L-2019-134, Units 1 and 2 - Quality Assurance Topical Report, Revision 22, Annual Submittal

Units 1 and 2 - Quality Assurance Topical Report, Revision 22, Annual Submittal

ML19197A104
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold
Issue date:	07/12/2019
From:	Parks W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-134
Download: ML19197A104 (93)

Text

~

-FPL.

JUL 1 2 2019 ATTN: Document c;onttolDesk U.S. N{iclear Regulatory Commission Washington, DC 20555-0001.

Re:

Florida Power & Light Compahy St. Lucie Units 1 and 2, Docket Nos. 50~335 and 50-389

• Fl~rida Power & Light Company Turkey Point Units 3 arid 4, Docket Nos. 50-250 and 50-251 N ext:Era Energy Seabrook, LLC.

. Seabrook Station, Docket No: SOA43 N e:x:tEra Energy Duane Arnold, LLC Duane Arn?ld Energy Center, Docket No. 50-331 NextEra Energy Point Beach, LLC Poi.ht Beach Units 1 and 2, Docket Nos. 50-266 arid 50-301 N extEra Energy Quality Assurance Topical Report (FPL-1) Revision 22 Annual Submittal L-2019-134 10 CFt 50.54(a)(3)

Reference:

Le.tter L-2017-122 from.Brian Booth, N extEra Energy, to USNRC, Submittal of Quality Ass11rance Topical Report (QATR FPL-1) Revision 21,.dated April 21, 2017..

Pursuant to 10 CPR 50.54(a)(3), ittached is the anmial update of the Florida Power & Light Cobipany (FPL);

NextEra Energy Seabrook, LLC; NextEra En~rgy Duane Arnoid, LLC; and NextEra Energy Point Beach, LLC Quality Assurance Topical Rep6rt(QATR) (FPL;l). This letter satisfies the10 CFR 5Q.54(a)(3)

. requirement to provide the NRC with an.update of changes to the quality assurance program description that *

. did not reduce commitments ili. the progia~ description and, therefore, did riot require NRC approval prior to implemei;'tation.

Revision 22 is the current version of FPL-1 in use and became effective onJune 5, 2019. A summary of the*

changes for Revisions 22 of FPL-1 is provided in Enclosure 1 of this letter. Enclosure 2 of this letter prqvides a copy* of Revision 22 of FPL-i for information purposes only.*

• Should there be any questions or need for additional information, please cciritact me.at (561) 803~ 7988.

Sincerely, Jw_.?-4,-..

• William L. Pa:tks*

Director, Nuclear Regulatory Affairs

. Florida Power & Light Florida: Power & Light Company*

700 Universe Boulevard, Juno Beach, FL 33408 QoDf 1

-;o l D jvtR.

Enclosures:

1. NextEra Energy QATR (FPL-1) Change Summary Q"une 2019)

2. NextEra Energy QATR (FPL-1) Current Version (Revision 22) cc:

Regional Administrator, Region I Regional Administrator, Region II Regional Administrator, Region Ill USNRC Project Manager, Turkey Point and St. Lucie Senior Resident Inspector, USNRC, Turkey Point Senior Resident Inspector, USNRC, St. Lucie USNRC Project Manager, Seabrook Station Senior Resident Inspector, USNRC, Seabrook Station USNRC Project Manager, Duane Arnold Senior Resident Inspector, USNRC, Duane Arnold USNRC Project Manager, Point Beach Senior Resident Inspector, Point Beach L-2019-134 10 CFR 50.54(a)(3)

Page 2 of2

ENCLOSURE 1 NextEra Energy QATR (FPL-1)

Change Summary (3 pages)

L-2019-134 10 CFR 50.54(a)(3)

Page 1 of3

L-2019-134 10 CFR 50.54(a)(3)

Page 2 of3 NextEra Energy Quality Assurance Topical Report Change Summary June 2019 Revision 22 QR052: Section A.2 Organization & Appendix E:

Site Organization Chart.

Change the Department Name from Information Management to Information Technology.

QR053: This revision has been prepared to update the QATR to reflect the current organizational structure and update the table for the independent assessments to reflect that the Maintenance and Work Management audits are now performed as one audit. versus two (change made to NA-AA-202-1000, Audit Topic

,1 Selection and Scheduling, Rev 11)

QR054: Change was to incorporate change to the reporting relationship for Emergency Preparedness and Licensing and also for Performance Improvement and Training.

This change was evaluated in accordance with 10 CsR 50.54(a), Conditions of License requirements.

The change is an Organizational revision and persons and organizations performing quality functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

Organizational changes:

These changes were evaluated in accordance with 1 O CFR 50.54(a) requirements. The changes are an Organizational revision and persons and organizations performing quality functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

Change in audits:

The table was changed to reflect that the Maintenance and Work Management audits are now performed as one audit versus two. As both areas are still audited there is no reduction in commitment.

These changes included in QR054 were incorporated in QR053 and therefore QR054 is cancelled.

Revision 22 QR056: Update the QATR (Section 8.4) to reflect the NRC provisional acceptance of ISO/IEC 17025 (2017 edition) applicable during the transition period set to expire on November 30, 2020 to allow accredited laboratories to transition from the current 2005 edition as provided by ISO.

L-2019-134 10 CFR 50.54(a)(3)

Page 3 of3 The NRC performed an independent review of ISO/IEC 17025:2017 and a gap analysis concluding that ISO 17025:2017 did not decrease or remove any of the technical and quality requirements that provided the basis for the NRC's initial recognition of the ILAC accreditation process. As a result, the NRC concluded that licensees and suppliers of basic components may procure calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017 in lieu of performing a survey as part of the commercial-grade dedication process in accordance with the NRC's SE of NEI 14-05A for the transition period provided by ISO.

Based on the above information, the change described does not result in a reduction of any QA Program commitment as a result of the following: The use of a quality assurance alternative or exception approved by an NRC safety evaluation provided that the bases of the NRC approval are applicable to NextEra Energy Nuclear Plants. (paragraph ii ).

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ENCLOSURE 2 NextEra Energy QATR (FPL-1)

Revision 22 (88 pages)

L-2019-134 10 CFR 50.54(a)(3)

Page 1 of88

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_Florida Power and Lig:ht Company,*.*

.** NextEra'* Energy.Seabrook,**L.LC~:.*.. **

• N.extEra' l=nergy D~ane Arrtold, *LLC,.

• • and*

'NextEraTM Energy Pqint.Beacn*, LLC ': '

• *auality Assurance Topical Report I

Revision 22 1.of 84

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• . May 28, 20'.9.

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• NextEra *Enet,gy * :

Quality Assurance Topical R~pt>rt (FPL-1)

, ;PQLJCY $TATl;IVIENT *

• Florida Power, and Light. :cornpany, NexfEra, Energy Seabrook, LLC, 'NextEra E:nergy *

Duane Arnold, LLC; and NextEr~ Energy:: PQlnt : !3ea¢h,.LLQ. (h~reafter. referred* :~o collectively as Next~ra Energy) shall maintain anq operate nuclear plarifo In a manner that Wiil ensure t~e health and safety* of the public and* workers: Facilities shail be. * *

• operated in compliance Witt) 1h1;1 requirementl;l. of.the Ooqe

• of Fe<iera! ReguJations, thf3.

applicc:1ble Nuclear Regylafory Commission (NRC) Facility * :Operating. Licenses; arid

. ~pplicable laws and regulations otthe state and loca~*govemments; Toe Quality A~surance Program (QAP) :dei;cribed herein arjd associated implementing.

• documents provide for control pf activities that affect the quality of safety. related nucl~ar

. plant structures, sy~terns, ~n<:I, components.

• The QAP

• is ~.lso* applied to <;e.rtaJn qtiality

• relat!3d

• equip merit and. *a.ctivities that. are not safety r¢lafed, but support safe plant.

operations, or; Where qthef reguJatory or industry guidance estabiishes progtanJ :

• reg iJ i remen.ts;

• * * : :, The :Quality Assurance Topical Re.pprt (OAT~} Js the top:-levei pplicy documehf that. *

• esta!)lish~ the. 111annet j~ wtii9h. quality is to be achieved and. pre$ents our* overall :

• pliilo~ophy r~garding achievement and ~ssurance ~f quality.

• Implementing docu,nehts

. assign *more detailed responsibilities and requirements and.. define the

• ofgan,zational interfaces invol"ed in :conducting ac::~vities witti.in :the scope of tl:le QATR, Cc;m1piianc::e With. the QA TR *imd implementing documents is mandatory for personnel,directly or indirectly associated'With *1mplernentation oftlie OAF\\. * *

• Responi:;ibHity for

• cievelopil'lg, implem~nting,. aild verifying *.execl.rtioil. of th_e Quality :

• Assurance Ptc;,gram is. delegated *to the Chief: Nuclear,0ffief3t and a~thodty for *

developing and erifying

• exec1.Jtipn of th~ prpgr~m to the Pireptor Nt1qlea.r' Assun~ric~ I *..

and Asses$"men

• Signe_d: *

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• James'L., Robb NextEta'Energy Chairman and Chief Executive Officer *. *

. :. Revision. 22

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Approved By: *

• R~vision 22 NextEra, Energy Q1,1allty'Assurande Top.ical Report(FPL-1)..

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• Director Nllclear Assurance & Assessment. *

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Vice President ~nd Chief Nuqlear Officer*

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NextEra Energy

• Quality Assurance Topical Report (FPL-1)

TABLE OF CONTENTS POLICY s.rATEMENT...*.......................,.:....,...............*..........:..... :........,... ;;.,......... :.... :... 2.

TABLE OF CONTENTS..... :.*.*.~............. :.. ::..........,.,.,............................... :.:............... :......... ~.4.*

INTRODUCTION........ ~...... *.............. :.:.. :............ :.:.:.......... ::.... :.............-.-............... ::........... s*

A: MANAGEMENT.;,:.;~.......................... :,,.............. ;,:..,.................:..........-:,.............. :,...,... 6 A:1 Mefhodology*... ~............................................ ~................ *.:.......... :.. :......,............. 6 A.2*

• Organization.... :................*............... :.:.. :......... :................ :.............. :,,:.:.......... :.8 *.

A.3 Resp.onsibility..... *.....:.........,..... :.:.......................,...... *..........,...... :............... :......... 15

• A.4 Aufhority..,:.:............. *.............................. ::.:.::...............*............ :.. :.......... :.:.... 17 A.5 Personnel Training and Qualification......... ::............. *.............................. :.. :18...

A.6. Corrective Action........................................... :............... :................... :.......... 20..

• A.7 Regulatory.commitments...........,................,................ :.............,..............,.. 21 B.. PERFORMANCENERIFICATION.... ;... ;.......... ;.. :,............................,.,..,......... ;... :.. 29 B.1 Methodol.ogy.......... :.:................. :..........,.,..............,.,........ :.....................,............. :29..

B.2*

Design Control................................ :.:..,.......................... *............... ;,:.:,......... 29.

B.3 Design Verification........................................................ :............................... 30

• .B.4 Pr*ocurement Control.................. :.......... :................................... :.................. 30 B.5 Procurement Verification....... :...... :....................................... :.............,......... 35 B.6:. Identification and Control of Items.... :........... :.*.. :......................... :.:.. :.......... 35.:

. B.7 Handling, Storage and Shipping................,................. :........................,...,.. 36

• • .s.a TestControl... :......................... :... :.......... ::.............................. :... :.,........ :.... :.. 39 B.9 Measuring and TesfEquipment Control.............. :............... '.........,.... :......... 39.

B.10 Inspection, Test and Operating Status.......................................... :..........40.

B, 11 Special Process Control......................,................................................,.,.".41

• • s.12

• inspection "*******....-.............. :..... ;............ ;............................... ;;.......... :,.. ::.41 B.13

• Corrective Action......................... :.:.. :......... :................................... ::.........42 -

B.14

• Document Control........... :::.......... :.. :.:.......... ;.... ;........................ ::.:...........42

. 8;15 Records ::.::;.~.........*....*.......... :............... ::.::,;.......................... :.:.::.......... :.:.;:.45

• • s;16

. Plant Maintenance................. :.. :::......... ::.:.::.............. :*:*************:.:.......... :.. :'..46 B.17

• Computer Software Control.......... :.:.......... :...............*................ :..............46.

• C. ASSESSMENT::......... *.~... *;..........':.. :~:.......... :.. ;:;.......... ;.*.;................ *.*......... :.. ;........... 47 C.1 Methodology.,:.........................,.... :......... :,...,................. :........... :::..........,...,:047

. c:2 Self-Assessment..................... :................ :... :............................. :........... :......48 C.3.

Independent Assessment...............................,.. *************:***************:,:............ 48:

APPENDICES..................... ;..:.......... :.. ;:.............. :.:.......... :.::................ :.......... :... :;........ 51.

• • Appendix A:

On-Site Review Group................ :.:;........... :............. :.:.:;.......... :,:.... 51

• Appendix B:

Procedures................... :.........,................,..... *............... :.:................ 54 Appendix C:. *Definitions........................... :.:..........,*............................... :.:.:.......... 58 *.

Appendix 0: Revision Summaries............. :.::.......................,.................... :.. :........ 62.

• Appendix E:. Organization Charts.... _............. ::.:.:*:*****************************:.......... :::.:.:83 The following pages have been affected in Revisi_on 22:

2, 3, 4, 9, 10, 11, 12, 13, 14, 31, 32,.33, 48; 50, 78, 79 Revision 22 4 of84

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. NextEra Energy

• . Quality P.ssurance Topical Report (FPL-1)

• INTRODUCTION The Quality Assurance Topical Report (QATR) describes the methods and establishes quality*

• .

• assurance program and administrative control requirements which comply witli the criteria of 10* *.

. CFR 50 Appendix B, and meets the requirements of Regulatory Guides and Industry Standards

. referenced in Section A 7 of this report.

• The Topital Quality Requirements and attached Policy Statement, together with Quality Instructions document the Program and Policy with. regard to*

Quality Assurance. This Program.shall apply to Florida Power & Light's St. Lucie Nuclear Plant, Turkey Point Nuclear Plant,. and NextEra. Energy's* Seabrook Station, Duane Arnold Energy Center, and Point Beach NuclearPlant and shall be implemented ateach plant site throughout the ope:rating llfe of these mJclear plants.

