An inspection and audit of the fire protection and loss prevention program to be performed by an outside qualified fire consultant at intervals no greater than 3 years.

j. Radiological environmental monitoring program and the results thereof at least once per 12 months.

k. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

l. The PROCESS CONTROL PROGRAM and implementing procedures for procecsing and packaging of radioactive wastes at least once per 24 months.

Audit reports encompassed by DI. 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, l

l l CPC-2A.R18

l Pags 78 Rav 18 Date: June 6,1997 QPD MANUAL APPENDIX E l RECORD RETENTION 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 i principalitems of equipment related to nuclear safety.

c. All reporteble events as defined in 10 CFR 50.72 and 50.73. ,

I

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. ,

1

g. Records of sealed source leak tests and results.

h. Records of annual physicalinventory of all source material of record.

E3, The following records shall be retained for the duration of the Facility Operating License:

a. Record and drawing changes reflec'ing facility design modifications made to systems and equipment described in the Palisades Final Safety Analysis Report or Big Rock Point Final Hazards Summary Report.

b. Records of new and irradiated fuelinventory, fuel transfers and assembly burnup histories,

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. Recurds 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 requ: red by the Quality Program Description,

n. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

l r

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i

' Pagn 79 Rav 18 Date: June 6,1997

l. Records of meetings of the PRC and reviews performed by NPAD according to Appendix B and C.

j. Records of monthly facility radiation and contamination surveys.

k. Records of secondary water sampling and quality (Palisades onb

1. Records of the service lives of all hydraulic and mechanical snubbers covered by Technical Specifications. This shallinclude the date at which the service life 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 Rock Point only).

n. Records of training and qualifications for members of the plant staff,

o. Records of reactor tests and experiments.

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

i i

6 CPC-2A.R18

l l

l I

4 ATTACHMENT 4 e

i CONSUMERS ENERGY COMPANY 1

BIG ROCK POINT PLANT DOCKET 50-155 '

PALISADES PLANT 3 DOCKET 50-255 i

i CPC-2A, Revision 18 Change Matrix l

l 24 l Pages j 4

i

CHANGE MATRIX 6/10/97 Ol!At ITY PRr0 RAM DESCRIPTION (CPC-?A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 1 1.1 POLICY (Page 1) 1.1 REQUIREMENTS (Page 1) Change made for each section title Content and commitmer.ts not affected.

to clarify that all parts of this QPD continues to cocply with 10 CFR 50.

OPD are requiremmts that must be Appendix B.

met (as specified in cover letter and other sections). Clarification necessary to satisfy NRC revi wer comm mt that " Policy

• could be interpreted as something less than a requirement.

2 1.1 (Page 1) 1.1 (Page 1) Corporate name change only. Content and commitments not affected.

Paragraph 1 Paragraph I QPD continues to comply with 10 CfR 50.

Appendix B.

Consumers Pwer Company (C?Co) is Consumers Energy is responsible for responsible for establishing and establishing and implementing the implementing the Quality Program, as Quality Program, as described herein, described herein. for the operational for the operational phase of its phase of its nuclear p w er plants. nuclear power plants. Although Although authority for development and authority for development and execution of some parts of the program execution of some parts of the program is delegated to others, suc.h as is delegated to others. such as contractors and consultants. CPCo contractors and consultants. Consumers retains overall responsibility. Energy retains overall responsibility.

3 1.1 (Page 1) 1.1 (Page 1) Corporate name change only. Content and commitments not affected.

Paragraph 2 Paragraph 2 QPD continues to comply with 10 CFR 50.

Appendix B.

This section of the Quality Program This section of the Quality Program Description (OPD) identifies the Description (QPD) identiftes the CPCo. Consumers Energy, 4 1.2.1 (Page 1) 1.2.1 (Page 1) Corporate name change and elevation Content and commitments not affected.

Paragraph 1 Paragraph 1 of management posttion responsible QPD continues to comply with 10 CFR 50, for nuclear plant operations. Appendix B.

The President and Chief Executive The President and Chief Executive Officer (see figure 1 of Company Officer (see Figure 1. Company Organization Charts) of CPCo is Organization Chart) of Consumers responsible for safe operation of CPCo Energy is responsible for safe nuclear pwer plants. Authority and operation of Constners Energy nuclear responsibility for establishing and pw er plants. Authority and implementing the Quality Program for responsibility for establishing and plant operations. maintenance and implementing the Quality Program for modifications is delegated through the plant operations. maintenance and Executive Vice President and Chief modifications is delegated through the Operating Of ficer - Electric to the Executive Vice President and Chief Vice President - Nuclear Operations. Operating Officer - Electric to the This delegation is formalized in a Senior Vice President - Nuclear.

STATEN NT OF RESPONSIBILITY AND Fossil, and Hydro Operations. This AUTHORITY signed by the President and delegation is fomalized in a Chief Executive Of ficer. Other STATEENT OF RESPONSIBILITY AND quality-related functions are provided AUTHORITY signed by the President and by other organizations as described Chief Executive Gf ficer. Other herein. quality-related functions are provided by other organizations as described herein.

Page 1

i CHANGE MATRIX 6/10/97 f 00AtlTY PROGRAM DESCRIPTION (CPC-?A) l RFVISION 18 Item Revision 17 Revision IF Reason for Change Basis for Conclusion 5 1.2.2 (Page 2) 1.2.2 (Page 2) Organization /name change resulting Content and counitments not affected. i from Item 4. OPD continues to comply with 10 CFR 50.

Responsibility for Attainin) Quality Responsibility for Attaining Quality Appendix B.

Objectives in the Mclear Operations Objectives at the Nuclear Plants ,

Organization >

6 1.2.2 (Page 2) 1.2.2 (Page 2) Corporate name change and elevation Content and commitments not affected.

Paragraph 1 Paragraph 1 of senior management position OPD continues to comply with 10 CFR 50. t responsible for nuclear operations. Appendix B.

The Vice President - Nuclear The Senior Vice President - Nuclear.

Operations is responsible to the Fossil. and Hydro Operations (NFHO) is  !

Executive Vice President and Chief responsible to the Executive Vice ,

Operating Officer - Electric for President and Chief Operating i operation and maintenance of CPCo Officer - Electric for operation and nuclear power plants. Managers who maintenance of Consumers Energy report to the Vice President. NOD. are nuclear pmer plants. Managers bdio i responsible for directing the report to the Vice President. NFHO.

performance of activities that affect are responsible for directing the safe plant operation and/or safety- performance of activities that affect related functions of structures, safe plant operation and/or safety-systems and components of the related functions of structures. '

operating nuclear power plants in systems and components of the accordance with Quality Program operating nuclear p mer plants in requirements. accordance with Quality Program j requirements.  ;

i 7 1.2.2.a. (Page 2) 1.2.2.a. (Page 2) Elevation of senior managemert Content and commitments not affected. [

Paragraph 1 Paragraph I posit 1 A responsible for Palisades OPD continues to comply with 10 CFR 50. t Plant and nuclear plant operations. Appendix B. t The Palisades Plant General Manager The Palisades Plant Site Vice i (see Figure 2) is responsible to the President (see Figure 1) is i Vice President. Nuclear Operations for responsible to tha Senior Vice operation and maintenance of the President. NFHO for operation and  ;

nuclear power plant in such a manner maintenance of the nuclear power plant t as to achieve Compliance With Plant in such a manner as to achieve licenses ap licable regulations and compliance with Plant licenses. t the Quality rogram. The Plant applicable regulations and the Quality  !

General Manager delegates to Program. The Site Vice President i appropriate managers and staff delegates to appropriate managers and t personnel in his organization staff personnel in his organization '

responsibility for carrying out responsibility for carrying out applicable controls required by the applicable controis required by the j Ouality Program. Quality Program Quality Program. Quality Program

• activities performed on the authority activities performed on the authority l of the Plant General Manager include: of the Site Vice President include 8 1.2.2.a. (Pege 2) 1.2.2.a. (Page 2) Position name change only. Content and commitments not affected. [

Paragraph 22 Paragraph 22 OPD continues to comply with 10 CFR 50. '

Appendix B.

Performing revims to advise the Plant Performing reviews to advise the Site ,

General Manager on matters related to Vice President on matters related to nuclear safety. as specified in nuclear safety as specified in ,

Appendix B. Plant Rev1 m Committee. Appendix B. Plant Revi m Committee.

Page 2 i

CHANri MATRIX 6/10/97 00AtITY PROGRAM OfSCRIPTION (CPC-2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 9 1.2.2.a. (Page 2) 1.2.2.a. (Page 2) Site reorganization eliminated the Cmtent and commitments not affected.

Nuclear Services organization (see OPD continues to cmply with 10 CFR 50.

hot in Revision 17, Paragraphs 23 through 34. Item 20) and made the nm Site Vice Appendix 8.