• The requirements of the Quality Assurance Program shall

• apply to nuclear safety related

• structures, systems, and. components as identified in the Safety Analysis Report or Q-List for..

each rn.:iclear unit. Additionally, the requirements of the Quality Assurance Prqgram shall apply *..

• to all Ne~Era Energy, contractor, or consultant organizations performing. activities affecting the quality of safety related structures, systems, and components of the nuclear power plants.

Portions of the Quality Assurance. Program requirements.are also applicable to quality related

.. *

• items and services and* non-safety related structures and components subject to

• an Aging

• Management Program (AMP) for license renewal. Those portions applicable to specific quality related items or services and non=safety related structures arid components subject to an Aging Management Program (AMP) for license renewal shall be delineated in appropriate instructions.

. This QA TR is organized and formatted to respond to NRG. Standard Review. Plan (NUREG-0800) Section-17.3 (Revision* 0 "':" August 1990). This approach was chosen because it best

• represents the commitment to the philosophy that. each individual, properly trained and..

motivated, achieves the highest quality of performance-of which they are capable. In addition; this emphasis is used on

• individual performance to reinforce the

• importance of self-assessments : (by ttie group responsible for the activity) and independent assessments. (by groups not responsible for the activity) to achieving excellence.

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NextEra Energy

• Quality Assurance Topical Report (F.PL.. 1)

A..

MANAGEMENT A.1 * * * *

• Methodology The Quality Assurance Topical Report (QATR) is the top-leveLpolicy documentthat establishes

. quality policy and. assigns. major functional responsibilities for plants

• operated

• by. NextEta.

Energy:. The following requiremeri~s apply to all organizations and*positi()ns.that m,mage and.*

• perform

• activities: within

• NextEra* Enerny's

• scope. *

• The organization

• is committed to in,plemeriting these: requirements. Personnel engaged in supporting _nuclear generation.shall coin ply with the requirements ofthe Quality Assurance Program (QAP) described in this QA TR.

Contractors, or: other supporting organizations; are required to comply with the QAP established..

by this. QATR.: or with.their own programs. having appr:oprlate scope and controls in accordance*.

With Section A.2. All.facilities shall be operated iri compliance with the appiicable Code( of Federal. Reglllations, NRC Operating Ucenses, and the_ ~pplicable laws and. regulations of thE:l.

state* aricl local governments Jn which t.he facility is located...

• The QAP comprises those planned and

• systematic actions

• necessary to provide adequate

• confidence that structures., systems,* and. components will perform their: *intended

• safety

• functions. The OAP consists of the NRC approved* regulatory document' that descdbes the

• .quality assurance program elements (the QATR).along with the associated qua_lity.instructions.

• Quality instructions establish responsibilities and authority for* carrying out important functions;

• establish' common practices for certain activi~ies such thafthe activity is controlled and carried out in.: a rrJariner that

• meets QAP requirements; and establish detailed: implementation requirements and methods... In. addition; to provide a clear understanding of the oper,;1ting philosophy, rules of practice : are established pertaining to *personnel. condud. and control, including' consideration of job related factors which can influence. the effectiveness of operating

. and maintenance personn*e,, including such factors as number of hours at duty *station, availability on~call of professional and supervisory pe_rsonnel, methods of conducrting'operations;

. and preparing and retaining plant documents.. Such rules are contained within' appropriate

. implementing documents. *. '

The' QAP applies to :activities affecting the performance of safety re.lated structures, systems and components, including, but not limited to, design; procurement; fabrication;' installation; modification; maintenance; :repair; refueling; *operation; training; inspection; and tests. A list, or****

• other means of identification, of $afety related Systems, Structures, and.Components* (SSC) under the control of the QAP is established and maintained for each operating'. plant. :The

. technical.aspects of the iterns are considered when determining program *applicability, including,...

as applicable, the item's design safety function, results: of probabilistic safety analysis, the ASI\\/IE Code arid the other references cited iri Sec.tion A.7.3. of this QATR. The QAP is c;1l.so

applied to certain activities where regulations other than 10CFR50 establish QA program

.., requirements for activities within. their scope. Thus, the QA TR is 13pplied to. the important. to.

' safety" activities of radioactive waste shipping and independent sperit fuel storage, as defined in * '

... those NRC regulations, as aliowed by 10CFR71.101.f and. 1 OCfR72.140:d..... *

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.Quality Assurance Topical Report (FPL-1)

• A.1.

. Methodology (Continued).

• It is NextEra Energy's policy to assure a high* degree of availability and reliability of :its: nuclear*.

plants while ensuring the health arid safety of the public and its workers. To this end, selected elements of the Quality Assurance Program are also applied to certain.quality related equipment

. and activities that are hot safety related, but l5Upport safe and reliable, plant operations, or.where other. regulatory o.r industry guidan_ce establishes program requirements.. This quality related classification is applied to selected equipment, components, structures and services designed to

-support. and/or protect the safety function *of safety related equipment.*. Additionally, selected elements of the Quality Assurance Program are applied to emergency preparedness, security, radiation protection, and*fire protection activities. Implementing documents establish program:.

element appUcabiHty.

• Activities-affecting quality are prescribed by and performed in acco.rd_ance with documents {such..

. :.. as instructions, procedures or drawings) of a type appropriate tothe circumsti:mces ana which, where applicable, include quantitative or qualitative acceptance criteria. Such. documents are p*repared

• am:! controlled according to* Section S:14.

In

• addition,

• means are provided for

....

• dissemination to plant staff of instructions of both general and continuing applicability (e.g.,

• *. dealing with job turnover and relief, designation of confines of the control room, limitations ori. *

• access to certain areas), as well as those of short~term applicability. (e.g., dealing with short-

. term operating conditions, publications, personnet' actions).

• Provision*s are included for review,

• updating,* and cancellation of such instructions.*.*

In. establishing, implementing :a'nd maintaining the QATR,

• Nextl;:ra Energy *commits. to Compliance with ASME.NQA-1, 1994, Basic Requirement 2, QATR revisions are reviewed by senior management and approved by the Director Nuclear Assurance & Assessment -and the.

Chief Nuclear Officer. Changes to this QATRwill be governed by and madefn compliance with 10CFR50.54(a).

In establishing proceduralcontrols; l'.,lextEra Energy commits tc;>:compliance*with NQA-1, 1994,

• Basic Requirement 5. In addition, *as stated in Position C:1 of Regulatory Guide 1.33, Revision 2, NextEra Energy commits to use Appendix A of Regulatory Guide 1.33 as guidance for establishing the types of procedures that are necessary to, control ar;id support plant operation.

Requirements specific to *procedures are also provided in Appendix 13 of this QATR.

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• Quality J.\\ssurance Topical Report (FPL-1)

A.2

• Organization This section describes the organizational structure, functional responsibilities;. levels of authority * * * * *

- and. interfaces for establishing, executing, and verifying QAP implementation.*

The organizational structure includes corporate functions and onsite.functions at each. plant.

. Appendix E contains *organization charts depicting the organizational. relationships for key _

management and functibhal groups both corporate and on-site.

Implementing documents_* *

• *

• assign

• more. sp*ecific responsibilities and. duties, and define the organizational interfaces involved in. conducting activities and duties within the :Scope of this QATR.

The Chief Nuclear Officer has overall responsibility for implementation of the quality program.

The, authority to accomplish quality assurance functions is delegated to the staff as necessary to fulfill the identified responsibilities.

Personnel executing peiiO:~mance activities. 1;md those_* performing verification activities are functionally independent to the degree c:::ommensurate with the activitY'.s relative importance to

• safety. The inethod _and exterit of verification is cominensuratewith importance of the activity to

• plarit safety and reliability. The organization executing independent assessment. activities

. *.. maintains independence from the organization(s) performing the activity being assessed.*.

. Management positions. are established both offsite. and onsite. for carrying out the. independent assessment functions. Individuals filling these positions:

Have sufficient authority and organizational freedom to implement their assigned responsibilities, including. authority to obtain. access to. records and* personnel as needed to perform assessments. -

Report. to a sufficiently high management level to ensure that cost and schedule considerations do not unduly influence decision making:

• *

• Have effective lines of ccm1munication with

• persons

• in

• other senior ma_nagement *

. positions.

• . Have no unrelated duties or responsibilities that would preclude full attention to assigned responsibilities....

Responsible individuals or organizations may delegc1te anY: or all of their responsibility. When

• work_ is delegated to personnel or orgc;inizations outside of NextEra Energy the responsibility for

• *. the program effectiveness arid the Work is retained by NextEra Energy, and the delegation shall

• be. identified and described such.that:

• . The organizational elements responsible for the work are identified.

Management controls and lines of communication are e_stablished.

• ..

• Responsibility for an appropriate QAP and extent of management oversight is *.

established.

.. *. Pe;rformance *of *delegated work.is formaUy evaluated by NextEra Energy.'

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• NextEra E*nergy Quality Assurance Topical Report (FPL-1)

A.2.

• Organization (Continued) * * *.

In establishing its organizational structure, NextEra Energy commits to compliance with NQA-1 *,

• 1994, Basic Requirement 1 and Supplement 1S-1. Managementgives careful consideration to

. the timing, extent and effects of organizational structure changes.

A.2.1. *

• Corporate Organization

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The follov,(ing positions.have the described corporate functional. responsibilities. Some titles and reporting relationships may vary between corporate and some sites, but in all cases there is a designated position to carry out the defined responsibilities.

A.2.1.1

• .NextEra En.ergy Chairman aii~ Chief Executive Officer (CEO)

This position is re1sponsible for overall corpor13te policy and proviqE:'ls executive direction and guidance for.the corporation as well as promulgates*corporate policy through the Company's senior management. staff. Responsibility for implementing the Quality Assurance Program is delegated to the.Chief Nuclear Officer and authority for developing *and verifying execution of the program is delegated-to the Director Nuclear Assurance and Assessment.*

A.2.1.2

• . President Nuclear Dlvision This position reports to the Chairrnan and CEO and has overall responsibility for the.Nuclear Division's activities including overall plant *nuclear safety. The President is designated as the Company Officer responsible for ensuring that defects and rion:..compliarices are reported to the NRC_ as. required* by 1 OCFR21.

A.2.1.3 Chief Nuclear Officer (CNO).

This position _reports to the President Nuclear Divisipn

• and h~s overall. responsibility for the implementation of* the. QAP arid for.-the Nuclear Division's* activities includin*g corporate

, responsibility for overall plant nucl~ar safety~*

This responsibjlity includes setting and implementing policies, objectives, and priorities to ensure activities are performed in accordance with. OAP and other corpOrate requirements..

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. Quality Assurance Topical Report (FPL-1)

A.2.

Organization (Continued)

A.2.1.3:a Vice President Corporate Support This posiUon reports to the CNO and is responsible for the following:

Corporate Functional Area Managers (CFAMs)..

Performance Improvement

• Security :

Fleet Training *.

Licensing

• Interface with Nucleadnformation Technology Continuo"us Improvement Program Fleet Projects* (including capital projects, projett control, projecfimplementation, and ISFSI).

• Development and implementation of the programs associated with regulatory driven projects across the fleet..

Outages Design Engineering.

• *: Fleet Engineering Support A.2.1.3.b. Sr. Director NuclearFleet Finance This position reports to the CNO and is responsible for the following:*

• Nuclear fleet_ bu_dgets _

Spending authorization *.. )

Key performance indicators:.. -*

A.2.1.3.c.. Generai fl/lanager Fleet Engineering The General Manager Fleet Engineering reports.to the Vice President Corporate Support and is.

responsible for:

Fleet Engineering Probabilistic Safety Analys_is Nuclear Fuel~ *

- **.Engineering'. Programs

• Equipment Reliability

• Engineering Chiefs Organization.

. The Engineering Site. Directors. report to thi_s position;.

• . A.2.1.3;ci. Sr. Director Fleet Projects and Construction.

• The Sr. Director Fleet,Projects and Construction reports to. tt:ie Vice President of Corporate

• Support and is responsible for the Engineering Construction Alliance interface including project..

. controls implementation and engineering.

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.Quality Assurance Topical Report (FPL,.1)

A.2 Organization (Continµe~)

A.2.1.3.e. Director Fleetpesign Engineering This position reports to the General Manager Fleet Engineering* and is responsible for:

Design Engineering.

Engineering Document Control Modifications and their Implementation

• . Plant Desi.gn Configuration Control

.The Engineering Site Design Managers report to this position.

• Ai 1.3.f. Director Nuclear Assurance & Assessment This position reports to and. bas direct access to the CNO for res.olution of any areas in question. This position is responsible for the following:

Activities that in*clude establishing, maintaining, and interpreting quality assurance practices and policies,(including this QA TR)

• . Managing* independent assessment * (Quality Assurance:. {QA}) and* establishing quality control practices and policies for quality verification activities

<I!

Performance: of receipt inspection, through the Nuclear Assurance Manager(s), to*

verify that.purchased items comply with. procurement documents at stations where receipt inspection is performed by the Nuclear Assurance organization.

Facilitating a.ctions deemed necessary to. prevent unsafe plant conditions or a significant violation of the OAP; including Stop Work authority at the sites and corporate offices

• . Periodically apprising the CNO of the status of the quality. assurance program at NextEra Energy facilities and. immediately appri~ing

• seni()r. management of significant problems affecting quality; and verifying implementation of solutions for. *

. significant conditions

• adverse. to quality identified by Nuclear Assurance and Assessment.

Establishing the-requirements for assessor arid inspector 'certification; and providing for supplier evaluation

• . Conduct. of supplier assessments or surveys; and verification that supplier quality

. assurance programs comply with NextEra Energyrequirements

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• A:2 Organization (Continue~)

. A.2.1'.3;g.. Vice_President Integrated Supply Chain (ISC).

. This position reports to the CEO through the Executive Vice President Engineering, Construction and ISC and is responsible through ISC directors for the. following:

Proc_u~~ment engineering.

• 9oordiriating contract activities. *

• * *Negotiating, generating, and issuing procurement documents for required items and services supporting. the operation,

• licensing, maintenance, modification,

• and.

• inspection at the nuclear plants,* arid for materials and equipment to support the.

• Nuclear Division staff * *

• . **Review of procurement documents to assure that technical and quality requirements are incorporated into th13 procurement documents thatitauthorizes.

• *. Performance *of* receipt inspection to verify

• that purchased items comply with

. procurement. document requirements (except at stations where receipt inspection is

• • performed by the Nuclear Assurance Organizatic;m)

Controiling materials received at ei;!Ch nuclear plant sitl{in accordance wit~ company policy ahd procedures, *

, A2;1.3.h. Senior Director IT Business. Solutions

.. This position reports to the ' N Executive Vice. President Finance and. CFO. through the Vice.

• President& GIO and is responsible for the following:

• Nuc.lear information technology such as *computer-related har9~are and software..

acquisition, deployment, maintenance, control and replacement; tele.communications

• Information/ cyber security; and applicable*training

• I

• Interface with the Vice' President Corporate Support-for cyber security*

• I Management of information technology

• *

• Nuclear cyber security.

• *. Computer --related hardware/software acquisition *

• .. The fu_nctions are supported via staff_ at both corporate and site* 1eve.ls.

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A.2 A.2.2 Organization (Continued)

Site;Organization The following site

• management positions des*cribe the typical. site QAp functional responsibilities, which may be delegated to others* as established in this document. :The on-site operating organization includes one or more individuals knowledgeable in the following fields: *

nuclear power plant. operatiori;. nuclear power plant mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry;.radiation protection; and quality

, assurance.

• Some functions,* such as operating experience, document control, or records management, :may be aiig'ned under different groups at* different sites. Site procedures provide

detailed organizational descriptions.

A.2.2.1,a Site Directors I Plant G.eneral Managers (PGMs)

. These posi.tions report to the CNO ariq are respo.nsible for the safe operation of the nucl~ar

• plant. The Site Directors / PGMs have. control of the onsite resources necessary for the. safe

• operation and ma)ntenance.regardless of organizational reporting.

In this position, the Site Directors I PGMs assure the.safe, reliable, and.efficient operation of the plant within :the cotistraints of. applicable regulatory requirements, Operating license, and the

• QAP.. : :Functional areas of responsibility also include chemistry activities, envimnmental services, fuel ftandling (receipt, movement, and storage), radiation protection, operations and

-support, rn1:1intenancE;J. and work control, and related procedures and. programs.* -The Onsite Review Group serves the Site Directors I PGMs in a technical capacity and provides review of plant safety and performance (see Appendix A).

A.2.2.1.b * * -Licensing Manager

• This _ position reports to the Site. Directors / PG Ms and is r~sponsible. for site regulatory

• . interfaces and functionally interfa~s with the fleet Licensing Director.

. A2,2.1.c, Training Site Manager This position reports to the Site Directors I PGMs and functionally interfaces with t.he Training Fleet Director (offsite) and is responsible for training.

The Site Training Manager provides

_ direction,, control, and overall supervision oftraining personnel and training fe>r all site personnel f!S required. : Functional. areas of *responsibility include training support *services; technical

training, and operations traini~g.,'

, This position is also responsible for NUREG-0737, Action Plan Item LB.1.2.technical. review...

functions that St-Lucie Unit 2 and Seabrook Station are committed to regarding the,oversight,.

implementation, and coprdination of internal and external operating experience:

A.221,d Emergency Preparedness Manager I.

I This position. reports.to the Licensing Manager and functionally interfaces with. the. Manager_ of I *

• Emergency. Preparedness ( offsite) and. is. responsible for maintaining and implementing the

' emergency plan for the station.

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• A.2.

• Organizfltion (Continued)

• The following positions report directly.offsite, butfunctionaHy report to a site position:

• A.2.2.2.a. Project S_ite Manager*:

This position reports to the

• Sr. Director Projects and Construction with direct. interface with the.

• Site.Directors./ PGMs.and is responsible fofinstallirm plant modifications as a result of design * *

'changes arid'implementing othe(major projects.

A.2.2.2:b Nuclear Assurance Maria9er Thi~ positior;i reports to the Director. Nuclear Assurance & Assessment (offsite) and is responsible for site quality_ activities..

• Significant safety. or quality. issues requiring escalated

. action* are directed through this position to senior management,. as necesi3ary.

Functional *.

• responsibilities include conducting independent.assessment~

• of line and support activities; monitoring and assessing day-to:-day station activities; stop work authority at the site; periodic reporting on the status and adequacy of the quality program; and providing quality. verification

• and inspections.

• A.2.2.1.c Engineering Site Director This position reports functionally to the Vice President Corporate Support through the General Manager. Fleet Engineering. The position has functional. areas of responsibility that include authority for. day-to'-day engineering support activities, engineering administration, system engineering, system testing, and technical support._

This position is also responsible for NUREG-0737, Action Plan Item LB.1.2 technical review

. functions. that St. Lucie Unit 2 *and Seabrook Station are committed to and implement by system

• health monitoring;

• development of. a quarterly: system _health report which provides system performance and statu& to senior management, arid development and irnplementatio.1:i of the

. Maintenance Huie Program.

A.2.2.2.d Design Engineering. Site Manager This positiort _reports functionally.fo the Vice Presid~:mt Corporate Support through the Gen,eral

. Manager Fleet Engineering and the Director Design Engineering with direct interface with Jhe Site Dir~ctors and. PG Ms and is responsible fqr compliance with the Oesign Co.ntrol Program.

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-- Responsibility NextEra Energy retains and-exercises the responsibility for the scope and implementation of an

- effective overall QAP.

Positions identified -in Section A.2 may delegate all or parf of the

• _ activities of planning, establishing, and implementing the program for Which they are responsible

_ to others, but retain the responsibility for the program's effectiveness. Decisions affecting Safety ar~ made at the level appropriate_ for its natl.ire and effect, and with any_ necessary technical.*

advice or review.

• Senior_ management is* regularly apprised of assessment. results. evaluating. the adequacy of implementation ofthe OAP through the assessment functions described in Section C.

NsxtEra Energy ensures thaUhe QAP isproperly documented, app/oved and *implemented before c1n activity within the scope of the program is undertaken. _ Managehlent is respor,sible to _

assure

• that processes a.nd procedures

• comply with the QAJR arid _ other applicable requirements,* and.. that employ~es comply with_ them.

Individual _ managers ensure that personnel working Linder theirmanagenierit cognizarice are provided the necessary training and resources to accomplish their assigned tasks. : Managers and supervisors are responsible for _

timely. and continuing monitoring.. cif performance fo verify tliat day-to--:day activities are.

conducted safely and in accordance with applicable requirements.

As described i.n Section C.3, Nuclear Assurance is responsible to verify that processes and

. procedures comply with QATR ahd other applicable requirements, that such processes or procedures are implemented, ~md that management appropriately ensures compliance.

Documents that implement the quality program are approved by responsible management; distributed; and revised in accordance with procedures. Work within the scope of the QAP is accomplished in accordance with these documents.

• In additio-n, operating personnel responsibilities include:

The reactor operator's authority and* responsibility for shutting_ down the. reactor when it is determined that the safety of the reactor is in jeopardy or when :operating parameters

exceed any of the reactor protection system set-points and automatic shutdown does not occur.

• . The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or..

an unexpiained or unscheduiecf power reduction. * * *

~

• . The senior reactor operator's responsibility to be_ present -at the plant and to provide direction for returning the: reactor fo power following a. trip or -ari: unscheduled or unexplained power reduction.

• -The responsibility to believe and respond conservatively to. instrument indications unless :

- -they are proved to be incorrect.

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Respon~ibjlity (Continued)..

The responsibility to adhere. to. the plant's Technical Specifications.

The responsibility to review routine operating data to assure sate operation:**.

. ~

• . The responsibility to take action to minimize personnel injury or damage to the facility*

. and to protect the health and safety ofthe J:>ublic in the event of an emergency not.

covered by approved procedures...

.. *. In establishing OAP responiibilities,. NextEra* Energy conimits to compliance with NQA-1, 1994, *.

.. Basic Requirement.1.and Supplement 1.S:-1.

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• . Authority *. * *

,. )

When, responsibility is delegated for planning, establishing, or implementing any part' of the.

overall QAP, _ sufficient authority fo accomplish the_ assigned* responsibilities is delegated.'

• Regardless of delegation, NextEra Energy retains overall responsibility.*

• Responsibility and authorityto stop unsatisfactory work, ~s delineated in Section A.2, includes-*

• authority to. control further processing,= delivery;* ins~allatioii, operation or. use* of nonconforming

• .items.

.

• This as$ures that cost an.d

• schedule considerations. do not. override ~afety considerations.

..

• In establishing. OAP authorities, Next Era Energy com*m\\ts to compliance. with NQA-1; 1994, Efasic Requirement 1 and Suppieinent 1S-t.

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A.5

. Personnel Training and Qualification

. Personnel assigned to implement elements ofthe QAP: must be capable of performing their.

• assigned tasks. lo this end, formal indoctrination and training programs are established and maintained for personnel performing, verifying or managing activities within the *scope of the

. QAP to assure.that suitable proficiency is achieved and maintained~

Generating site and.

support* staff* :minimum qualification requirements c1re as d.elirieated ; in plant Technical Specifications bf other. appropriate documents.

Other qualification requirements may be *

.established but will.hot reduGe those required by plant Technical Specifications.

Sufficient

. managerial depth is provided fo cover absences

• of incumbents.. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in

• accordance with those requirements as estabiished in ttie applicable procedures. Indoctrination may include the administrative and techni~al objectives, requirements: of the applicable codes andstandards,.and the QAP elements to.be employed.. Training: for *positions identified i.n 1 OCFR50.120 is accomplished according to progrartJs accredited. by the National Nuclear

• Accrediting Board of the Nat(orial 0Academy for N.uclear Training that implements a systematic

• *approach to training'.. Records of personnel training and qualific1:1tion ar.e maintained.

• *.. In establishing qualification and training programs, NextEi-a Energy commits to compliance with

• . NQA-1, Basic Requirement 2, Supplements 2S~1. 2S-2, 2S-3 and 2S-4, and Non-mandatory Appendix 2:A.,1 with ttie following clari'fications and:exceptions:

• *. For Suppiement 2S-1: Inspections, examinations* :Or tests:: may be. performed by individuals in.the same.organization as that which performed the work, provided that (a).

the qualifications of the inspector for an activity are equal to or better than the minimum qualifications for persons performing the activity, (b) the work is within the skills. of personnel and/or. is addressed by procedures, and (c) if work involves breaching a pressure-retaining item, the quality ofthe work can be c:f ehlonstrated through a functional * *

• test. When a; b and c. are not met, inspections,: examinations or tests are carried out by *

• . individuals certified in accordance with: Supplement 2S-1. *Individuals: performing visual

• inspections required by the. ASME Boiler and Pressure Vessel Code* are qualified and.

• certified according to Code requirements.

• *

• At all NextEra Energy plants except Poirit Beach, in lieu of being certified as Level I,* 11 or Ill in. accordaric;::e with Nori-mandatory AppendiX 2A:1.. of NQA:-1-1994,. personnel performing operations phase independent quality verification inspections, examinations, *.

measurements, or tests on material products or. activities,. that *are. in the same *

. *

• organization as that *which performed. ttie work,. will be required to pOssess the same

. minimum level of qualification. as that requrred for performing ttie *task being verified. The..

verification shall. be Within the. : skins of. these personr,el andiqr is addressed by *

. procedures.*

Individuals responsible for* the* planning

• of. such quality verifiCc1tion

• inspections and tests (i.e. establishing holq points and accepfa11ce criteria i.n proced4res, or. determining. who will. be responsible for. performing the* inspections) will meet.

qualification requirements :equivalent to those. contained in Appe.ndix 2A-1 and suitably.*

.

• trained for the function.

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AS.

Pe.rsonnel Traiiling and.Qualification (C9ritinued}

~. In lieu ofNonmandatory Appendix 2A~1. NextEra Energy Point Beach does not establish*

levels of qualificatiori/ certification for inspection personrie1.* Instead, NextEra Energy Point Beach establishes initiaLqtialificatiorf requirements and determines individual

. qualification through. evaluation of* education, training and experience,** and through demonstration ofcapability iri performing the type of inspeqtions expected on the job.

In lieu of Supplement 2S~2. NextEra Energywill follow:the applicable standard cited. in

.. the latest. version(s) of Section Xi of the ASME Boiler and Ptemsure Vessel. Code

.approved. by the NRC for use ;1t NextEra. Energy sites for qualification of nonde~tructive examination personneJ.

• For Supplement 2S-3: The.requirement that prospective Lead Auditors have participated

. in a minimum of. five (5) audits in* the previous three. (3).* years is* replaced by the following, "The* prospective lead auditor shall dem_onstrate. his/her abjlity to properly implement the independent assessment (audit) process, as implemented by NextEra Energy ~ccording to Section C.3 of this QATR, to effectively lead an assessment team,.

and to effectively organize: and report results; including participation in at least one nuclear independent. assessment

• or audit. within

• the year preceding

• the date:* of qualification:;,

• The term "audit" and "indepemdent. assessment*,are synonymous and niay be used interchangeably

• throughout the QAP.

The demonstration process for prospective lead auditors is *described in written procedures. *

=

For Supplement 2S-~: A 90-day grace period may be applied to the requiremenffor: a documented annual: evaluation of lead auditor proficiency:* When. the grace period is

• applied, the next due date for the activity is based upon the original* sche.duled date.

However, in all cases thEi periodicity shall not exceed: one year plus 90 days:

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A.6 *

• Corrective Action Management, atall levels, fosters a non-punitive ("no-fault") attitude toward the identification of conditions adverse to qualify.

This includes* failures: nialfunctloris, deficiencies,. deviations, defective material and equipment, abnormal occurrences, nonconformances, and out-of-control processes; including the failure to fonow procedures.

A corrective c;1ction program is implemented to promptly identify, control, document, classify, and

correct conditions adverse to quality. In addition, for significant conditions adverse to quality,

. the. program provides for cause evaluation and corrective actions to prevent : recurrence.

Provisions are also made to ensure that corrective actions for significant conditions adverse to quality are completed as intended. arid are not inadverl:ently nullified by subsequent actions.

Results of evaluations of conditions adverse to

• quality. are analyzed to : identify trends.

• Significant conditions adverse to quality and significant adverse trends c1re documented and reported to responsible niariagement,.

\\

• Nonconforming items. are reviewed and. accepted,. rejected, : repaired,: or reworked, and are identified and controlled to prevent their inadvertent test, installation or u.se.

• Nonconforming.

items niay be conditionally released for installation, test, energization, pressurii;ation, or use if.