Presidant responsible for these items.

10 1.2.2.b. (Page 3) 1.2.2.b. (Page 3) Position name changes only. Content and commitments not affected.

Paragraph 1 Paragraph 1 QPD continues to comply with 10 CFR 50.

Appendix B.

The Big Rock Point Plant Manager (see The Big Rock Point Plant General Figure 2) is responsible to the Vice Manager (see Figure 1) is responsible President. Nuclear Operations for to the Senior Vice President. NFHO.

operation and maintenance of the for operation and maintenance of the nuclear power plant in such a manner nuclear power plant in such a manner as to achieve comgliance with Plant as to achieve cmpliance with plant licenses. apolica le regulations and licenses, applicable regulations and the Quality Program. The Plant the Quality Program. The Plant Manager delegates to appropriate General Manager delegates to managers and staff personnel in his appropriate managers and staff i organization responsibility for personnel in nts organization ,

carrying out appl! cable controls responsibility for carrying out '

required by the Quality Program. applicable controls required by the Quality Program activities performed Quality Program. Quality Program on the authority of the Plant Manager activities performed on the authority include: of the Plant General Manager include:

11 1.2.2.b. (Page 3) 1.2.2.b. (Page 4) Position name change only. Content and commitments not affected.

Paragrar>h 5 Paragraph 5 QPD continues to cmply with 10 CFR 50.

Appendix B.

Modifying components including Modifying components. Including procurement. Installation. Inspection procurement. Installation. Inspection and testing activities when assigned and testing activities when assigned by the Plant Manager. by the Plant General Manager.

12 1.2.2.b. (Page 5) 1.2.2.b. (Page 6) Position name change only. Content and commitments not af fected.

Paragraph 29 Paragraph 29 QPD continues to comply with 10 CFR 50.

Appendix B.

Performing reviews to advise the Plant Performing reviews to advise the Plant Manager on matters related to nuclear General Manager on matters related to safaty. as specified in Appendix S. nuclear safety. as specified in Plant Review Committee. Appendix B. Plant Revi m Committee.

13 1.2.2.c. (Page 5) 1.2.3 (Page 6) Renumbered section for clarity Content and commitments not affected.

Renumbered following organization and title OPD continues to comply with 10 CFR 50.

The Manager. Nuclear Performance changes. Retitled to be consistent Apper: dix B.

Assessment Department. (see Figure 2) Titled "Responsib111 ties of the with other sections.

is responsible for: Nuclear Performance Assessment Department Page 3

CHANGF MATRIX 6/10/97 00ALITY PROGRAM DESCRIPTION (CPC.2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 14 1.2.2.c. (Page 5) 1.2.3 (Page 6) Consolidation of two organization Content and cmmitments not affected.

Paragraph I Paragraph I charts into one, and position name OPD continues to c m ply with 10 CFR 50.

change. Reporting relationship not Appendix B.

The' Manager. Nuclear Performance The Manager. Nuclear Performance affected.

Assessment Department. (see Figure 2) Assessment Department. (see Fig *re 1) is responsible for: Is responsible to the Senior Vice President. NFHD. for:

15 1.2.2.c. (Page 5) 1.2.3 (Page 6) Position name changes only. Content and commitments not affected.

Paragraph 8 Paragraph 8 OPD continues to comply with 10 CFR 50 Recommending to the Plant General Recommending to the Site Vice Manager / Managers or the Vice President. the Plant General Manager.

President. Nuclear Operations that a or the Senior Vice President NFHD that plant be shut down if such action a plant be shut dom if such action appears necessary. appears necessary.

16 1.2.2.c. (Page 5) 1.2.3 (Page 6) Organization name replaced by Content and commitments not affected.

Paragraph 10 Paragraph 10 functional name. OPD continues to comply with 10 CFR 50.

Appendix B.

Revis rf performance trends Review of performance trends associated with NOD activities associated with nuclear plant including corrective actions. activ1tles including corrective actions.

17 1.2.2.c. (Page 6) 1.2.3 (Page 6) Corporate name change only. Content and commitments not affected.

Paragraph 13 Paragraph 13 OPD continues to comply with 10 CFR 50.

Appendix B.

Reporting audit findings relative to Reporting audit findings relative to foll m-up on corrective actions and foll m-up on corrective actions and the effectiveness of the Quality the effectiveness of the Quality Frogram to CPCo Management. Program to Consumers Energy Management 18 1.2.2.c. (Page 6) 1.2.3 (Page 6) Responsibility added p*-r senior facilitation role does not interfere Paragraph 15 management directive. with auditing and independent Not in Revision 17. assessment of plant actions. The Facilitation of Self-Assessment and Manager. NPAD. retains the required Quality Verification Programs independence to effectively carry out (Palisades only). his assessment role as required by Criterion I of 10 CFR 50. Appendix 8.

19 1.2.2.c. (Page 6) 1.2.3 (Page 7) Corporate name change only. Content and commitments not affected.

Paragraph 15 Paragraph 16 ODD continues to comply with 10 CFR 50.

in order to implement these In order to implement these responsibilities. the Manager. NPAD. responsibilities, the Manager. NPAD.

Is provided with "Stop Work" authority is provided with "Stop Work

• authority whereby he can suspend any quality whereby he can suspend any quality related activity or process which say. related activity or process which may.

In his opinion. adversely affect in his opinion. adversely affect public safety or the safe operation public safety or the safe operation of Consumers Power nuclear plants. Consumers Energy nuclear plants.

Page 4

CHANGE MATRIX 6/10/97 WAlITY PROGRAM DESCRIPTION (CPC-?A)

REVISION 18 Iten Revision 17 Revision 18 Reason for Change Basis for Conclusion 20 1.2.2.d. (Page 6) (Page 7) Site reorganization eliminated the Content and commitments not affected.

Nuclear Services organization (see OPD continues to comply with 10 CFR 50.

The General Manager. Nuclear- Not in Revision 18. Item 9) and made the new Site Vice Appendix B.

Services. President responsible for these These duties have been added to the items.

Site VP responsibilities.

21 1.2.3 (Page 7) 1.2.3 (Page 7) Conibination of nuclear. fossil and Content and commitments not affected.

hydro operations eliminated need for OPD cont'nues to comply with 10 CFR 50.

Responsibilities for Attaining Guality Not in Revision 18. thistitle. Appendix 8.

Objectives in Fossil and Hydro Operations.

22 1.2.3.a. (Page 7) 1.2.4 (Page 7) Fonnat change due to corporate re- Content and commitments not affected.

, organization that consolidated QPD continues to comply with 10 CFR 50.

The Manager. Equipment Services Responsibilities of the Equipment nuclear.. fossil and hydro plant Appendix B.

provides electrical, rotating and Services Department coerations under one Senior Vice stationary equipment expertise. Prnident.

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

including developing and qualifying procedures for welding and heat treatirg.

23 1.2.4 (Page 8) 1.2.5 (Page 7) Organization name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

Responsibilities for Attaining Quality Responsibility for Attaining Quality Appendix B.

Objectives Outside Nuclear Operations Objectives Outside Nuclear. Fossil and Fossil and Hydro Operations and Hydro Operations 24 1.2.4 (Page 8) 1.2.5 (Page 7) Corporate name change only. Content and commitments not affected.

Paragraph 1 Paragraph 1 Renumbered paragraph. OPD continues to comply with 10 CFR 50.

Appendix B.

Certain functions that constitute part Certain functions that constitute part of the Nuclear Operations Quality of the Nuclear Quality Program are Program are performed by CPCo. performed by Consumers Energy...

25 1.2.3.b. (Page 7) 1.2.5.b. (Page 7) Organization name and reporting Content and commitments not affected.

relationship changes. No change in QPD continues to comply with 10 CFR 50.

-The Director.. Fuel Sup. ply & Plant 'he i Executive Manager. Fuels & Power actual responsibilities. Appendix B.

Operations maintains the Records Transactions is responsible to the Management System including required Executive Vice President and Chief retention. protection and Operating Officer - Electric for retrievability.. maintaining the Records Maiiagement System including required retention.

protection and retrievability.

Page 5

CHANGE MATRIX 6/10/97 GIAt ITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Ites Revision 17 Revision 18 Reason for Change Basis for Conclusion 26 1.2.4.b. (Page 8) 1.2.5.c. (Page 7) Organization name and reporting Content and commitments not affected.

relationship changes. No change to OPD continues to comply with 10 CFR 50.

The Director. Electric Employee The Manager. Production Services (see actual responsibilities. Appendix 8.

Development (see Figure 1) is Figure 1) is responsible throu the responsible to the Executive Vice Vice President Electric Transa ssim President and Chief Operating Officer and Distribution to the Executive Vice

- Electric for operating the Skill President end Chief Operating Officer Centers including the training, and - Electric for operating the Skill qualifying of personnel and equipment Centers including the training. and for welding operations. qualifying of personnel and equipment for welding operations.

27 1.2.4.c. (Page 8) 1.2.5.d. (Page 7) Renumbered paragraph. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

The Corporate Records A &inistrator. Renumbered. Appendix B.

28 1.2.4.d (Page 8) 1.2.5.e. (Page 8) Renumbered paragraph. Content and commitments not affected.

OPD continues to cmply with 10 CFR 50.

The Manager. Environmental and The Manager. Environmental and Appendit B.

4 Technical Services (EATS). Technical Services (E&TS)..

29 1.2.4.d. (Page S) 1.2.5.e. (Page 8) Renumbered paragraph. Changed Content and car sitments not affected.

Paragraph 5 Paragraph 5 organization to functional wording. OPD continues o comply with 10 CFR 50.

1 Appendix B.

Providing a PL-M&TE Inventory List for Providing a PL-M&TE Inventory List for

~

Nuclear Operations. Nuclear plants, i

30 1.2.4.d. (Page 8) 1.2.5.e. (Page 8) Renumbered paragraph. ChangM Content and .ommitments not affected.

Paragraph 6 Paragraph 6 organization to functional wording. OPD continte s to comply with 10 CFR 50.

Providing chemistry support to Nuclear Providing chemistry support to Nuclear Operations, as requested. plants, as requested.

31 1.2.4.e. (Page 9) 1.2.5.f. (Page 8) Renumbered paragraph. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

The Manager. Electric Services is The Manager. Electric Services is Appendix B.

responsible. through. . responsible. through. .

32 Figure 1 (Page 10) ' figure 1 (Page 9) Revised to show title and Content and cmmitments not affected.

Corporate Organization Corporate Organization organization changes described in OPD continues to comply with 10 CFR 50.

Section 1.0. Appendix B.

] 33 2.1 POLICY (Page 12) 2.1 REQUIREMENTS (Page 10) Change made for each section title Content and commitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50

. OPD are requirements that must be Appendix B.

1 met (as specified in cover letter and other sections). Clarification

, necessary to satisfy NRC reviewer

! comment that " Policy

• could be interpreted as something less than a requirement.

Page 6

.- . _ - - _ - - - _ - _ - _ . _ . ~ - _ _ - - . . . _ _ .__ _ _. - . _ _ _ _ . -_ __ ____ - - _ _ _ . . _ - - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ - _ - - _

CHANGE MATRIX 6/10/97 GIAl ITY PROGRAM ()fSCRIPTION (CPC.2A) i REVISION 18 '

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 34 2.1 (Page 12) 2.1 (Page 10) Corporate name change only. Content and commitments not affected.  !

Paragraph 1 Paragraoh 1 OPD continues to comply with 10 CFR 50.

Policles that define and establish the Policies that define and establish Consumers Power Company (CPCo) Quality Consumers Energy Quality Program.

Program.

35 2.1 (Page 12) 2.1 (Page 10) Corporate name change only. Content and commitments not affected.

Paragraph 3 Paragraph 3 QPD continues to c mply with 10 CFR 50. >

Appendix B.

Quality Pr ram status sc e. Quality Program status, sc e.

adequacy an compliance wit adequacy and c m pliance wit 10 CFR 50. Appendix B are regularly 10 CfR 50. Appendix B are regularly reviewed by CPCo Management. reviewed by Constners Energy.

i 36 2.1 (Page 12) 2.1 (Page 10) Renumbered exceptions due to change Content and commitments not affected. ,

Paragraph 4 Paragraph 4 in Appendix A. Part 2. OPD continues to c mply with 10 CFR 50.

Appendix B.  !

Paraqraph Extentions. Paracraoh Exceptions. -

2.2.3 204, 20.b 2.2.3 21a. 21.b E[i.6 1. 184. 20a. 20b k.'d.6 1. 19. 21a. 21b 37 2.2.1 (Page 12) 2.2.1 (Page 10) Corporate name change only. Content and commitments not affected.

OPD continues to comply w1th 10 CFR 50.

The President of Consumers Power The President of Consumers Energy, as Appendix B.

Company. as Chief. Chief.

38 2.2.2 (Page 12) 2.2.2 (Page 10) Corporate name change only. Content and commitments not affected. l OPD continues to comply with 10 CFR 50. L The Quality Program at CPCo. The Quality Program at Consumers Appendix B. [

Energy.

I 39 2.2.3.b. (Page 13) 2.2.3.b. (Page 11) Corporate name change only. Content and commitments not affected.  !

OPD continues to comply with 10 CFR 50. i The Quality Program described in this The Quality Program described in this Appendix B. ,

, Quality Program Description is Quality Program Description is  !

intended to apply for the life of intended to apply for the life of ,

CPCo's nuclear power plants. Consumers Energy's nuclear power t plants. [

L b

P Page 7

i i

CHANGE MAfRIX 6/10/97 00AlITY PROGRAM DESCRIPT10N (CPC-2A)

RFVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion i

40 2.2.4 (Page 13) 2.2.4 (Page 11) Corporate name change. Added Addition of reference to 10 CFR 71 adds ,

wording on annual submittal to more clarity. No other content or This Quality Program Description. This Quality Program Description. clearly address 10 CFR 50.54 and commitment changes. OPD continues to  !

organtred to present the CPCo Quality organized to present the Consumers 10 CFR 71 requirements. seet 10 CFR 50. Appendfx B.

Program for Operational Nuclear Power Energy Ouality Program for Operational Plants in the order of the 18 criteria Nuclear Power Plants in the order of of 10 CFR 50. Appendix B. states CPCo the 18 criteria of 10 CFR 50.

policy for each of the criteria and Appendix B. states Consmers Energy describes how the controls pertinent recutrements for each of the criteria to each are carried out. Any changes and describes how the controls made to this Quality Program pertinent to each are carried out. l Description that do reduce the Any changes made to this Quality  ;

commitments previously accepted by the Program Description that do not reduce NRC must be submitted to the NRC and the commitments previously accepted by receive NRC approval prior to the NRC must be submitted to the NRC 1mplementation. The submittal of the at least annually as specified by  ;

changes described above shall be made 10 CFR 50.71.e. Any cnanges made to  !

in accordance with the requirements of this Quality Program Description that 10 CFR 50.54. do reduce the commitments previcusly accepted by the NRC must be submitted  ;

to the NRC and receive NRC approval -

prior to implementation in accordance with the requirements of 10 CFR 50.54.

41 2.2.5.b. (Page 13) 2.2.5.b. (Page 11) Corporate name change only. Content and commitments not affected.

QPD continues to comply with 10 CFR 50 f When Contractors perform work under When Contractors perform work under Appendix 8.  ;

their own quality assurance programs, their own quality assurance programs. t these programs are reviewed for these programs are reviewed for l compliance with the applicable compliance with the applicable requirements of 10 CFR 50. Appendix B requirements of 10 CFR 50. Appendix B =

and the contract. and are approved by and the contract. and are approved by '

CPCo prior to the start of work. Consumers Energy prior to the start of

• work.

42 2.2.5.c. (Paga 13) 2.2.5.c. (Page 11) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CfR 50.

Applicable elements of the operations Applicable elements of the operations Appendix B.

Quality Program are applied to Qaality Program are applied to emergency plans. security plans. emergency plans. security plans. i radiation and fire protection plans radiation and fire protection plans  !

for CPCo. . for Consumers Energy. j 43 2.2.6 (Page 14) 2.2.6 (Page 11) Corporate name change only. Content and commitments not affected.

Paragraph 2 Paragraph 2 OPD continues to comply with 10 CFR 50.

• Appendix A to this Quality Program Appendix A to this Quality Program Description lists the ANSI Standards Description lists the ANSI Standards and Regulatory Guides to which CPCo and Regulatory Guides to which .

commits. . Consumers Energy.

l l

t Page 8

. ._.__m_ _m.~.--_. -m . ~ _ .. _ _ _ - - - . _-

CHANGE MATRIX 6/10/97 GIAIITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 i

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion j 44 2.2.6.a. (Page 14) 2.2.6.a. (Page 12) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50 CPCo uses the criteria spectfled in Consumers Energy uses the criteria Append 1x B.  ;

Regulatory Guides 1.26 and 1.29 in specified in R ulatory Guides 1.26 engineering... and 1.29 in eng neering.  ;

45 2.2.8 (Page 14) 2.2.8 (Page 12) Corporate name change only. Content and commitments not affected. t OPD continues to comply with 10 CfR 50  !

Development. cmtrol and use of Development. control and use of Appendix B.  !

computer programs affecting nuclear compt.ter programs affecting nuclear l power plant design and operation at power plant design and operation at  :

CPCo are subject. . Constmiers Energy are subject.