• the conditional release will not adversely affect rior preclude identification* and* correction of the

. nonconforniance. Disposition of conditionally released items are resolved before the items are relied. upon to perform

• their safety... related functions.. Conditional release 'evaluations are *

• . documented, reviewed, and approved prior to implementation.

• 1n establishing requirements for corrective action, NextEra Energy commits to compliance with

• NQA-1, 1994, Basic Requirements 15 and 16, and Supplement 15S? 1.

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A.7 Regulatory Commitments A.7.1 Through this QATR, NextEra Energy commits to Compliance.with the following:

• • 10CFR50, Appendix. B, "Quality Assurance Criteri;:1 for Nuclear Power Plants and Fuel Reprocessing Plants"

.10CFR Part 71, Subpart H, IIQuality Assurance for Packaging and Transportation of

• Radioactive Material".

• 1 OCFR Part 72, Subpart G, "Quality Assurance for. Licensing Requirements for the

. Independent Storage of Spent, Nuclear Fuel and High-Level Radioactive Waste"

(*

1 OCFR Part 21, "Reporting of Defects and Non-Compliance"

• General Design Criterion 1, of Appendix A to 1 OCFR Part.so or 1967 Proposed Draft

• . Generai:Oesign Criterion I (for Point Beach and Turkey Point) 1 1 OCFR50.55a, "Codes and Standards" 1 O CFR *73, "Physical Protection of Plants and Materials".

Wheri applicable, for Class 1, 2, and 3 items covered by Section 111 of the ASME Boiler and Pressure Vessel Code, the code Quality Assurance requirements are supplemented by the guidance of applicable regulatory guides (see Section A.7:3).

A.7.3

• NextEra Energy also is committed. to carrying out the provisions of certain nuclear. quality..

assurance industry standards, other than ASME. NQA-1. The extent of the commitment to each of the Regulatory Positions.of related. NRC

• Regulatory. Guides and Generic Letters is specifically described below.

• Commitment to a particular Regulatory Guide does not constitute commitment to Regulatory.Guides or: other standards that may be referenced therein, unless. *

. otherwise noted.

• Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants"

• - commitments regarding qualification and training *Of personnel are.described in Section A.5 of this QATR, which states. that staff qualification requirements are. as delineated in plant Technical Specifications or*:other documents,. and that training for positions identified in *10CFR50.120. is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National;Academyfor Nuclear.Training:*

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A. 7 Regulat9ry Commitments {Continued)

• Safety/Regulatory Guide 1.26, Revision(site specific) "Quality Group Classifications and Standards for Water-, Stearri:-. and Radioactive Waste-:Containihg Components of N4clear Power Plants" Commitment to Safety/Regulatory Guide 1.26 is.site specific, as required.by the approved UFSAR/License at each site. Sites may use this guidan*ce te> assist i.n establishing the. li~ts of equipment to which th.i~ QAP applies, or for other purposes.

Regulatory. Guide.1*.28, _Revision 3,.August. 1985, * "Quality As~urance. Program.

• Requireme.nts (Design and. Constructio11)" (ASME; NQA-1, 1983a)..., For all. NextEra.

En~rgy plants except Point Bei:3ch, NextEra. Energy d.oes riot commit to comply with position C.1

• pf this Regulatory. Guide for personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests on material. products or activities, that are. in the sarrie organization as that which* performed the work.

Point Beach does. not commit to compliance with

• position C.1 *of this Regulatory Guide; instead of *establishing* three ievels of,:*qualification. provided in Nonmandatory Appendix,2A.. 1, NextEra Energy Point Beach. establishes initial qualification requirements and _determines individi.1;31 qualification through evaluation of *.

edupc:1tion, training a.n.d experjence, and. through

• demonstration of capability: in performing the type of inspections expected-on the job. See the specific exceptions. to

28-1 and 2A-1 contained in Section A.5 'of this QATR. Nexi:Era Energy complies with*

position C.2 for record retention times, and position C.3.2 for external audits, with the exception that for position C.3.2.2, the information described therein will be reviewed 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 consiQered for effect on a

• suppliers continued qualification and adjustments:.n:,ade as necessary (including corrective actions, adjustments of supplier audit plans,* and input to third party auditing entities, as warranted).\\ Additionally, results are reviewed periodically* to determine if, as a whole,

• they constitute a significant condition. adverse

• to *quality requiring

• additional *action. 1.n lieu of compliance with Regulatory Position C.3.1, independent assessment frequencies as described in *section C of this QATR are established. In lieu ot°NQA-1 1983a, NQA-1 1994 is used.

Safety/Reguiatory Guide 1.29, Revision (site specific) Seismic Design Classification" -

Sorrie plants were designed, constructed and licensed based on criteria available prior to this Regliiatory Guide being issued,. The specific design cdteria and seismic designations are reflected in each plant's UFSAR, an.d. i.n other docketed analysis.*. T.hus, the commitment to Safety/Regulatory Guide. 1.29 i$ site specific, as required by the i:!pproved UFSARILicense at each site: Sites may use.this guidance to.assist in.

• . establislJitig the lists of equipment to which this OAP applies, or for other purposes.

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'A?

. : Regulatory Commitrrients (Con'tinued)

Regulatory Guide* 1.30, August 1972, "Qualify Assurance Requirements* for the

• 1nstaUation, Inspection and Testing of Instrumentation arid Electric Equipment/ (ANSI N45.2.4-1972/IEEE 336-1971) __,NQA-1 1994, Subpart2.4/IEEE 336-1985 is substituted for N45.2.4 in its commitment to Regulatory Guide 1..30: As. noted in Regulatory Position

• C.1, Subpart 2.4

• is being Li~ed in conjunction with* NQA-1,: Part 1, which replaced ANs.1

• N45.2.

• As noted in Regulatory.Position. C.2,

• other

• industry *standards may be

• referenced; the commitment in this. QATR to NQA-1, : Subpart 2.4 includes commitment to those standards.to the extent necessary to implement Subpart 2.4 requirements.

• 1f

*.: NRC guidance applies to ttiose referenced standards, it is followed;* Regulatory Position *

.. c.. 3 in,dicate~ that the* requirements of the. endorsed. standard. should aiso be* con.sidered applicable duririg the operation phase of the nuclear power plaht. This is addressed in Sections E3_.12 an.d.E3, 16 of this QATR, wnich also establish any necessary exceptions or.

:. alternatives to the :Provisions of Subpart 2.4.

'Regulatory Guide 1.3:f Revision 2, February 1978,. "Quality Assurance Progr~m Requirements (Operation)". (N18.7) --: NQA-1 contains quality assuran*ce requirements equivalentto those bf ANSl*N,,18.7, and NextEta Energy has included in this QATR the remaining "administrative controls" elements from N~ 18. 7 ( 1976). Therefore, Ne~~ra Energy does riot commit to compliance with the *requirements. of ANSI N-18. 7.:. As

. recommended by Regulatory Position C.1, Appendix A of RG 1.33 is used as guidance.

1n establishing the *types of procedures required for plant operation arid support.

Regulatory Position C.2 is no longer' considered valid, as the referenced sfandards arid guidance have now been incorporated into ASME NQA-1 1994, or* are addressed

• . : specifically' in this section.

• NextEra Energy meets the guidance in Regulatory Position C.3 in that proposed changes to technical specifications or license amendments are, reviewed by the independent review body, OR,G, prior to submittalfo the Commission for approval. lri lieu of compliance with Regulatory Position C.4; assessment topics and

frequencies are established as described in Section C.3 of this QATR. *: In lieu of* *.

. :

• compliance with. *Regulatory Position C:5, appropriate equivalent: requirements have been.established within this QATR.**

• . Regulatory* Guide: 1 ;36, Revision 0, February 1973, "Non.metallic Thermal Insulation for *.

Austenitic Stainless.. Steel". -. Some of the, current plants were committed. to this

~egulatory Guidance during original construction. Regulatory Guide 1.36 may be used for plant.modifications ori a case by case basis, but this QATR makes no generic.

. commitnient thereto:'

• *.: I

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. Regulatqry Commitments (Coiltinu~d) *.

• Regulatory Guide*1:37, March t973, "Quality Assurance Requir~ments for Cleaning of Fluid*

Systems and Associated. Components 6f Water-Cooled Nudlear P6wer Plants/'* (ANSI N452.1-1973)..:.: NQA-1 1994, Subpart 2.1 is substituted for N45.2.1 in its commitment to Regulatory. Guide 1.37. As noted in Regulatory Position C.1,. other industry standards riiay.

be referenced; the. commitment in this QATR to NQA:.1, Subpart 2.1 includes commitment to*

• those standards to the extent necessary to implement Subpart 2.1. requirements. If NRC guidance applies to those referenced standards, it is followed. Regulatory Positions C.3, C.4 and C.5 recommend alterations.to certain provisions of N45.2.1; The provisions of NQA.~1.

\\

• Subpart. 2.1 establish requirements that are consistent with those

• recommendations.

Regulatory. Position t:2 indicates that the requirements of the endorsed standard should be.

used during the. operatiqns phase when applicable." This is addre~sed in Sections 8.7 and S.16 of ttiis QATR,. which

• alsq estab!ls.h any necessary e:xceptions. or alternativt:ls to the.

. provisions Of Subpart 2. t.

Regulatory Guide 1.38, Revision.2, May:1977; "Quality Assurance Requirements. for Packaging; Shipping, Receivin*g, St9rage, and Handling* of Items for Water~Cooled.

N,uclear Power Plants," (ANSI N45.2.2-1972) - NQA-1 1994, Subpart 2.2 is substituted.*.

for N45.2.2 in its commitment to Regulatory.Guide 1.;3S,

• As noted. in Regulc,1tory PQsition C.1.ai. other industry standards* may be referenced; the commitment in this QATR. to NQA-1; Subpart 2.2. includes. commitment to those standa[ds to the extent necessary to.

implement Subpart

• 2.2 requirements.

• If NRG guidance applies. to* those referenced standards, itis followed: Regulatory Position C.1.b modifies a provision of N45.2.2 such that the minimum load for dynamic testing to' re-rate hoisting equipment for. special* lifts

• becomes 110% of the rated load. NextEra Energy takes exception to the Storage Areas

• section (6:2.4) of NQA-1 arid commits*to "the use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and b~flimited to designated areas where* such use or storage is not deleterious fo stored items",

• The Hc;tcidling

• • section: (7) of NQA~ 1, Subpart 2.2 defers to the provisions of Subpart 2.15,.

• NextEra : *

• Energy does not.commit to Subpart 2.15; as there is no current NRG guidance regarding the other provisions of this part..* For purposes of compliance to* Regulatory Guide 1 '.38, Position C.1.b;

• NextEra Energy commits.to follow the guidance as stated (see Section

• 8.7).. Regulatory Positions: C.1.c, *c.1.e, C:2.a, c.4.b, C.2.c, C.2.d and C.2.e. **

recommend alterations to certain provisions of N45.2.2: The* provision$. of NQA-1, Subpart. 2.2 establish

• requirements that are consistent with those recommendations.

Regulatory.Position. C.1.d indicates that the* requirements. of the endorsed standard

• *

• should be *used durlng the operations: phase "when appiicable." this is addressed in * *

• Section

• 13. 7 of

• this* QATR,

• which *also. establishes any

• necessary exceptions. or altern~tives to the provisiqns of stibpart 2.2. * '

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. A. 7 Regulatc;,ry Commitments (CQntinued):

• • Regulatory Guide 1.39, Revision 2, September 1977, "Housekeeping Requirements for

• Water-Cooled Nuclear Power Plants," (ANSI N45.2.3-1973).:_ NQA-1 1994, Subpart 2.3 is substituted for N45.2.3 in its commitm_ent to Regulatory Guide 1.39...As noted in Regulatory Position_ C.1, other industry standards may be referenced;.the* commitment in this QATR to NQA-,1, Subpart 2.3 includes commitment to. those standards to the extent :

• necessary to implement Subpart 2.3 requirements. If NRG guidarice applies to those.

referenced standards,.

• it is followed.

Regulatorv. Position C.2 indicates that. the

. provisions.of section 3.2.3 of. N45.i3 are not part 'at the Regulatory endorsement.

• As ".

NQA-1, Subpart 2:3, section 3.2.3 lias the same wording c1s N45.2'.3, the Re.gulatory

• Position is applicable and will be followed in. implementation of Subpart.2.. 3. Regulatory Position C.3 indicates that the endorsed* standard is "applicable for housekeeping activities during* the: operations phase that are comparqQI~ to those occurring during.

construction." This is addressed in Section 8. 7 of this QATR that also establishes any necessary exceptions or alternatives to the provisions of Subpart 2:3.

• .

• Regulato_ry

• Guide 1.54, Revision b, June 1973, "Quality *Assurance for Protective.

Coatings Applied to Nuclear Power Plants" (N101'.4-1972) - Commitment to Regulatory Guide 1.54 is site specific, as required by the.approved UFSAR/License c:1t. each site.. * *

• 'Regulatory Guide 1.94,, Revision 1, April 1976, "Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel* During the Construction Phase of Nuclear Power Plants," (f\\NSl N45.2$-197 4).-* NQA-1 1994, Subpart 2.5 is substituted for N45.2.5 in* its commitment to Regulatory Guide* 1.94; however, Subpart 2.5 includes requirements for ~foils and foundations which were not included in N4q.2.5;. and the commitment to

• Subpart 2.5 herein does not include comniitment,to those requirements, As noted in Regulatory Position C.1, other industry standards may be referenced; the: commitment in this QATR to NQA-1, Subp9-rt 2.5

. includes commitment to those standards to the extent necessary to implement *subpart 2.5 requirements. If NRG guidance applies to those referenced standards, itiS follovved...

Regulatory Position C.2 recommends using the general planning provis_ions of N4~.2.5

. in conjunction with Regulatory Guide 1.55, which has since been withdrawn; therefore, this position is no longer applicable. Regulatory Positions C.3 and C.4 reco.mmend.

alterations to certain provisions of N45.2.5.. The provisions of NQA-1, Subpart 2.5 are

• consistent with those recommendations.

Applicability and use of Subpart 2.5. is

. addressed in Sections 8.12 and 8.16 of this QATR, which also establish any necessary

• . exceptions or alterria'tives to th~ provisions of Subpart 2.5.