46 2.2.9 (Page 15) 2.2.9 (Page 12) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50. t' Responsibility and authority for Responsibility and authority for Appendix B.

planning and implementing planning and implementing  ;

indoctrination and training are indoctrination and training are  !

specifically designated in the CPCo specifically designated in the organization. . Consuners Energy organization. .  ;

i 47 2.2.10 (Page 15) 2.2.10 (Page 13) Corporate name change only. Content and commitments not affected.  !

QPD continues to comply with 10 CFR 50. i Status and adequacy of the quality Status and adequacy of the quality Appendix B.  ;

program are regularly assessed by CPCo program are regularly assessed by {

Management. Consumers Energy Management. .

48 3.1 POLICY (Page 16) 3.1 REQUIREMENTS (Page 14) Change made for each section title Content and commitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50 l QPD are requirements that must be Appendix B.

met (as specified in cover letter and other sections). Clari fication f2 necessary to satisfy NRC reviewer comment that

• Policy" could be [

interpreted as something less than a requirement.  ;

t 49 3.2.1 (Page 16) 3.2.1 (Page 14) Department organization change. Content and commitments not affected.

Each plant was, and remains. Its own QPD continues to comply with 10 CFR 50. i Authority and responsibility for Authority and responsibility for

• design authority.* Appendix B.  !

modification activities is under the modification activities is under the [

cognizance of the Nuclear Operations cognizance of the Nuclear Plants Department. l I

50 3.2.5 (Page 17) 3.2.5 (Page 15) Corporate name change only. Content and commitments not affected.  !

QPD continues to comply with 10 CFR 50. t

... Decisions and problem resolutions ... Decisions and problem resolutions Appendix B. t involving design interfaces are made involving design interfaces are made .

by the CPCo organization having by the Consumers Energy organization  !

responsibility for engineering having responsibility for engineering direction of the design effort. direction of the design effort.

Page 9

i CHANrE MATRIX 6/10/97 f

4 Gi!ALITY PK .;N DESCRIPTION (CPC-2A) t t l REVISION 18 i

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion i

! 51 3.2.7 (Page 17) 3.2.7 (Page 15) Reorganization eliminated the Content and commitments not affected.

Nuclear Engineering and Construction QPD continues to comply with 10 CFR 50.

, Modification design doctment packages Modification design doctment packages department. Reviews are still Appendix B.

4 are reviewed by either Plant are revi sed by Plant Engineering performed by the design authority.

Engineering personnel or by Nuclear personnel to assure that the Engineering and Construction personnel doctment s.

to assure that the documents. _

52 4.1 POLICY (Page 19) 4.1 REQUIREMENTS (Page 17) Change made for each section title Content and commitments not affected. <

, to clarify that all parts of this OPD continues to comply with 10 CFR 50 QPD are requirements that must be Appendix B. l

< met (as specified in cover letter j and other sections). Clartf1Catton ,

4 necessary to satisfy NRC. reviewer  ;

j comment that " Policy" could be '

< interpreted as something less than a

requirement.

i 53 4.2.3.e. (Page 19) 4.2.3.e. (Page 17) Corporate name change only. Content and commitments not affected. <

QPD continues to comply with 10 CFR 50.  !

, A requirement for a documented Quality A requirement for a documented Quality Appendix B. i Program, subject to CPCo revi m and Program subject to Consumers Energy written concurrence prior to the start review and written concurrence prior ,

of work. to start of work. i

, 54 4.2.3.h. (Page 20) 4.2.3.h, (Page 18) Corporate name change only. Content and c mmitments not affected.

OPD continues to comply with 10 CTR 50. i

...the schedule of saamittals and ...the schedule of submittals and Appendix B. t identification of doctments requiring identification of documents requiring  ;

CPCo approval. Consumers Energy approval.

i .

55 5.1 POLICY (Page 21) 5.1 REQUIREMENTS (Page 19) Change made for each section title- Content and commitments not affected.  !

4 to clarify that all parts of this QPD continues to comply with 10 CFR 50. i QPD are requirements that must be Appendix B.  !

met (as specified in cover letter and other sections). Clarification-necessary to satisfy NRC reviewer comment that " Policy' could be t interpreted as something less than a  !

, requirement.

56 5.2 (Page 21) 5.2 (Page 19) Corporate name change only. Content and commitments not affected.

1 Paragraph 4 Paragraph 4 QPD continues to comply with 10 CFR 50. t Appendix B. I The procedures used by CPCo to control The procedures used by Consumers

• lts activities include the following: Energy to control its activities include the following:  :

i 57 5.2.15.c. (Page 23) 5.2.15 c. (Page 21) Corporate name change only. Content and commitments not affected.

QPD continues to comply with 10 CFR 50.

• Control of the interfaces between CPCo Control of the interfaces between Appendix B.

and its suppliers Consumers Energy and its suppliers  !

t Page 10 i 1

_ _ _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ . A-_ __ m . _ r-%'- M a +-' -- - -__m_ ___._. - -m._.

~- . . - ,

i l

l CHANGE MATRIX 6/10/97 ,

l [

l OMAtITY PROGRAM DESCRIPTION (CPC-?A) J t

REVISION 18 i l

l I Item Revision 17 Revision IL Reason for Change Basis for Conclusion 58 5.2.15.d. (Page 23) (Page 21) Procedures for controlling plant Withreorfanizations. management control o modifications rests modifications must still meet all I

, Offsite management control Not in Revision 18. old 5.2.15.e. onsite. relevant requirements. There is no  ;

renumbered as 5.2.15.d. need to address offsite management .

control. since none is provided. This t section continues to meet Criterton V  ;

)

of 10 CFR 50. Appendix B.

! 59 6.1 POLICY (Page 24) 6.1 REQUIREMENTS (Page 22) Change made for each section title Content and commitments not affected.  :

to clarify that all parts of this QPD continues to comply with 10 CFR 50. I

QPD are requirements that must be Appendix B. I

! met (as specified in craer letter ,

and other sections). Clarification  !

necessary to satisfy NRC reviewer comment that " Policy" could be I l

Interpreted as something less than a j requirement.  !

i

.! 60 6.1.1 (Page 24) 6.1.1 (Page 22) Position title change only. Content and c waitments not affected. l QPD continues to comply with 10 CFR 50. i for Palisades, an ap For Palisades. an appropriate senior Appendix B. I department manager. propriate Dased on the senior department manager, based on the activities addressed in the specific activities addressed in the specific  ;

procedure, predesignated in writing by procedure. predesignated in writing by  !

the Plant General Manager: or the Site Vice President; or j i

61 6.1.2 (Page 24) 6.1.2 (Page 22) Position title change only. Content and commitments not affected.  ;

OPD continues to comply with 10 CFR 50.  ;

For Big Rock Point. the Plant Manager. For Big Rock Point. the Plant General Appendix B. {

Manager. j 62 7.1 POLICY (Page 26) 7.1 REQUIREMENTS (Page 24) Change made for each section title Content and commitments not affected.  !

to clarify that all parts of this OPD continues to comply with 10 CFR 50. }

QPD are requirements that must be Appendix B. i met (as specified in cover letter [

and other sections). Clarification  ;

necessary to satisfy NRC review w I comment that " Policy" could be interpreted as scaething less than a t

requirement. 7 t

63 7.1 (Page 26) 7.1 (Page 24) Added reference to new exception NRC memo stated the change was .

Paragraph 2 Paragraph 2 recently approved by NRC memo dated acceptable and the OPD

• continues to April 18. 1997. seet the requirements of ,

, Paraqraph Exceptions. Paracraoh Exceptions. 10 CFR Part 50. Appendix B.  ;

E2.2 Not in Revision 17 E2.2 16d i i I

t Page 11 f

O'ANGE MATRIX 6/10/97 OIAllTY PROGrM DESCRIP. TION (CPC-2A)

NEVIS10N 18 Item Revision 17 Revision 18 Reason for Change Barts for Conclusion 64 7.2.2 (Page 26) 1.2.2 (Page 24) Corporate name change. Changed NRC memo stated change from annual

• annually

• to

• continuously

• per new evaluations was acceptable. based on CPCo qualifies suppliers by performing Constners Energy qualifies suppliers Exception / Interpretation 16d. continuous monitoring / evaluation of a documented evaluation of their by performing a documented evaluation approved by NRC on April 18. 1997. supplier performance. NRC memo stated capability to provide items or of their capability to provide items the OPD

• continues to meet the services specified by procurement or services specified by procurement requirements of 10 CFR Part 50.

doctnents. To remain qualified. documents. To remain qualified. Appendix B.*

s'4 pliers involved in Ative surpliers involved in active j procurrients are reevM .ated annually procurements are evaluated

, and are audited triera hlly, if an continuously and are audited

! audit is acquired frA .a external triennially. If an audit is acquired ,

! sourre. the audit is evaluated prior from en external source. the audit is !

to its use, evaluated prior to its use. '

~

l 65 8.1 POLICY (Page 29) 8.1 REQUIREMENTS (Page 26) Change made for each sect:an Content and commitments not affected.

l to clarify that all parts of this QPD continues to comply with 10 CFR 50.