Regulatory Guide 1.97, Revision 3:,:.May 1983, "Instrumentation for Light-Water-Cooled

.-Nuclear Power Plants to Assess Plant and Environs Conditions During,and Following an

.Accident" (Table 1, paragraph 5) - In lieu of the Regulatory Guides listed in the Table, NextEra Energy commits to the Regulatory Guidance and industry standards for quality assurance as described in this QATR. *'Commitment to the technical provisions of

. Regulato_ry Guide 1.97 is site specific as addressed in _each plant UFSAR or other licensing cqmmitments.

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• A:7

• Regulatory Commitments (Continue~)*

• Regulatory Guide 1.116, Revision 0-R, May 1977,,;Quality Assurance Requirements for Installation, Inspection, and Testing of *Mechanical Equipment arid Systems/ (ANSI N45.2.8-1975),.:.. NQA-11994, Subpart 2.8 is substituted for N45_.2.8 iri its commit.ment

. to Regulatory GuidE:;l 1: 116.

As noted iii

• Regulatory position C.1, other indu*stry.

• standards* may be referenced; the co*mmitment in this QATR to NQA-1, Subpart 2.8 *

• includes commitment to those standards to the extent neceisSary to implement Subpart

• 2.8. requirements. If NRG. guidance applies to those referenced standards, it is followed.

. Regulatory Position C.3 recommends using section 5 of. N45.2.8 in. conjunction* with

. Regulatory Guide. {68 for* pre-operational, cold functional,. and hot functional: testing.

. \\iVhile section 5 of NQA-1,,Subpart 2.8 provides the same requirements, itis anticipated that NextEra-Energy plants, since they are. 'already beyond these tests, wiU not need to

• implemE:;lnt.RegLilatory Guide 1.68. If. te~ting in accordance with Regulatory Guide 1.68 becomes necessary, NextEra.Energy will comply with the guid~nce.of the Regulatory Guide 1.116 position. Regulatory Position C.2 indicates that the endorsed standard should be "followed forttiose applicable operations phase activities that are comparable to activities occurring during the construction phase." This is.addressed in Sections 8.12.

• and 8.16 of this QATR, which also establish any necessary exceptibns or alternatives t6*

• the provisions of Subpart 2.8.

Regulatory Guide 1.143, Revision 2, November.2001, "Design Guidance for Radioactive Waste. Management Systems, Structures 'and Components Installed in Light-Water:..

Cooled Nuclear Power Piants" (Position C.7) - The :intent of the quality assurance guidance cited in Position C.7 is met. Compliance with the remainder of the [technical]

positions of Regulatory Guide 1.143 is site specific, as addressed in each plant UFSAR.

• Regulatory Guide 1.152, Revision 1, January 1996, * "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants'.'*.:.... None of the plants were committed fo this Regulatory Guidance during or1ginal construction.. Regulatory Guide t152 may be used for pla.nt modifications on a case by case basis, but. this QATR makes no generic cornmitment.thereto.

• *

• Regulatory Guide 1:155, Revision 0, August 1988; "Station Blackout" {Position C.3.5) -

Quality Assurance guidance cited in Position. C.3.5, Appendix A is.met. Compliance with Appendix B and the remainder of the [technical] positions of Regulatory Guide 1.155 is

. ~ite specific; as addressed in. each plant.UFSAR or. Liceris_e commitmer1ts.

Generic Letter. 89-02/EPRI-NP-:-5652 (March: 1988, and supplements through Mar.ch 1993)- Next:Era Energy.commits to compliance w1th*the endorsed industry guidance

• regarding selection.and qualification. of.commercial grade.suppliers* and dedication of commercial. grade items for use in safety related applications..

Generic Letter 91-05 (April 1991) -: NextEra Energy. commits to compliance with the

.. guidance regarding licensee commercial..:grade proCurementand dedication programs..*

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A. 7 Regulat<;>ry Commitments (Continue~).

• Branch Technical Position CMEB 9.5-1,.Revision 2, July 1981 (Positions C.2 arid C.4)...,...

Provisions for administrath,e

• controls for, Fire Protection comply with site specific commitments, or with the provisions of Position C.2 of CMEB 9.5.. 1, Rev,.2,. as specified in NRC approved siteJire protection programs and ~he applicable NRC Safety Evaluation

• Reports.* Application of the provisions of this QATR to fire protection activities provides elements of quality assurance that comply with* site specific fire protection quality assurance commitments or with CMEB 9:5.1, Revision 2, Position ~.4..

• . For plants with an NFPA 805 fire protection licensing bases, NextEra Energy commits to implement Regulatory Guide 1.205, December 2009, "Risk-Informed, Performan.ce-Based Fire Protection for Existing Light-Water Nuclear Power Plants," which endorses. in

. part, NEI 04-02, Revision 2, Nuclear Energy Institute Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c). The implementation of these documents is described in the station specific Technical Specifications and License Conditions and station specific NRC approved Safety

..Evaluation Reports...

• Regulatory Guide 4.15, Revision 1, February 1979, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" -

The intent of Regulatory Guide 4.15 is met.

Regulatory <3uide 7.10, Revision 2, March* 2005, .Establishing Quality Asst;1rance Programs for Packaging Used in the Transport of Radioactive Material" -

N,extEra Energy commits to implement the quality assurance guidance for activities related to the

• packaging and transport of radioactive material that are under its control. *

• Quality Assurance for. *the design, fabrication ancf licensing of shipping contalners is the

. responsibility ofthe container certificate holders.

• Generic letter 85-06, April 1985, "Quality Assurance Guidance for A TWS Equipment That Is Not Safety-Related" - NextEra Energy commits to the quality assurance guidance cited in the. Generic Letter:

Regulatory Issue Summary 2000-18, October 2000, "Guidance on Mc;1naging Quality Assurance Records in Electronic Media" - In instances when electronic media storage is chosen.as a means of maintaining required records, NextEra Energy will comply with the guidance of this Regulatory*lssue Summary.

Confirmatory Order Number EA-08~172,Section V.c, states, <'FPL will create a. fleet security organization to provide management oversight rel.ated corrective actions and enhancements to improve the thoroughness of searches at the St. Lucie Plant and other.

fleetwide facilities.

• NextEra nuclear plants with a* renewed Facility Operating* License are committed to

satisfy the intent of NUREG-1800,

• Branch Technical Position IQMB-1, "Quality

• Assurance for Aging Management*Programs," and/or Ni.JREG-1801 elements. The: 10 CFR Part 50, Appendix B quality assurance program* provides for corrective actions, the

. confirmation process, and administrative controls for Aging Management Programs :

• (AMP) for* license renewal.*

• The scope of this existing QA program is expanded to Revision 22 27 of 84

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• Quality Assurance Topical Report (FPL~1) include non-safety-related. structures anc;i components. that

• are. subject to an

• Aging

. Management Review (AMR) for license renewal.

. \\

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B...

PERFORMANCENERIFICATION 8.1 Methodology. *

. Personnel who work. directly*.or indirectly for NextEra Energy are* responsible for the achievement of acceptable quality in the work covered by this QATR..* This includes design, engineering, procurement,.* manufacturing, construction; installation, start-up, maintenance,.*

• modifications,. and operations. Personnel performing verification activities are responsible for

• verifying the achievement of acceptable quality. Activities governed by the QAP ate perform~d

. as directed by documented instructions;: procedures

• and drawings that are of. a detail

. appropriate for. the activity's complexity and. effect on safety.*. Instructions, procedures and : *

. drawings specify quantitative or quaiitative acceptance criteria as applicable cir appropriate for the activity, and verification is against these criteria. provisions are established to designate or identify the proper documents to be used in an activity, and to ascertain that such documents.

are being used:.

B.2

Design Control A program has been established and implemented to contml the design of items that are subject *

• to.the provisions of this QATR (see Section A.1).. The program includes provisions to control design inputs, processes, outputs, changes, interfaces, records and organizational interfaces.

These provisions assur~ that design inputs (such as design bases and the performance, *.

regulatory, quality, and

• quality verification requirements) are correctly translated into design outputs (such as specifications,. drawings,* procedures, and instructions) such that the final design output can be related to the design input in sufficient detail to permit verification. The program defines the interface controls (internal and external between-* participating design organizations and across technical disciplines) necessary to control the development, review, approval, release, distribution and revision: of design inputs and outputs.

Design processes provide for designverificcitioh (as c:iescribed in Section 8,3) that items and* *

• . activities* subject to the provisions of this QATR are* suitable. for* their intended application, consistent with their effect on safety. Changes to final designs (including field changes) are

. subjected to these controls, which in.elude measures commensurate with those applied : to original plant design. Design changes and disposition:of nonconforming items as "use as is" or*

"repa1r*are reviewed and approved by the responsible design organization.

Records. are* maintained sufficient to provide evidence that. the design wa~ properly accomplished.

• These records include the final design output and any revisions thereto, as well *

• as record of the important design steps (e.g., c:alculatioris, analyses and cornputer programs) an~ the sources of inputthat support the final outp.ut/

In addition, temporary design changes (temporary modificationsj,

• such as temporary bypass.

. lines, electrical jumpers and lifted leads,. and temporary trip-point settings, are controlled by

• procedures that include requirements f6r appropri~te. installation and r~hloval verifications and status tracking..

.. In establishing its program for.design control, NextEra *Energy commits to compliance with. NQA-

. 1, t994, Basic Requirement 3,.and Supplement 3S-t, :Sections 1, 2, 3, 5, 6, and 7.

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B.

• PERFOR.MANCE,VER.IFICATION (CONTINUED}*

8.3

• Design Verification The design control program includes. requirements for verifying the acceptability of design

, activities and documents, consistent with their effect on safety. This includes design inputs, design outputs ahd design changes.

Design verification procedures *are established and

• implemented to assure_ that an appropria,e verificat_ion method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verific.ation is satisfactorily accomplished and documented. Verification rriethods *may include, but are not limited to, design reviews, alternative calculations and qualification testing.

• Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under *

• conditions that simulate the most adverse design* conditions expected for an item's intended

• use.

Design verification activities are completed before the design outputs are used by other organizations for design work, and before they are used to.* support other activities such as

' procurement, manufacture or construction... When such timing cannot be achieved, the unverified portion of the design is *identified arid controlled such. that, in all cases, *the design

• verification is. completed before relying on the item to perform its intended safety function.

Design verification can be performed by the.designer's immediate supervisor, provided (1) the

• supervisor did not specify a singular design approach or rule out certain design considerations and' did not.establish the design inputs.used in the design; _or (2) the supervisor' is the.only technically qualified individual capable of. performing the verification, and (3) the need is individually documented and approved in advance by th.e supervisor's management. The frequency and effectiveness of the use of supervisors as design verifiers are independently verified to guard against abuse.

• In es.tabllshing its program for design verification, NextEr_a Energy commits to compliance with

• NQA-1, 1994,. Basic Requirement ~. and Supplement 38-1, Section 4.

B.4 Procurement Control.

Controls are* established and impl~mented*to assure that purchased items (components, spares and repl_acement parts necessary for plant operation, refueling, maintenance and modifications) and ~ervices are subject to quality and technical requirements : at least equivalent* to those specified for original equipment or specified by properly reviewed and approved revisions to assure the items are suitable for the intended ser-vice, and are of acceptable quality, consistent with their effect on safety. These controls include provisions such that:...

• . Where original technical or quality assurance requirements cannot be determined, an engineering evaluation.i~ condµcted and documented by qualified staff to establish

. appropriate requirements and controls to assure that interfaces,. interchangeability,

• safety, form, fit and function, as applicable, are not adversely affected or contrary to applicable regulatory requirements.

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_B..

.

• PERFORMANCENERiFICATION (CONTINUED) 8.4

• Procurement Control (Continued).

• Items are inspected (see Section B, 12) and identifieq and ston~d (see Sections R6 and B. 7) to protect against damage, deterioration or misuse: *

• . Prospective suppliers of safety related items and services are evaluated to assure that orily qualified suppliers are used.' Qualified suppliers are period_ically evaluated 'to assure they coritinu~ to provide acceptable products and services_. Industry programs, such as thqse applied by ASrv1E, NUPIC,. or other. establishecl utility groups, are used as iriput or the basis for supplier qualification whenever appropriate. In addition, NextEra Energy commits to Position C.3.2 c:if Regulatory Guide. 1.28, Revision 3, for auditing ar:id evaluation 'of suppliers, with an option to take exception.for position C.3.2.2, where the.

'information described therein is reviewed as it becomes available through its ongoing receipt inspection, operating experience, and' supplier evaluation programs, in lieu of performing a Specific. evaluation oh. an annual basis. The results of the* reviews are

.

• promptly considered for effect on a supplier's _continued qualification and adjustments.

• *. made as. necessary -(including corrective actions; adjustments of Supplier audit plans, and input to third party auditing entities, as warranted):.* In addjtiqn, results are rev(ewed periodically to determine if., as a whole, they constitute a significant condition adverse to

- quality. requiring. additional action.

• Other 1 OCF~50 licensees,

• Authorized.Nuclear.*

Inspection Agencies, National Institute of Standards and Technology, or other state and federal agencies which

• provide items or services* to. NextEra

• Energy plants are not required to be* evaluated* or audited. A 90~day gr~ce

• period may be applied to the

• _requirement to audit Suppliers on a triennial basis.

• When:the grace period is applied, the

• riext due date for the activity is based upon the original scheduled date. However, in all cases the periodicity shall not exceed three years plus 90 days: *

~. ' Applicable technical; regulatory, administrative,: quaHty and reporting requirements (such' as specifications, codes, *

• standards,

• tes_ts, *

• iriSpectiohS,

• special

• processes, and 10CFR21) are :invoked for procurement ofitems arid services. Documentary eviden_ce

. that an itern conforms fo these requirements is available at the site before relying.oh the

-*. item to *perform its intended. safety function. These documents are *considered* records.

. according to Section B: 15:,

• . provisions. are made for* accepting purchased_. items and services,. such as. source.

• *. verification,. receipt inspection, pre-and post-installation

tests, certificates of.

conformance,. and document reviews. Acceptance actions" are Gompleted. to ensure t_hat procurement, ' inspection, ' and test' requirements, as' applicable, have'. been satisfied

. before relying ori the.item to perform its intended safety function.

-,e_~

Controls are imposed for the -selection,' determination~ of suitability for intended. use (critical characteristics), evaluation, receipt and acceptance of co'n:imercial grade or: '.'of{-

. the-shelf'.items to* assure they will perform satisfactorily in service in safety. related.*. -*

applications.

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• s:

. PERFORMANCE/VERIFICATION (CONTINUEO)

B.4

.

• Procurement Control (Continued) : :.

. Jn* *establishing controis for procurement,* Next Era. Energy commits to compliance _with NQA-1,

. 1994, Basic Requirements 4 arid 7, and Supplements 4S~ 1 and 7S-1, _with the following exceptions:

ForSupplement4S-1, Section 2.2 (which requires procurement documents to providefor identification of test,. inspection,* arid acceptance,requirements of the Purchaser for

.

• monitoring and evaluating the suppliers performance), and Supplement 7S-1; Section 5,.

. for suppliers. of commercial-grade calibration services. with a2creditatio'n by a nation.ally-recognized accrediting body, a docu_mented review ofthei supplier's accreditation m*ay be used in. lieu of inspection Qr t.ests following delivery or in-proce15s surveillances during performance of the service.. Jhis review, shall include, at a minimum, all of the fol(Qwing:. :

1. :. The accreditation.encompasses ANSJ/ISO/IEC 17025,2005, (or ANSI/ISO/IEC 17025:2017), "Gen'eral *Requirements* for the

• Competence of Testing and

• Calibration: Laboratories",

2.

The accreditation body

• is recognized by the *.!LAC (lritj3rnational Laboratory

/\\ccreditation.Cooperation) via.a MRA (M1.1tual Recognition Agre.einent).

)

3..

The published scope of the accreditation for the. calibration laboratory covers the

. needed measurerrient parameters, ranges, and uncertainties.

,\\ :

4.

For procurement of testing services, the published scope of accreditation for tM

• . test laboratory covers the. needed testing services including test methodology arid

• *

• toler~nces/uncertainty.

For Supplement 4S.::1, Section2.3 (which requires procurement documents to require.a quality program that: complies

• with NQA~1 }, when purchasing commercial.,.gracle

. calibration/testing services from laboratories accredited by a domestic or *international

• calibrati_on

• and,testing laboratory*: accredited

• by an:

• 1LAC MRA signatory, the*

accr~ditation process may be used. in* 1ieu of performing a commercial grade survey as pait 0:f the coniinercial grade dedication process.. In such cases, accreditation may be accepted in lieu of imposing a QA Program consistent with NQA~ 1-1994, provided all the.

following are mef : *

1) *.A review of the suppHer Accreditation: is performei:t and includes v~rification of the folio.wing:

. (a) The. aQcreditationc is to: ANSI./ISO/IEC 17025:2005,'

(or. ANSl/1$0/IEC 17025:2017), "General Requirements for the. Competence of :Testing. and

• .Calibration Laboratories."

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- PERFORMANCE,VERiFICATION (CONTINUED) 8.4 _ - Procur~ment Control (Continued) * * *

(b) The_ accrediting body is* recognized by the ILAC (International Laboratory

-Accreditation Cooperation) via a MRA (Mutual-Recognition Agreemeht).

(c) For procurement of calibration services, the published scope of accreditation for the Ci:tlibration laboratory covers the needed measurement parameters, ranges,

• and uncertainties.

l (d) For procurement of testing services, the published scope of accreditation for the

- test lab6ratory

• covers the needed testing services including test methodology

.* and tolerances/uncertainty.

2) Purchase order documents shall require:.

(a) The service must be provided in-accordance with the supplier's accredi_ted ISO/IEC 1702~:2005 (orANSI/ISO/IEC 17025:2017) prpgram and scope of

• accreditation.

.'\\.

(b) As,-Found calibration data must be reported in the certificate of calibration when

. calibrated items are found to be out-of-tolerance (for calibration servic~s only).

(c) Equipment/standards used to perform the calibration must be identified in the certificate of calibrati_on (for calibration services only).

• (d) The calibration/testing laboratory to notify FPL of any condition that adversely *.

impacts the laboratory's ability to maintain the *scope of accreditation.

(e) Any additional technical and quality requirements, as necessary, based upon a.

review of the procured scope of services, which may include, but are not necessarily limited to, tolerances, accuracies, ranges, and industry standards.*

3) The receipt inspection shall validate the laboratory's document/certificate that:

(a} Certification that the calibration or. test service has been performed in accordance with the ISO/IEC 17025:2005 program* and that the test/calibration has been

. performed within their scope. of accreditation and ali purchase order requirements have b~~n met *

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B..

• • PERFORMANCENERiFICATION (CONTINUED) 8.4.. Procureme'nt Confl'ol (Continued)

Fo(Supplemelit 4S-1,.Section 2.3, which requires ptocuremer.1t documents to require a quality program thqt complies with NOA-1, other riatio,na11y* recognized and NRC.

. endorsed quality standards.,* $UCh as N45.2, may be applied as appropriate to the.

' 'circumstarices ()f the procurement. ' ' ' '

• . For *supplement 7S-1, Section a: 1, documentary evicJence that items conform to

• procuremer:it requir~rnents nee.d not be ;:ivailable at the site prior to: item installa{ipn, but.

will be available-at the.s.ite priqr to: placing {eliance <;m the item for its intended$1;1fety function.

• *.For Supplement 48~1 and SupplemenL7S-1, the guidance contained in Generic Letter 89,.02/EPRI NP~5652 and Generic Letter ~1-05 to procure Commercial Grade Items will be used in lieu of these requirements.

The methodology for use of: accreditation iri :lieu of commercial: grade surveys for laboratory calibration. and test services *

• is. defined *

• in the

• Nuciear Energy Institute document NEH4-05Aand acknowledged by the NRC 1n RIS 2016-01 as acceptable for

• use by all holders: of operating licens~ under Tit.le 1 O of the Code of Federal Regulations

• * * (1 O CFR) Part so:* Requir~ments for applying t.his methodology are defined in RIS 2016:.

Ot. Additionally, the.NRC provided provisional a.cceptance of ISO/I.EC. 17025:2017 applicable during the transition period set to expire on November 30, 2020 to allow

. accredited* laboratories to transition from the current 2005 edition as. provided by ISO. * *

• The use* of*ISO/IEC 17025:2017 beyond the transition period requires*NRC acceptance of the next revision to. NEI 14-05A:supporting this edition (ADAMS Accession Number

. ML19056A451. dated.April 16, 2019to Nuclear Energy Institute).

For com*mercial grade calibration services from a supplier that has been accredited by a nationally recognized accrediting.body (NVLAP or other accrediting body recognized by

.ILAC.via a Mutual Recognhion Agreement {MR.A}), the service rnay be accepted subject

.. to the restrictions noted in Section. B.4 above instead of Supplement 4S-1 and

. s'upplement 75., 1.

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PERFORMANCE/VERIFICATION (CONTINUED)*

8.5 Procurement Verification

. Measures are established and implemented to verify the quality of purchased items and

, services, whether. purchased directly or through contractors, at intervals arid to a. depth consistent wittJ the item's or service's importance to safety, complexity, quantity and the

• frequency of procurer:nent. Verification actions include testing, as appropriate, during desjgn,

• fabrication.* and COrJ$kuction **activities : associated with plant maint~hance or modifications.

Verifications occur at the. appropriate phases of the. procurement process, including, as necessary, verification of activities of suppliers below the first tier.

In establishing procurement vedfication. controls,*.NextEra Energy commits to compliance with

• NQA~1, 1~94, Basic ~equirement 7 and Supplement 7S-1.,...

8.6

ldentific&ti<m and :c.ontrol of Items Provisions are established and implemented for the identification :and control of items to prevent

• . the. use of incorrect or defective* items. This includes controls for consumable materials. and

• items with limited shelf life.

• The identification ot. items is maintained :throughout fabrication,

• erection, instaUation and use so that.the item can be traced to its documentation, consistent with.

• . the item's effect on safety., Identification location.s and methods are selected so as not to affect

. the function or quality ofthe item.

• In establishing provisions. for identification and control of items, NextEra Energy commits to

• . compliance with NQA-1, 1994, Basic Requirement 8 and Supplement 8S-1.

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• 8.7 Handling, Storage and:Shipping Provisions are established and implemented to control the handling, storage, shipping, cleaning and preservation of items to *preve_nt inadvertent damage; loss or deterioration.

• These provii:;ions include specific* procedures, when. required to maintain acceptable quality, for *

• cleaning, handling, storage, packaging, shipping ;:ind preserving items imp*ortant to safety.

Items are c;1ppropriately marked and labeled during packaging, shipping, handling and storage to

, ide.ritify,. maintain and preserve the item's integrity and indicate the need for special controls.

Special controls (such as containers, shock ~bsorbers, accelerometers, inert *gas atmospheres,

. specific moisture content levels and temperature levels) are provided when req.uired to maintain

. acceptable quality.

• . In establishing. provisions. for harid)ing, storage and shipping, NepctEra Etiergy commits to.

• cpmpliarice with NQA-1, 1994, Basic Requirement 1;3 and Supplement.1.38-1.

• NextEra Energy also commits to compliance: with the* requirements of NQA-1, 1994,

• Subpart 2.2, with th<?

following exceptions:

Subpart 2.2, Section 2.2 estabiishes criteria Jor classifying items into protection* 1evels.

lnstea9 of classifying items into protection levels, plants may establish controls for the packaging, shipping, handling and storage of s_uch items on a case-by-case basis with clue 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.

Subpart 2.2, Section 5.2.2' requires receiving

• inspections be performed _in an area equivalent in e.nvironmental controls to those for the* 1evel of sto*rage of the item. At NextEra Energy plants, receiving inspection area environmental controls may be less

• • stringent than the storage environmental requirements for the item. Such inspections *

.. are performed in a manner and in an environment which does not endanger the required quality of the item.

• Subpart 2.2, Section 6.2.4 states that the use or storage offood, drinJs, and: salt tablet *

• dispensers in controlled storage areas shall not be permitted. Exception is taken to the wording of Section 6.2.4 and an alternate requirement substituted that the use or storage

.of food, drinks, and salt tablet dispensers in any storage area shall be controlled.and be.

. : limited to. desigm:ited areas* Where such. use or sf orage iS: not deleteri()US to the stored.

iterris.

• Subpart 2.2, Section* 6.4.2 states that care of items iri storage shall be exercised in.

accordance with* the. following: (h) Other maintenance requirements.specified.by the manufacturer's instructions shall be performed. Exception is taken to the wording of Section 6.4.2 (h) and an alternate requirement substituted that,;Care of items in storage

.

• shall be exercised. in accordance with the following: Types of components. that could * *. * *

. require maintenance. while

• in storage. shall be *identified -and evaluated for specific ---

maintehance requirements.

Maintenance activities in Section 6.4.2 (h), listed in this requirement* shall be* considered. during *this. evaluation and* any deviations shall be

. documented."

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B.7 Handling, Storage and Shipping (Continued)

Subpart 2.2; Section 7,1 refers to Subpart 2~15 for.req*uirements related tdhandlirig of

. items. ThE;l scope of Subpart 2.15 includes hoisting, rigging and transporting of items for

• nuclear. power plants. This scope exceeds the scope of the NRC's original endorsement of ANSI N45.2.. 2.in Regulatory Guide 1.38, and establishes requirenierits for which there is no.NRC regulatory position. *In.lieu of compliance with Subpart 2.15, Controls are established and implemented over hoisting'. rigging and transport activities to the extent

• necessary to protect the integrity of.the: items *involved, as well as potentially affected

. nearby structures. and components.

• For re-rating of. lifting equipment to allow. special lifts,"* NextEr~ Energy performs dynamic load testing. over the full range of the lift using test loads at least 1.10% ot the lift weight Dynamic tests include raising, lowering, arid traversing. the load: :.Where* required, Next Era Energy complies with applicable hoisting,

• rigging and transportation regulations and codes.

Housekeeping practices during. normal operations. and maintenance. activities, including refueling, are established to account.for conditions or environments that could affect the quality

.of.structures, systems. and components within the plant This includes control of cleanness of facilities and materials, fire prevention arid protection, disposal of combustible material and debris, control of access to work areas, prqtection of equipment; radioactive contamination control and storage of solid radioactive waste. Housekeeping practices assure that only proper

. materials, equipment, processes* and procedures are used and that the quality of items is not degraded as a result. Necessary procedures or work instructions, such as for electrical bus and control

• center. cleaning,

• cleaning* of control consoles, and radioactive decontamination are developed and used.

ln*addition,* NextEra Energy commits to compliance with the requirements of NQA-1,. 1994,

• Subpart 2.1, to establish appropriate provisions for the *cleaning of fluid systems and associated components; and* Subpart* 2:.3, to establish appropriqte provisions for housekeeping; with the

• following exceptions: * *

• Subpart 2: 1, Sections 3.1 E!rid 3.2 establish criteria for classifying items into cleanness * *

• classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, plants may establish cleanness requirements on *a case:-by-case basis,

. consistent with the other provisions of Subpart 2.1., Appropriate cleanliness controls are.

' established for work on safety related: equipment to minimize introduction. of foreign '

'material and maintain systems/component cleanliness throughout maintenance or modification act,ivities, including documented yerification of absence of foreign materials prior to system dosure.

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B. 7

• Handling, Storage and Shipping (Continued). *. *:.

s Instead of the five-level zone designation iri Subpc1rt 2.3, control over housekeeping activities is. based on a consideration of what is necessary and appropriate for the.

• activity involved.. *.The control$ are effected through procedures or instructions that, in the case of maintenance or modification work, are developed on a case-by..,case basis.

Factors considered iri developing the procedures arid instructions include cleanliness

. coritroi, personnel safety, fire prevention and protection, radiation control and secudty.

• The proce~ures and: instructions make.use of standard janitorial anct work pra9tices to.

thE3 extent possible.

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PERFORMANCE/VERIFICATION (CONTINUED) 8.8 Test Control:

Testing programs are established and implemented to demonstrate that items subject.to the

. provisions

• of this QA TR will. perform satisfactorily in service, that the *plant c~n be operated safely and as: designed,* and that the coordinated operation of the plant as a whole is

• satisfactory.. These programs include criteria for determining when testing is required, such as proof tests. before installation; p*re-operational tests, post-maintenanqe tests, post-modification tests, inservice tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design interit.