( QPD are requirements that must be Appendix B.

met (as specified in cover letter ,

and other sections). Clarification '

necessary to satisfy NRC reviewer

{ comment that " Policy

• could be interpreted as something less than a L requirement.

i 66 9.1 POLICY (Page 30) 9.1 REQUMEMENTS (Page 27) Change made for each section title Content and commitments not affected. [

to clarify that all parts of this QPD continues to comply with 10 CFR 50

• QPD are requirements that must be Appendix B.

l met (as specified in cover letter  ;

and other sections). Clarification l necessary to satisfy #1RC reviewer comment that

• Policy" cnuld be ,

interpreted as something less than a requirement.

5 67 9.2.1 (Page 30) 9.2.1 (Page 27) C rporate name change only, Content and commitments not affected.  !

OPD continues to comply with 10 CFR 50 Processes subject to special process Processes subject to special process Appendix B. ,

controls at CPCo are those. . controls at Consumers Energy are those.

68 9 2.7 (Page 30) 9.2.7 (Page 27) Provide proper department name Content and commitments not affected.

(corrects typo). QPD continues to comply with 10 CFR 50. l-The Nuclear Assessment Department The Nucl ar Performance Assessment Appendix B.  !

l audits / assesses special process Department audits / assesses special activities. Incir-1ing qualification process activities. Including activities to a%ure they are qualification activities to assure satisfactorily performed. they are satisfactorily performed.  !

Page 12

- . - . _ . - - - - - . ~ ~ . - ~ . - . - . . - - . . . -

l CHANGE MATRIX 6/10/97 UIALITY PROGRM1 DESCRIPTION (CPC-2A) j REVISION 18 i Ites Revision 17 Revision 18 Reason for Change Basis for Conclusion  !

69 10.1 POLICY (Page 31) 10.1 REQUIREMENTS (Page 28) Change made for each section t ule Content and commitments not affected. }

to clarify that all parts of this OPD continues to comply with 10 CFR 50.

OPD are requirements that must be Appendix B.

met (as specified in cover letter '

and other sections). Clarification  ;

necessary to satisfy NRC reviewer i comment that.* Policy" could be interpreted as something less than a 4

requirement. '

m.

[

f 70 10.2.3 (Page 32) 10.2.3 (Page 29) Position title change and Content and commitments not affected.

elimination of the Nuclear Services OPD continues to comply with 10 CFR 50, i

...The Plant General Manager / Manager ...The Site Vice President / Plant Department. The Site Vice President Appendix B.

is responsible for review and General Manager is responsible for now is responsible, as all site t concurrence with plant training and revim and concurrence with plant activities are under his direct f qualification programs that are under training and qualification programs control. r his direct responsibility. For that are under his direct i activities performed at Palisades that responsibility. e are under the cognizance of Nuclear >

Services. the Manager. Nuclear ,

Projects and Construction is  !

responsible for rev1N and concurrence t of such gograms. j i T 71 10.2.7.b. (Page 33) 10.2.7.b. (Page 30) Corporate name change only. Atent and commitments not affected.

uPD continues to comply with 10 CFR 50. 1 The work is within the skills of CPCo The work is within the skills of Appendix B.

l personnel. . Consume . onergy personnel.

I 72 10.2.10.a. (Pace 33) 10.2.10.a. (Page 30) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 FFR 50.  !

The work is performed using the CPCo The work is performed using the Appendix B.  !

Quality Program and procedures. Consumers Enargy Quality Program and  ;

procedures.

73 11.1 POLICY (Page 34) 11.1 REQUIREMENTS (Page 31) thange made for each section title Content and commitments not affected. '

to clarify that all parte of this OPD continues to comply with 10 CFR 50. ,

, QPD are requirements that must be met (as specified in cover letter Appendix B. '!j and other sections). Clarification  ;

necessary to satisfy NRC reviser '

comment that " Policy" could be  !

interpreted as something less than a  !

reqairement.

74 12.1 POLICY (P y a6) 12.1 REQUIREMENTS (Page 33) Content and commitments not affected.

! Chanfemadeforeachsectiontitle to c arify that all parts of this OPD continues to comply with 10 CFR 50.

QPD are requirements that must be Appendix B. ,

met (as specified in cover letter t and other sections). Clarification L necessary to satisfy NRC reviaer ,

comment that

• Policy" could be [

interpreted as something less than a i requirement.

Page 13

._--n, . - - - . - - . _ _ _ . - - . . - _ _ . _ _ . - - _ _ . . = . - - - _ _ - - _ - _ _ = _ - _ - _ .__ _ _ _ . _ - - - - - . - _ - . _ _ - _ _ _ _ _ _ _ . _ _ - - _ - - . _ _ . . _ _ - . - - - _ _ . . . . _ _ _ _ _ - _ _ - . . --.

, - _ . . - . . m.. . . _ _ .__m . . ~ ..m . - m _

.= - i C M7SE MATRIX 6/10/97 OtfALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion

'S 12.2.4 (Page 36) 12.2.4 (Page 33) Corporate name change only. Content and commitsnts not affected.

OPD continues to comply with 10 CFR 50.

CPCo uses a system of labels to be Consumers Energy uses a system of Appendix B.

f- attached to. labe M to be attached to. .

76 13.1 POLICY (Page 38) 13.1 REQUIREMENTS (Page 35) Change made for each section title Content and comitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50.

OPD are requirements that must be Appendix B.

met (as specified in cover letter and other sections). Clarification necessary to satisfy NRC reviewer comment that " Policy

• could be interpreted as something less than a requirement.

77 14.1 POLICY (Page 39) 14.1 REQUIREMENTS (Page 36) Change made for each sxtion title Content and commitments not affected.

to clarify that al: parts of this ODD continues to comply with 10 CFR 50, 6 9 are requ.rements that must be Appendix B.

met (as specified in cover letter and other sections). Clari fication necessary to satisfy NRC reviewer comment that

• Policy" could be interpreted as something less than a requirement.

78 15.1 POLICY (Page 40s 15.1 REQUIREMENTS (Page 37) Change made for each section title Content and commitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50.

OPD are requirements that rust be Appendix B.

met (as specified in cover letter and other sections). Clarification necessary to satisfy NRC reviewer comment that " Policy" could be interpreted as something less than a requirement.

79 16.1 POLICY (Page 42) 16.1 REQUIREMENTS (Page 39) Change made for each section title Content and commitments not affected.

to clarify inat all parts of this OPD continues to comply with 10 CFR 50.

OPD are requirements that must be Appendix B.

met (as specified in cover letter and other sections). Clarification nacessary to satisfy NRC revi ser comment that " Policy" could be interpreted as something lesa than a requirement.

80 17.1 POLICY (Page 43) 17.1 REQUIREY NTS (Page 40) Change made for each section title Content and commitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50.

OPD are renuirements that must be Appendix B.

met (as specified in cover letter and other sections). Clarification necessary to satisfy NRC reviner comment Jiat

• Policy" could be interpreted as something less than a requirement. g Page 14

CHANr,E MATRIX 6/10/97 '

01iAtiTY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Iten Revision 17 Revision 18 Reason for Change Basis for Cor clusion j 81 18.1 POLICY (Page 45) 18.1 REQUIREMENTS (Page 42) Change made for each sectim title Content and c m mitments not affected.

to clarify that all parts of this OPD continues to comply with 10 CFR 50.

OPD are requirements that must be Appendix B.

met (as specified in cover letter ,

and other sections). Clari fication necessary to satisfy NRC reviewer ,

comment that " Policy" could be "

r interpreted as something less than a requirement.

82 QPD Manual (Page 47) QPD Manual (Page 44) Corporate name change only. Content and commitments not affected. t Appendix A. Psrt 1 Appendix A. Part 1 QPD continues to comply with 10 CFR 50. ,

Paragraph 1 Paragraph 1 Appendix B. i The Cmsumers Power Company Quality The Consumers Energy Quality Program Program complies $ th the c mplies with the regulatory.

regulatory..

R3 Appendix A. Part 1 - 3 (Page 47) Appendix A. Part 1 - 3 (Page 44) Clarifles limitation of commitment Content and cmmitments not affected.

as described in exceptions. OPD continues to comply with 10 CFR 50. l Regulatory Guide 1.8 - (9/80 Draft) - Regulatory Guide 1.8 - (9/80 Draft) - (Exceptions were always part of QPD. Appendix B. ,

l Personnel Qualification and Training - no change made in actual <

PersonnelANSI Endorses Qualification

/ANS 3.1 and Training)-

- (12/79 Draft . Endorses ANSl/ANS 3.1 - (12/79 Draft) commitments.)

(application limited as described in exceptions 4a and Sa of Appendix A.

Part 2).  !

i 84 Appendix A. Part 1 - 22 (Page 48) Appendix A. Part 1 - 22 (Page 45) Corrects typo (missing parens). N/A  ;

ANSI /ANS 3.1-1987. Section. ANSI /ANS 3.1-1987. Selection.  !

Qualification. and Training of Qualification. and Training of Personnel for Nuclear Power Plants Personnel for Nuclear Power Plants .

application limited as described in (application limited as described in  !

Appendix C of this document). Appendix C of this docment). t L

85 QPP Manual (Page 49) OPD Manual (Page 46) Corporate name change only. Content and commitments not affected. i Appendix A. Part 2 Appendix A. Part 2 OPD cont:aues to comply with 10 CFR 50.  !

Appendix B.

ICPCOExceptionstoOperatingPhase Consumers Energy Exceptions to d

• a-d+ ds and Regulatory Guides Operating Phase Standards and '

i g Regulatory Guides  ;

, Appm...x A. Part 2 (Page 49) Appendix A. Part 2 (Page 46) Corporate name change only. Content and commitments not affected.

1. Paragraph 3 1. Paragraph 3 OPD continues to comply with 10 CFR 50.

Appendix B.

The CPCo commitment refers to the The Consumers Energy commitment refers Regulatory Guides, to the Regulatory Guides.

87 Appmdix A. Part 2 (Page 49) Appendix A. Part 2 (Page 46) Corporate name change only. Content and cunmitmes.ts not affected.  ;

1. Paragraph 4 1. Paragraph 4 OPD continues to comply with 10 CFR 50.

Appendix B.

Imposition of these Regulatory Guides imposition of these Regulatory Guides ,

on CPCo suppiters.. on Consumers Energy suppliers.

Page 15

.m CHANGE t%TRIX - 6/10/97 OIALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Item Rwiston 17 Revision 18 Reason'for Change Basis for Conclusion 88 Appendix A. Part 2 (Page 49) Appendix A. Part 2 (Page 46) Corporate name change only. Content and commitments not affected.

2. Paragraph 1 2. Paragraph 5 OPD continues to comply with 10 CFR 50.

Appendix B.

Consumers Power Company has Consumers Energy has established an established an organizational unit, organizational unit.

89 Appendix A. Part 2 (Page 49) Appendix A. Part 2 (Page 47) Corporate name change only. Content and commitments not affected.

2a. Exception / Interpretation 2a. Exception / Interpretation QPD continues to comply with 10 CFR 50.

Appendix B.

Since CPCo has more than one nuclear Since Consumers Energy has more than unit. . one nuclear unit.

90 2h. (Page 52) 2h. (Page 49) Corporate name change only. Content and commitments not affected.

Exception / Interpretation Exception /Interpretstion OPD continues to comply with 10 CFR '0.

Appendix B.

l CPCo considers that this requirement Constmiers Energy considers that this applies only to procedures.. requirement applies only to procedures..

91 2h.c.! (Page 52) 2h.c.1. (Page (9) Position title change only. Content and commitments not affected.

QPD continues to comply with 10 CFR 50.

Appropriate

• senior Palisades Appropriate

• senior Palisades Appendix B.

department manager predesignated by department manager predesignated by the Plant General Manager: or the Site Vice President: or 92 2h.c.2. (Page 52) 2h.c.2. (Page 49) Position title change only. Content and commitments not affected.

OPD continues to cmply with 10 CFR 50.

The Big Rock Foint Plant Manager. The Big Rock Point General Manager. Appendix B.

~

93 2h.(*) (Page 52) 2h.(*) (Page 49) Position title change only. Content and cemitments not affected.

OPD continues to comply with 10 CFR 50.

Determination of the appropriate Determination of the appropriate Appendix B.

senior Palisades department manager is senior Palisades department manager is based on the activities addressed in based on the activities addressed in the specific procedure, and will be the specific procedure. and will be predesignatedinwritingbythe gredesignatedinwritingbythe ralisades Plant General Managar. ralisades Plant Site Vice President.

94 21. (Page 52) 21. (Page 49) Corporate name change only. Content and commitments not affected.

Paragraph 2 Paragraph 2 QPD continues to comply with 10 CFR 50.

Appendix B.

CPCo initiates appropriate corrective Consmers Energy initiates appropriate action when it is discovered. corrective action when it is discovered.

% 2J. Exception. . (Page 53) 2j. Exception. (Page 50) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

Work that is within the skills of CPCo Work that is within the skills of Appendix B.

personnel. Consumers Energy personnel. .

b-Page 16

_ _ _ = _ _ _ _ _ __ _ ____ __

CHANGE MATRIX 6/10/97 0lALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion

% 2p. Exception.. (Page 55) 2p. Exceptions. (Page 52) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

Maintenance and modification Maintenance modification activities Appendix B.

activities which are within the skills which are within the skills of

'f CPCo maintenance personnel. ConsurJers Energy maintenance personnel.

97 2q. Except.on. (Page 55) 2q. Exception. (Page 52) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

CPCo uses the terminology

• independent Consumers Energy uses the terminology Appendix B.

verification points

• as. " Independent verification points" as. ,

98 2r. Exception. (Page 56) 2r. Exception. (Page 53) Corporate name change only. Content and commitments not affected.

OPD continues to comply with it, CFR 50. i At CPCo. equipment is returned to its At Consumers Energy. equipment is Appendix B.

normal operating status. returnad to its normal operating status. .

99 3b. Exception. (Page 57) 3b. Exception. (Page 54) Corporate name change only. Content and commitments not affected.

Paragraph 1 Paragraph 1 OPD continues to comply with 10 CFR 50.

Consistent with guidance presented in Consistent with guidance presented in NRC letters dated March 29. 1983 NRC letters dated March 20. 1983 l (RLSpessard to JMTaylor) and (RLSpessard to JMTafl or) and  :

January 30.1984 (JGPartim to January 30.1984 (JGPartlow to  !

RLSpessard). Consumer Power company RLSpessard). Consumers Energy l i

interprets the commitment to. Interprets the commitment to..  ;

100 3b. Exception. (Page 57) 3b. Exception. (Page 54) Corporate name change only. Content and commitments not affected. ,

Paragraph 2 Paragraph 2 QPD continues to comply with 10 CFR 50.. i Appendix B.

Consumers Pmer Company maintains a Consumers Energy maintains a matrix <

mitrix that identifies. that identifies.

T 101 4a. Exception. (Page 57) 4a. Exception. (Page 54) Change bar was placed on this item Content and comm.tments not affected. I in error. No difference between OPD continues to comply with 10 CFR 50.

The commitment to ANS 3.1 (12/79. The commitment to ANS 3.1 (12/79. Revisions 17 and 18. Appendix B.

draft) is limited to the requirements draft) is limited to the requirements '

that apply to the training and that apply to the training and  !

qualification of persons performing qualif: cation of persons performing indnpendent quality assurance independent quality assurance ,

functions. except for Lead Auditors. functions. except for lead Auditors.

Lead audito s are trained and Lead Auditors are trained and qualif ted to Regulatory Guide 1.146 qualifted to Regulatory Guide 1.146 (8/80)/ ANSI 45.2.23-1978. Other (8/80)/ ANSI 45.2.23-1978. Other personnel are trained and quallfled as peesonnel are trained and qualified as designated in plant Technical designated in plant Technical Speci fications. Speci ficailons.  ;

i Page 17

i m _ . - _, .._.___m m ._ m._ . --- _ . _ . _ . . . . ._. .. . _ . . .

CHANGE MATRIX 6/10/97 ,

0.lALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 102 55. Exception. (Page 58) $b. Exception. (Page 55) Corporate name change only. Content and commitments not affected.  ;~

QPD continues to comply with 10 CFR 50.

CPCo understands that this requirement Consumers Energy understands that this Appendix B.

applies both to CPCo employees from requirement applies both to Consuaers another site and to contract personnel Energy employees from another site and who are tenvorarily assigned to a to contract personnel who are ,

nuclear power plant either as temporarily assigned to a nuclear replacments for regular mployees or power plent either as replacements for ,

to augnent the staff during outages. regular employees or to augment the ,

CPCo employees. staff during outages. Constaners  !

Energy employees. 1 103 6a. Exception. (Page 58) 6a. Exception. . (Page 55) Cornorate name change only. Content and commitments not affected.