Programs.also **include provisions for establishing and adjusting test

. schedules and maintaining status for periodic or recurring tests. Tests are perforrn9.d accordi_ng to applicable procedures th.at include, consi~te11t with the effect on.safety, (1)* instructions arid prerequisites to perform the. test, (2) U$e of proper test equipment, (3) accept_ance critE:Jria, and (4) mand!;ltory verification point$ as necessary to confirm satisfactory test completion. Test results are do.cumented and ev*aluated by. the organization performing the test and reviewed by

• the appropriate authority having responsibility for the.item being tested. If acceptance. criteria are not met, retesting is performed as :needed to confirm acceptabllity following correction of the system or equipment deficiencies that caused the failure.

In establishing provisions for testing, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 11 arid Supplement 11 S-1..

8.9 Measuring and Test Eguipment Control

• Provisions are established and implemented to control the calibration, maintenance, and use of

• measuring and test equipment, including installed plant instrumentation, that provide information important to safe plant operation.. The pr()visions cover equipment such as indicating and actuating instruments and gages, tools, ref~rence and transfer standards,* and nondestructive examination equipment. The :provisions assure that:

• Measuring and test equipment is calibrated at specified intervals on the basis of the item'_s required accuracy,.intended use, frequency of use, and stability characteristics or other conditions affecting its performance. Alternatively, equipment may be calibrated immediately before and after use if a defined interv~I is not appropriate.

Measuring. and test equipment is labeled, tagged or otherwise controlled to indicate its calibration stat.us and pro\\/ide traCe?bility t6.calibration* test data or records...

• .. Calibrations are performed-against standards that have. an accuracy of at-.least four times. the required accuracy of the equipment being

• calibrated.

When this is not possible, the standardi:diave an accuracy that ensures the equipment being calibrated

. will be within the required tolerance.

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• PERFOR.MANCENERIFICATION (CONTINUED) 8.9

. Measuring and Test Equipment Control (Continued)

Where possible, calibration standards are traceable to: appropriate national standards.

Calibration standards have greater accuracy than the standards being calibrated, except

.. where the same. aq:uracy as the instruments. being calibrated can be shown to be.

adequate for the service requirements. *

• . rvleasuring and test equipment found out of calibration is tagged or segregated and not

.. *. i.Jsed until it is successfully re-:calibrat_ed. An evaluation is performed to determine the.*.*

acceptability of any items measured, inspected or testecl with an out-of-calibration device from the time. of the previous calibration.

.... In establishing provisions for control of measuring and test equipment, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 12, Supplement 12S-1 and Subpart 2.16

. for. establishing appropriate requirements for calibration and:. control*.of measuring and test

• equipment, including installed plant instrumentation, with the following exception:

Se.ction 5.5 of IEEE 498-85 (NQA-1, Subpart 2.16) requires all M&TE to be labeled. As J

stated above, plants may not label-certain M&TE, such as installed instrumentation, but provide other means of identification so appropriate controls can be implemented. This exception also applies to Section 7.2.1 of IEEE 336-85 (NQA-1, Subpart 2.4). *

• 8.10 Inspection, Test and Operating Status Measures are established and implemented to identify the inspection, test and operating status

. of items arid components subject to the provisions of this QA TR in order to maintain personnel and. reactor safety* and avoid unauthorized Operation of equipment.

Where necessary to *

• preclude inadvertent bypassing of inspections or tests, 6r to predude inadvertent operation*,

these measures require the inspection, test or operating. status be verified. before release;

. fabrication, receipt, installation, test or Lise.

These measures also establish the necessary authorities arid. controls for the application and removal of status indicators or labels.

Equipment control provisions for workmen's protection comply with applicable federal and state

• OSHA regulati<5ns. -

~

. In establishing measures for control C>f inspecti_on, test cind operating status, NextEra Energy.

. commits to compliance with NQA~ 1, 1994, Basic Requirement t4.

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• . PERFORMANCENERIFICATION (CONTINUED).

8.11 Special Proc~ss Contr()l:

• Provisions are established and implemented to. assure that special processes that require

. interim process controls to assure quaiity, *such as welding, heat treating, chemical deanihg, and nondestructive examination, are controlled: These provisions include assuring that special * *

processes are accomplished by qualified person*nel using qualified' procedures ar:ic/ equipment..

Special processes

• are performed iri.

• accordance with *. applicable codes,* standards,

-specifications; criteria or other specially established requirements. Special processes are those where the results are highly dependent on ttie control of the process or th~ skill of the. operator, or botti;*and for which the specified quality cannot be fully and readily determined by inspection or test of the final product.

In establishing measures for the control of special processes, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 9 and Supplement 9S-1, as well as the

• applicable AS.ME Boiler.and Pressure Ves.sel Code provisions established via 10CFR50.55a.* -

. 8.12 Inspection.

Provisions are established and implemented for inspections to assure that items, services and activities affecting safety meet established requirements and conform to applicable documented instructions, procedures and drawings.* Inspection rnay also be applied tb items, services. arid activities affecting plant reliability. Types of inspections may include those verifications related to procurement, as discussed in Sections B.4. and B.5, such as source, in"'.process; final, and receipt inspection, as well as maintenance, modification, in-service, and operational activities.

Inspections are carried: out by properly qualified persons independent of those who performed

_* or directly supervised the work:

Inspection planning (for those act_ivities subject to inspection) identifies the characteristics and

. activitie.s to.* be inspected,

• the

• inspection techniques,. the acceptance criteria and **the

. organization responsible for performing* the inspection. Inspection planning identifies required hold points, beyond which work is not to proceed without the consent :of the inspection '

organization.. Provisions for ASME Boiler and Pressure Vessel. Code Authorized Inspections

. are includ(:}d when required.

lnspecti~:m results are docu*mented by the inspector and approved by authorized personnel. If

• * *

• acceptance criteria are notrriet, corrected areas are reinspected.

- In *establishing inspection requirements, NextEra Energy commits to compliance* with NQA-1, 1994, Basic Requirement 10, Supplement 10S~1 and Subpart iA. In addition, for.situations comparable to original construction, NextEra Energy. commits _to. compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspectiqn requirements.

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• P.ERFORMANCEJVERIFICATION (CONTINUED)*

8.13 Corrective Action Provisions are established.. arid implemented to assure* that personnel have both

• the

. responsibility-*and authority to identify. conditions* adverse to quality, and the opportunity to suggest, recommend or. provide solutions to resolve-the condition.

Provisions also include verification of resolution of significant issues (see also Section A.6). *

• Reworked, repaired and replacement items are inspected and tested* to meet the original inspection or test requirements, or appropriately specified alternatives (see also Sections 8.8.

and 8.12).

• If evidence *indicates that common components. in. safety relc:1ted systems have performed.

... unsatisfactorily; cqmpens6ltory or ce>rrective measures are planned prior to. replaceh1ent or repair of si:.u;h components. Replacement components receive adequate tes_ting or are of a design for :which

• experience indicates a high.* probability of satisfactory. performance.

Consideration is given to phased replacement to permit inservice performance to be evaluated and minimize the possibility of systemic failure. *

• 1n establishing provisions for corrective action and control of nonconforming* items, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirements 15 and 16, and.

Supplement 15S-1.

8.14 Document Control

. Provisions are established -and implemented to specify the. format and content (see Appendix B for procedures), and control the development, review, approval, issue,

• use and revision,* of documents that specify quaiity requirements or. prescribe activities affecting quality or safe operation to a~sure the correct documents are.being employed.: These provisions assure that specified documents are revieweq for adequacy; approved prior to use by authorized persons,

arid distributed accorc:::ling to current distribution lists and

• used at the location where: the

. prescribed activity takes place*. Procedures governing power plant activities (see Appendix B) are reviewed by qualified persons, *other than the preparer, as designated by the Site Directors.

Such procedure reviews include a determination whether additie>nal cross-discipline reviews are required a_rid Whether a* Plant Technical Specification change or other NRG approval is required.

Only safety related procedures and procedures important to safety as used in 1 OCFR71. and 72 require this review.

Provi.sions iricrude establishing levels of* use, such. as requiring the document to be present at the work location. Documents subject to control provisions include, buf are not limited to, drawings (design, as-fa1ilt), engineering documents (calculations, anaiyses; specifications, computer codes, Updated Final. Safety. Analysis - Reports,. Plant

• Tech*n-ical Specifications), and procedures (administrative, operating, emergency:operating, *

• maintenance,

• calibration, surveillance, inspection, test).* Other documents; such

• as: those*

• relsted to procurement, corrective actions, and assessments, : c:1re control.led as d~fined by the provisions and commitments cit~d in those.sections of this* QAl'H.

Controlled copies of instruGtions andprocedlires are mad~ available to and l,!Sed by tt:ie pen~ons performing the.*.

activity covered. New or revised.controlled documents are made available in a timely fashion to support ongoing work. and preclude use* of incorrect information. Superseded documents are

• identified or removed from availability. Each site maintains documentation that describes how

• implementing documents are maintained to assure that QAP requirements are met arid are not

. inadvertently removed in later revisions..

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• .Quality Assurance Topical Report (FPL-1) e; PERFORMANCENERIFICATION (CONTINUEO) 8.14: **Document Control.(Continued)

. Revisions to controlled documents are reviewed for adequacy and approved for release by the

. same organization(s) as originally did s.o, bt' by other designated organizations th:at are qualified..

and. sufficiently knowledgeable of the reqt1irements:. ahd intent of the*. original. document.

Programmatic procedure preparation, review and u~age *controls are established that enst1re

. procedures are tech11ic~lly and administratively correct. These control~ ensure that procedures

. are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusual incidents occur, 'when plant modifications are made,. arid when.

.. significant deficiencies are identified, Procedures may also be reviewed because industry experience reviews: use during job execution or training, self-assessments or: independ~nt assessments identify deficiencies or opportunities for improven,ent. Revisions are.made as.

• .. necess~ry. Emergency operating: prClcedur~s. off-non:n.al procedures, and. procedures which

• . implement ti)~ emergency plan are exercised on* the simulator or revi~wed at least once every f:wpyears arid revised. as appropriate.

.. The Site Directors may designate specific procedures or classes of procedures in writing to be

• reviewed by qualified reviewers in lieu of review by the ORG. Review by qualified reviewers shall be in accordance with implementing procedures. In addition, 10.CFR 50.59 and/or 10 CFR72:48 reviews are performed on designated procedures, including subsequent changes, to. *

• . determine if *

• NRC review and *. approval is requ_ired prior to* implementing the

. procedures/changes..

Procedures required by Technical Specifications shall.be approved by the Site Directors or by: *

. cognizant managers or other supervisory personnel prior to implementation as specified by administrc1tive, requirements. ** The approval authority for*.specific procedures or* classes

• of

. procedures shall be designated in writil)g by the Site Direct9rs:

Temporary changes to approved procedure~ that do not change the intent are approved by two members.of plant $taff knowledgeable in the areas affected by the procedure. Additionally for

. temporary changes to *approved procedures identified in Appendix B.of this QATR, at least one of the two approvers musfhold a senior reactor operator's license. Temporary changes are documented, reviewed by the ORG or by a qualified reviewer, and approved by the. designated

approval authority within 14 :~ays of imJilementation. If appropriate, *temporary.changes are

. incorporated in the next revision of the procedure.

In. establishing provisions for document control/ NextEra Energy commjts to* compliance with NQA-1, 1994, Basic Requirement 6 and SL1pplement6S-1.....

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-B'.15 Records Provisions are established and implemented to ens-ure that sufficient records of items

• and

. activities. affecting _ quality are generated and_ maintained to reflect

• completed work.

Such records may include, blit are not limited to, design, engineering, procurement, manufacturing,

- construction, inspection, test, installation, modification, operations, maintenance, corrective

• action, assessment, and associated reviews. The provisions establish requirements for records

. administration, including generation, receipt, preservation, storage, safekeeping, retrieval arid final disposition. _ For activities governed by 1 OCFR71 or 72, these provisions address the* *

• specific requirements of sections 71.135 and 72.174. In establishing measures for the retention of security records, NextEra ~nergy commits to compliance with NQA-1 1994, Basic Requirement 17 and Supplement 17S-1, as_well as the applicable portions of 10_ CFR 73._

established via 10 CFR 73.55 (q) and 10 CFR 73.70.

The list of records in_ 10CFR71.135, 1QCFR72.174, and Non-mandatory AppendJx 17A-:-1,

-supplemented by the recommended retention times_ established _ in Regulatory Guide 1.28, Position C.2 (Table 1), are.. used to establish the types of records that will be created and

. retained in support of plant operation. Non~mandatory Appendix 17A-1 of NQA-1-1994 lists.only those operations phase records having permanent (lifetime) retention; Regulatory Guided.28, Table 1, which provides for lifetime, 3, and 10 year (non-permanent) retention periods, does not specifically list operations phase record types. Appropriate retention times are established for

-non-permanent operations phase record_s_ based on similarity to the same record types identified in Table 1 of Regulatory Guide 1.28. Thus, non-permanenhecords are designated for 3 or 10 year retention, as required by NQA-1-1994, Supplement 17S-1, Sections 2.7and 2.8. In cases.

where local or state retention requirements are more restrictive than the regulatory guidance, the local requirements are met. Records* of the service lives of all snubbers including the date at which the service life commences and associated installation and maintenance records have lifetime retention:*

In addition, when using optical or electronic records storage and retrieval systems, NextEra

_ Energy complies with NRC guidance in RIS 2900-:-18.

In establishing provisions for reGords, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 17 and Supplement 17S:c 1, with the following exception:

• - Supplement 17S-*1, Section 4.2(b) requires records to be firmly attached in binders or -

• placed in folders or* envelopes for storage in steel file cabinets or on shelving in

• containers. For hard-copy records maintained by plants, the records are suitably stored in steel file cabinets or on shelving in. containers, except. that methods other. than

. binders, foiders or envelopes may be used to organize the rec:ords fo_r ~torage...

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• PERFORMANCENERIFICATION (CONTINUED) 8.16 Plant Maintenance Controls are established for the maintenance or modification of items and equipment subject to

. this* QATR tel' ensure quality at least equivalent to that specified in original design bases arid requirements, such that safety related structures, systems and components are maintained in a

• * *

• manner that assures their ability. to* perform their intended safety function(s).

Maintenan.ce

-pCtivities (both Corr~ctive and preventive). are scheduled and. pl~nned SO as not tQ unnecessarily

-compromise the safety of the plant.