OPD continues to cmply with 10 CFR 50. '

CPCo certiftes its inspv tors. Consumers Energy certifies its Appendix B.

inspectors.

104 6c. Exception. (Page 59) 6c. Exception.. (Page 56) Corporate name change only. Content and cmmitments not affected.

QPD continues to comply with 10 CFR 50 i CPCo sometimes uses other. . Consumers Energy smetimes uses Appendix B.

Other.  ;

105 7c. Exception. (Page 60) 7c. Exception. (Page 57) Corporate name change only. Content and commitments not affected.

Paragraph 1 Paragraph 1 OPD continues to comply with 10 CFR 50.

Appendix B.

Based on compar*. son of these Based on cmparison of these statements to ANSI /ASME NQA-2 1983. statements to ANSI /ASME NQA-2 1983. .

CPCo believes the intent was to Consumers Energy believes the intent  !

establish. . was to establish.

106 Ba. Exception (Page 62) 8a. Exception. (Page 59) Corporate name change only. Content and commitments not affected.  !

OPD continues to comply with 10 CFR 50.

In tead of the five-level zone Instead of the five-level zone Appendix B.

designation system referenced in ANSI designation system referenced in ANSI .

N45.2.3. CPCo bases. N45.2.3. Consumers Energy bases.

• l 107 9b. Exception. (Page 63) 9b. Exception. (Page 59) Corporate nam? change only. Content and commitments not affected. i QPD continues to comply with 10 CFR 50.

All of the documents listed are not All of the documents listed are not Appendix B.

necessarily required at the plant site necessarily required at the plant site .

for installation and testing. CPCo for installation and testing. l assures that they are available to the Constsners Energy assures that they are  ;

site as necessary. available to the site as necessary.

l f

I k

Page 18

_.__m__ _ _ . _ _ _ . _ _ . _ . _ _ _ _ . _ __ _. _ _ _ . _ . _ . . _ _ _ _ . _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _

m m m._..__.___ . . . _ _ _ . _ . - . _ . _ _ _ _ _ _ . - - . _ _ _ _ . . . . . . . . _ _ ._

CHANGE MATRIX 6/10/97 5

00ALITY PROGRAM DESCRIPTION (CPC-2A). i REVISION 18 i

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 1

108 10a. Exception. (Page 63) 10a. Exceptions (Page 60) Corporate name change only. Content and commitments not affected. [

QPD continues to comply with 10 CCR 50. >

This standard (N45.2.5) was written This standard (N45.2.6) was written Appendix B. I for the construction phase of nuclear for the construction phase of nuclear power plants; as such. It presumes p wer plants: es such. It presumes

. significant activity in the areas of significant activity in the areas of ,

4 concrete and structural steel which do concrete and structural steel which do not generally occur at an operating not generally occur at an operating 3 plant. At Consumers Energy.

plant. At Consumers Power. persons.

persons.

109 10b. Exception. . (Page 64) 10b. Exception.. (Page 60) Corporate name change only. Content and commitments not affected.

GPD continues to comply with 10 CFR 50. ,

CPCo uses the requirements. . Consumers Energy uses the Appendix B. i requirements.

11n 12a. Excention. (Page 65) 12a. Exception. (Page 62) Corporate name change only. Content and commitments not af fected.

QPD continues to comply with 10 CFR 50. '

. CPCo endorses this position. Consumers Energy endorses this Appendix B.

j position.

111 12b. Exception. (Page 65) 12b. Exception.. (Page 62) Corporate name change only. Content and commitments not affected. j OPD continues to comply with 10 CFR 50. ,

... examination and test objectives. ... examination and test objectives. Appendix B.

• this is not construed by CPCo as this is not construed by Con m s requiring personnel. Energy as requiring personnel. .

?l2 13c. Exception. (Page 66) 13c. Exception. . (Page 63) Corporate name change only. Content and c mmitments not affected.

OPD continues to comply with 10 CFR 50.

All of the documents listed are not All of the documents listed are nct Appendix B.

necessariiy required d the plant site necessarily required A the plant site '

for installation and testing. CPCo for installation and testing.

assures that they are available tg the Consumers Energy assures that they are site as necessary. available to the site as necessary, i b

113 14c. Exception. (Page 68) 14c. Exception. (Page 65) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.  ;

CPCo adheres to ANSI /N45.2.9-1974. Constners Energy adheres to ANSI / Appendix B. ,

Subdivision 5.6. N45.2.9-1974 Subdivision 5.6.

- 114 15a. Exception. . (Page 68) 15a. Exception. (Page 65) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50. i CPCo follows the requirements of. Consumers Energy follows the Appendix B. f requirements of.. i

I j

i Page 19

- _ _ _ _ . _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ = _ - _ _ _ _ _ _ - _ - _ _ = _ - _ - _ _ _ . _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - - - . . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ .

CHANGE MATRIX 6/10/97 0'IALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 115 16c. Exception. (Page 69) 16c. Exception. (Page 66) Corporate name change only. Content and commitments not affected.

QPD continues to comply with 10 CFR 50.

In addition to the exemption; of in addition to the exemptions of Appendix B.

RG 1.144. CPCo considers that RG 1.144. Consumers Energy considers Authorized Inspection Agencies, that Authorized Inspection Agencies.

National Institute of Standards and National Institute of Standards and Technology or other State and federal Technology or other State and federal Agencies which may provide services to Agencies which may provide services to CPCo are not required to be audited. Consumers Energy are not required to be audited.

116 (Page 69) 16d. RG 1.144. Sec C.3.b(2), second Exception submitted to and appro/ed NRC approval letter stated "the paragraph (Page 3) by NRC. Reference April 18. 1997 preposed changes to CPC-2A are Did not appear in Rev 17. memo. Schaaf (NRC) to Bordine acceptable in that the quality Requirement (Consumers Energy). assurance program continues to meet the ,

a documented evaluation of the requirements of 10 CFR Part 50.

supplier should be performed annually. Appendix B.

Where applicable. this evaluation should take into account (1) revim of supplier-furnished documents sucis as certificates of conformance, non-confonnance notices. and corrective actions. (2) results of previous source verifications, audits and receiving inspections. (3) operating experience of identical or similar I products furnished by the same supplier and (4) results of audits from other sources (e.g. customer.

ASME or NRC Audits).

Exception /!nt erpret ation Constners Energy will review the information described in the second paragraph of section C.3.b(2) of Regulatory Guide 1.144. Revision 1.

1980. as it becomes available through its ongoing receipt inspection.

operating experience, and suppIler evaluation programs. in lieu of performing a specific evaluation on an annual basis. The results of the reviews are prom.ptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions. adjustments of supplier audit plans. and input to third party auditing entitles as warranted). In addition, results are revi Ned periodically to determine if. as a whole. they constitute a significant condition adverse to quality requiring additional action.

Page 20

CHANGE MATRIX 6/10/97 CUAL ITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 i

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 117 17a. Exception.. (Page 69) 17a. Exception. (Page 67) Corporate name change only. Content and commitments not affected. [

QPD continues to comply with 10 CFR 53.

For replacement parts and materials" For replacement parts and materials. Appendix B.  ;

CPCo follows ANSI N18.7. Consumers Energy follows ANSI N18.7. ,

118 17e. Exception. (Page 71) 17e. Exception. (Page 68) Corporate name change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50. ,

Consumers Power qualifies audit Consumers Energy qualifies audit Appendix B. i personnel according. personnel according.

119 179 Exception. (Page 71) 179 Exception. (Page 68) Corporate name change only. Content and commitments not affected.  !

QPD continues to comply with 10 CfR 50. ,

In exercising its ultimate In exercising its ultimate Appendix B.

responsibility for its quality responsibility for its quality program. CPCo establishes. program. Consumers Energy

• establishes.

120 18a. (Page 71) 18a. ANSI N45.2.23-1978. Section 2.3.4 Exception submitted to and approved NRC approval letter stated *the t (Page 69) by NRC. Reference April 18. 1997 proposed changes to CPC-2A are .

This is now 19a. Nee 18a. was not in memo. Schaaf (NRC) to Bordine acceptable in that the quality [

Revision 17. 9eouirement (Constaters Energy). assurance program continues to meet the  !

ihe prospective lead auditor shall requirements of 10 CFR Part 50 "

have participated in a minimum of five Appendix B. F (5) quality assurance audits within a ,

period of time not to exceed three (3) {

years prior to the date of qualification. one audit of which ,

shall be a nuclear quality assurance i audit within the year prior to his qualification.

Exception / Interpretation The prospective lead auditor shall .

demonstrate his ability to properly 1 implement the audit process defined by r this Standard and Consumers Energy program / procedure. to effectively lead an audit team, and to effectively organize and report results. including .

participation in at least one nuclear quality assurance audit within the i year preceding date of certification. l i

121 19a (Page 72) 20a. (Page 69) Editorial. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

Branch Technical Position. Renumbered. Appendix B.

122 204. (Page 72) 21a. (Page 69) Editorial. Content and commitments not affected.

OPD continues to comply with 10 CFR 50 RG 1.29 Sec C. Regulatory Position. Renumbered. Appendix B.

Page 21

a.

CHANGE MATRIX 6/10/97 ,

00ALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 l-g Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 123 20b. (Page 72) 21b. (Page 69) Editorial. Conter.t and commitments not affected.

OPD continues to comply with 10 CFR 50 l RG 1.29. General. Renumbered. Appendix B. }

124 21. (Page 72) 22. (Page 70) Editorial. Content and commitments not affected.

OPD continues to comply with 10 CFR 50.

. ANSl/ANS 3.1 - 1987 Renumbered. Appendix 8.

?

3 125 Appendix B (Page 73) Appendix B (Page 71) Position title changes only. Content and commitments not affected. I Bl. Function Bl Function OPD continues to comply with 10 CFR 50. -

Appendix B. [

The Plant Review Committee (PRC) shall The Plant Revi m Committee (PLC shall  !

function to advise the Plant General function to advise the Site Vice  !

Manager / Manager un all matters related President / Plant General Manager on all l

=

to nuclear safety. matters related to nuclear safety. t 126 B2. J1 POSIT 10N (Page 73) B2. COMPOSITION (Page 71) Position title change only. Content and commitments not affected.

Paragraph 1 Paragraph 1 OPD continues to comply with 10 CFR 50. <

Appendix 8.  ;

...The Chairman. Alternate Chairmen. ...The Chairman. Alternate Chairmen. y and members shall be designated in and members shall be designated in #

, adniinistrative procedures by the Plant administrative procedures by the Site  !

General Manager. Vice President.

t 127 B6.a. (Page 74) B6.a. (Page 71) Position title changes only. Contmt and commitments not affected. ,

QPD continues to comply with 10 CFR 50.  !

All procedures and programs specified All procedures and programs specified Appendix B. E by the Technical Specifications and by the Technical Specif. cations and r changes thereto. and any other changes thereto. and any other [

procedures or changes thereto as procedures or changes thereto as  ;

determined by the Plant General determined by the Site Vice j Manager / Manager to affect.. President / Plant General Manager to  ;

4 affect. ,

L 128 B6.e. (Page 74) B6.e. (Page /2$ Position title changes only. Content and commitments not affected. I OPD continues to comply with IP CFR 50. f

. Reports of special reviews and Reports of special revims and Appendix B. '

1 investigations as requested by the investigations as requested by the >

Plant Genc'al Manager / Manager or NPAD. Site Vice President / Plant General  !

Manager or NPAD.  ;

4 129 B6.k. (Page 74) B6.k. (Page 72) Position title change only. Content and commitments not affected. [

. OPD continues to comply with 10 CFR 50 '

... forwarding of these reports to the ... forwarding of these reports to the Appendix B. l Plant Manager and to the Manager. Plant General Manager and to the i Nuclear Performance Assessment Manager. Nuclear Perfcrsance Dapartment (Big Rock Point only). Assessment Department (Big Rock Point 3 only).

r i

i Page 22 (

_m._ .

1 CHANGF MATRIX 6/10/97-l OHALITY PROGRAM DESCRIPTION (CPC-2A)

REVISION 18 s

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion 130 C/.a. (Page 75) B7.a. (Page 72) Position title changes only. Content and commitments not affected. ,

OPD continues to comply with 10 CFR 50 .i Recommend in writing to the Plant Recommend in writing to the Site Vice Appendix B. +

i General Manager / Manager approval or President / Plant General Manager disapproval of items considered under approval or disapproval of items ,

B6.a. through J. above, considered under B6.a. through j. i above.  ;

131 B7.c. (Pace 75) B7.c. (Page 72) Position title changes only. Contmt and commitments not affected. i 1 OPD continues to comply with 10 CFR 50 i Provide written notification within 24 Provide written notification within 24 Appendix B.

, hours to the Vice President - Nuclear hours to the Senior Vice President - f Operations and to the Nuclear Nuclear. Fossil. and Hydro Operations l Performance Assessment Department of and to the Nuclear Performance ary disagreements between the PRC and Assessment Department of any the Plant General Manager / Manager; disagreements between the PRC and the i hwever. the Plant General Site Vice President / Plant General Manager / Manager shall have Manager; however: the Site Vice +

responsibility for the resolution of President / Plant General Manager shall .

have responsibility for the resolution such disagreements.

nf such disagreements. i 132 B7. (Paga 75) 87. (Page 72) Position title changes only. Content and commitments not affected.  ;

Paragraph 2 Paragraph 2 QPD continues to comply with 10 CFR 50.

Appendix 8. t The PRC Chairman may recommend to the The PRC Chairman may recommend to the ,

Plant General Manager / Manager approval Site Vice President / Plant General of those items. Manager approval of those itens.

133 B7. (Page 75) B7. (Page 73) Position title changes only. Content and commitments not affected.

Paragraph 3 Paragraph 3 QPD continues to comply with 10 CFR 50 .

Appendix 8.  !

The item shall be reviewed at a PRC The item shall be reviewed at a PRC  :

? meeting in the event that: meeting in the event that:  ;

9 (1) Comments are not resolved: or (2) (1) Comments are not resolved; or t the Plant General Manager /Managar (2) the Site Vice President / Plant l overrides the. General Manager overrides the. l

.134 B9.2.a. (Page 76) 89.2.a. (Page 73) Position title change only. Content and commitments not affected.  !

QPD continues to comply with 10 CFR 50. -

Procedures. programs and changes Procedures. programs and changes Appendix B. l thereto identified in the Technical thereto identified in the Technical

• Specifications and any additional Specifications and any additional 2

procedures and changes thereto procedures and changes thereto  !

identified by the Plant General identified by tne Site Vice President

[

Manager / Manager as significant to as significant to nuclear safety.  ;

nuclear safety.

135 Appendix C (Page 77) Appendix C (Page 74) Position title change only. No Content and commitments not.affected. .

C2. COMPOSITION C2. COMPOSITION change in reporting relationship. OPD continues to comply with 10 CFR 50.

Appendix B.

The ISRG shall include the Manager. The ISRG shall include the Manager, i NPAD. who reports to the Vice NPAD. who reports to the Senior Vice ,

President NOD. and. President - NFHD. and.

Page 23 s i

i CHANGE MATRIX 6/10/97 1

QUALITY PROGRAM DESCRIPTION (CPC-2A) f i

- REVISION 18 t

Item Revision 17 Revision 18 Reason for Change Basis for Conclusion ~

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136 C5. AUTHORITY (Page 78) C5. AUTHORITY (Page 75) Position title change only. Content and commitments not affected.

OPD continues to comply with 10 CFR 50,. -l The 15RG shall report to and W ise The ISRG shall report to and advise Appendir B. t the Vice-President. NOD. of the Senior Vice-President. NRID. of  ;

significant findings associated with significant findings associated with i those areas of responsibility those areas of responsibility i specified in C4 above and Appendix D. specified in C4. above and Appendix D. l Audit frequencies. Audit frequencies.

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137 C6.a. (Page 78) C6.a. (Page 76) Position title change only. Content and commitments not affected.. 1 OPD continues to comply with 10 CFR 50.  !

The iesults of revi m s performed The results of revi ss performed Appendix B. i pursuant to C4 above shall be reported pursuant to C4. above shall be l to the Vice-President. NOD. at least renorted to the Senior Vice-President. j monthly. NFfiD.atleastmonthly.  ;

138 C6.b. (Page 79) C6.b. (Page 76) Corporate name change only. Content and commitments not affected. f; OPD continues to comply with 10 CFR 50.

A report assessing each plant's A report assessing each plant's Appendix B. t overall nuclear safety performance overall nuclear safety performance shall be provided to senior Consumers shall be provided to senior Constners .;

Pmer Company management annually. Energy management annually.

239 Appendix D (Page 79) Appendix 0 (Page 77) Position title change only. Content and commitments not affected. j DI.f. DI.f. OPD continues to comply with 10 CFR 50. p  ;

Appendix B.

Any other area of plant operation Any other area of plant operation  ;

considered appropriate by NPAD or the considered appropriate by NFAD or the

Vice President - Nuclear Operations. Senior Vice President - NFHD.

i - t 140 Appendix E (Page 81) Appendix E (Page 79) Provide reference to Appendix B as Content and commitments not affected.  !

E 3.1. E3.1. source for PRC activities. OPD continues to comply with 10 CFR 50.

Records of meetings of the PRC and Riords of meetings of the PRC and revi ms perfonned by NPAD according to reviews performed by NPAD according to Appendix C. Appendix B and C.

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