Permission to release. equipment. or systems for maintenance is granted bY: designated operafillg personnel who are responsible to verify that

-. : the equipment or system can be reieased and determine how long itmay be out of service.

• This includes attention to the potentially degraded degree of protection when orie subsystem of a redun_dant safety system has been removed for main_tenance.. Release is documented,

• When equipn,ent is ready to be

• returned to service,. operating personnel place *the equipment in operation and verify an.d document its functionar acc~ptability. In completing maintenance and restoring equipment, attention is given to restorati.or:i. of normal conditions, such as removal of jumpers or signals used. in maintenance or testing, or such as returning valves, breakers or.

.. switches to proper operating positions:

lri establishing coritrois for plant maintenance, NextEra Energy commits to compliance with NQA-1, 1994, Subparts 2.16 and 2. 18, with the following. exception_s:

• Section 5.5 oflEEE 498~85 (NQA..:1, Subpart 2.16) requires all M&TE to be labeled. As stated in QATR Section B.9, plants may not label certain installed instrumentation, but provide other means of identification so :appropriate controls can be implemented. This exception also applies to Section 7.2.1 of IEEE 336.,85 (NQA-1, Subpart 2.4).

Subpart 2.18,. Section

• 2.3.a requires. cleanliness during

• maintenance to be in

• accordance with Subpart 2:1.

• Commitment to 8ubpart 2. t is described in Section B. 7.

Subpart 2.18, Section_ 2. 7 requires the application. of Subparts 2.4, 2.5 and 2.8 for inspections. of instaUation activities: Commitment to Subparts 2.5 and 2.8 is ljmited to.

. : activities comparable in nature and :extent to *those during original construction (see s*ection 8.12). Inspections (verifications) of maintenance or modification activities are established, *conducted and documented as. required by Section B.12. to establish a suitabfe level of confidence in affected structures, systems, or components.

The

--__ inspection criteria* _in Subparts 2.5 arid 2.8 may be usecJ in establishing rElquired inspections for maintenance and minor modifications, _

. *. 8.17 -

Computer Software Control Provisions ar.e estabiished and implemented to. assure.. that computer software used. in applications affecting safety is prepared, documented, verified a_nd tested, and used such that.

the expected output is obtained and configuration contra.I maintained. To. this erid, NextEra Energy commits to compliance with the requirements of NQA-+ 1 1994, Supplement 11 S-2. arid Subpart 2:7 to establish the appropriate provisions.-. *:

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.

• ASSESSMENT C.1 *

• Methodology.

• Programs* are. established tor..reviews and assessments to. verify that activities covered by this QATR' are perform~d: in compliance. With' the r~qliirements' established, review significant '

proposed plarit changes or tests, :Verify that reportabl~ events are promptly investigated. and.

• corrected, and detect trends which may not be* apparent to.the day-to-:day observe( The.se*

• programs: are, themselves, reviewed 'fof effectiveness as part of the overall assessment

. processi as described herein.

Self-assessment is used (performed by or for the. group responsible for the activity being a:ssessed) a11d independent assessment {performed by the Nuclear Assurance organization) to monitor: overal.1 perforrhan9e, identify anomalous pe,rformance and precursors of potential

• . problems, and verify satisfactory resolution of problems... persons responsible for c~rryjng out. :

. these assessments ~re cognizant of.d<;ty-to-day activities.: such* that they c~m act in *a manageme'nt. advisory function with respect to the. scope of the assessmerit.

Both self-assessments and independent assessments. are accomplished using* instructions or pro.cedures

' that provide detail. commensurate' with the' assessed. activity's' complexity and importance to ' '

safety.

• The plants mai.ntaiil on-site :review groups to review overall plant performance and advise site

• management on matters related to nuclear safety. Appendix A establishe::flherequirements for

. these committees..

. '*1 Independent reviews are periodically performed of matters involving the safe operation* of the

fleet of nuclear power plants, with a minimum of one such review being conducted for each generating site each year. The. review addresses matters that plant and corporate nianagemeht

' determine warrant 'special attention, such as plant' programs, 'performance tr~hds, employee concerns, or !Tiatters related to safe plant operations.

• The review is performed by a team : *

• . consisting of personnel. with* exp~rience and *competence: in th~

• activities

• being reviewed, but

. independent '(from cost and schedule.considerations) from,the organiiationsTesponsible for those activities.

The review is supplemented by outside consultants or organization*s as necessary to *ensure the* team has* the requisite expertise and *competence.

Res.alts are..

' documented and reported to responsible management In establishing the,independent assessrileilt program, N.extEra Energy commits to compifance.

with NQA-1, 1994, Basic Requirerri~nt 18 and Supplement 188-1, with the fQlldwing clarification: :

The form "audit" and :"independent assessment" are *synonymous and may be used interchangeably.

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. AS.SESSMENT (CONTINU~D). *.

C.2.*

Self-Assessment

Self~assessments performed by or for the group responsible for the activity beitrg assessed are' osed to identify anom~lous performance and precursors of potential' problems.. When line organizations.perform self-assess111ents, their focus is technically and performance oriented.

• : with focus on. the quality of the end* product as weU as on compliance with procedures.a.nd processes. The objective of self.:asses~ment is tq verify co111pliance, i111prove performance: and achieve.excellence. Results of self-assessments. are reported in an understandable form and in a timely: fashion to a level bf management having the authority to effect corrective action and verify. satisfactory resolution of problems.

C.3 Independent Assessment A program* of planned.and periodic performance-based independent assessments has* been

• established to monitor overall performance and confirm. that activities affecting quality comply.

with the. QAP and that the QAP is effectively implemented.. The organization performing.

independent assessment (Nuclear Assurance) is technically and performance oriented, with its

• focus on the quality of the e*nct. product and the effective implementation of procedures and processes. Persons performJng independent assessments do not*have direct responsibility for any area being. assessed,. and do not report to a*: management position with

• irrin:iediate

. responsibility for the activity being assessed. Assessment. resources may be s.upplemented with technical specialists as needed. The independent assessment program will be reviewed at

• least semiannually through one of the following: an Independent Evaluation of QA/QC, review*

by a designated management representative, or review by a designated management review

• body.

The* independent* assessment program provides comprehensive independent evaluations of activities* and procedures. Planning for independent assessments identifies the characteristic;s *

. and* activities to be assessed :and the* relevant performance. and/or acceptance criteri<;t. As

. appropriate to the. scope of* an:* assessment, these criteria* include* related, plant Te<;:hnical Specification requirements, Independent assessments are. then conducted using these predetermined criteria...

. An independent biertni~I assessment includes an* ~xamination of selected procedures tq verify.

that the procedure review and revision controls of Section 8.14 are effectively implemented.

• Results of independent assessments are reported iri an understanda.ble form::and in a timely fashion.to a* 1evel of management hav1rig. the authority to effect corrective action.. Nuclear Assurance conducts timelY follow~up* action, illcluding re-assessment of deficient.areas, as '

necessary, to establish adequacy of corrective actions:

L

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. C. *.

• ASSESS.MENT (CONTINUED):

C.3

. lndef?endent Assessment (Continued)* *

. Independent. assessment results are: documented. and:* reviewed* by Nuclear, Assurance

. management. and by management having. responsibility for the area assessed...

• in addition, Nuclear. Assurance activities are: periodically assessed for. effectiveness.

RE:ls(!lts are *

• doc;:umented and reported to responsible management. *

, Nuclear.Assurance provides,for assessment of wcirk carried out under the requirements. of the QAP th~t is delegated to other (nori-:NextEra En~rgy) entitles.

Independent Assessments are performed on a fixed frequency...

... * *. lndepe,ndent Assissments qf the *topics in Tabl~ 1 are aµditeda(least biennially. :.A 90-day grace peri.od may be applied to these hpn-regulatory. topics in execu~i,ng this periodicity. When the.. grace period is applied, the next

• due date for the activity is based upon

• the original

• scheduled date.. However, in all cases the periodicity.shall not exceed two years plus 90 days.

Certain activities, as identified. in. Table 2. (Regulatory Topics), receive independent assessments. *at frequencies established by related NRC rules. A grace period shall not. be applied to these regulatory topics unless permitted by. the NRC rule.

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• • ASSESSMENT (CONTINUEP) *..

C.3 * * :

• Independent Assessment (Continu.ed)

• Table 1 Topics_Subjectto Independent Assessment;with QATR DefinedFtequency

,.'l~}l;1'.itj

[~/{l;~fi

>x** :

' *.,.,,,,.,.. ~,.*.....,.~,

Chemistry, Effluents & Environmerital.,

Monitorina Engineering. *

• Maintenance/Work ManaQement Nuclear Assurance Operations I

• Performance Improvement

. Procurement & Nu.clear Materials Management QA Programs.*

• Radiological Protection.& Radwaste

• Trainini:t ** *

.Table 2.:

• Topics Subject to Independent Assessment with Regulatory Defined Frequency

1. Topic titles in these tables _may va_ry; however, all* program elements (Le. applicable regulatory req1Jirements and al.I 10. CFR 50 Appendix. B crite*ria) will be c9vered as identified in irnplemenfin~ procedures.

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. APPENDICES Appendix A: Ori-Site Review Group

• 1~0 General The Ori-:Site Review Group (ORG) is responsible to the Site Directors for advice on all plant-related matters concerning nuclear :safety.. The requirements. for personnel,* committee com'position, meeting frequency, quorum :~md meeting records are identified in implementing procedures. A general description of.these areas is ineluded bel()W. '

(Note: Each plant may name this on-site review group function differently. Regardless of t.he name, theserequiremerits are met.)

In discharging its independent review responsibilities, the ORG shall keep safety considerations

.. paramount when opposed to cost or schedule considerations. Should a voting member at a

'particular meeting have direct responsibility for an item under review where a conflict of such

• considerations is likely, that member shall beJeplaced (to fill the quorum) by another voting member not having such potential conflict.

• 2.0 Composition The ORG ls comprised of a minimum number of members as designated by the Site Directors and detailed* in implementing procedures.

All members' are qualified in accordance with impl~menting procedure requirements that meet site. Technical Specificcitions.

Membership*

includes representation from at least the following disciplines: Operations, Maintenance; Engineering! Radiation* Protection and Chemistry. The ORG collectively-has, or has access. to, the experience and* competence necessary to review the* areas of :(1) nuclear power plant operations, (2) nuclear engineering;,(3) chemistry and radiochemistry, (4) metallurgy, (5)

• nondestructive testing, (6) instrumentation arid control, (7) radiological safety, (8) mechanical

. arid electrical engineering, (9) administrative controls and quality assurance practices, and *(10) other fields associated With the Unique characteristics of the :plant. Consultants. may be utilized to provide expert advice as heeded.

• Alternate chairmen*.and members may be appointed by: the Site Directors. to

• serve

• on a

. permanent or temporary basis.

3.0 Meetings.

The ORG meets commensurate with th_e scope of activities, but niiili_mal frequency requirements

• are specifieq in procedures. *

• Rules for a quorum are established and adhered to.

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Appendix A: On-Site Review Group (Continued)*.

4.0 RevJew

. The ORG reviews at_ least the following:

(1).

(2).

(3)

(4)

(5)

(6)

(7)

(8)

(~)

(10)

. (11)

Change~ to the Offsite Dos~ Calc.ulation M_anual (ODCM) and ttie Process Control

• Prograrn (PCP). In additiori; changes to R.adwaste Treatment Systems are reviewed

• for St. Lucie and Se.abrook Plants.

Pro"posed tests or experiments that affect nuclear safety..

. Proposed changes or modifications to plant systems or equipm~nt that affect nucl~ar safety..

• Written 1 OCFRS0,59/72.48 evaluations to verify that changes to the facility or

procedures; tests

• or experiments do. not involve a change in*. the Technical Specifications or require prior NRC review.

• Proposed changes to Operating License. and Technical Specifications..

Reports covering violations *of applicable NRG statutes, codes, regulations, orders, Technical Specifications,. license requirements or of internal* documents* having nuclear safety significance.

Reports of special reviews and investigations as requested by the-Site Directors.

. Events reportable in:Writing to the NRC according to applic<Jble *regulations.

Reports of significant operating abnormalities or deviations from the nmmal anq

• expected performance of plant equipment or systems that affect nuclear s_afety.

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

Review of any accidental, unplanned, or un~ontroHed radioactivity release.

(12).

Any other matter related to nuclear safety requested l;>y* the Site Directors, selected (13)

. (14)

_by ORG members: or referred to the ORG by other site or *co~porate Clrg~nizations:

(

. Review of. Diesel

• Fuel Oil. Testing Program and. implementing procedures (Turkey.

Poirit Qnly)

• Review arid;_documentation of judgment t:oncerriing proloriged operation in bypass, chanm~I

• trip, and/or repair of defective protection channels

• of. process v_ariables..

placeo.in bypass since the last ORG meeting. (St. Lucie qnly)

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Appendix A:*

• On-Site Review Group (Continued)*.*

• 4.0

-\\.

Review (Continued)*

Reviews of Items (6) through (12): include results of. any investigations made and recommendations resulting from

• such jnvestigatR:111s to. prevent or reduce the probability* of recurrence of th_e event..

• 5.0

• Authority TheORG:

Rec.om.mends in writing to the Site Dire.ctors approval or disapproval of items reviewed.

Renders determinations in wdting with regards to whether* Items (1) through (4), :or changes thereto, require prior NRG approval i.n accordance with 10CFR50,59/72.48.

Provideswritten notification to level(s) above the Site'Directors of any disagreements between theORG.and.the Site Directors.

The ORG shall advise. the Site Directors _on matters related to safe operation *and overall

. performance. The ORG has authority to obtain access to records and personnel as needed to conduct reviews.

. In carrying out its review responsibilities,. the ORG may establish subcommittees or use designated organizational units. to carry out the review. The subcommittees or organizational

. units ml!st regularly report. results of reviews for full.committee consideration and*. may recommend items*tor full committee review as wi:lrranted.

• 6.0

• Records

• The ORG maintains written* minutes of each ORG meeting, to include identification

• of items reviewed, arid decisions and recommendations ofthe Committee. Copies of the minutes are provided,to the on-site and. off-site management position(s) above the Site Directors,. and to

.. * *. othef. management responsible for. the areas revieweq. as necef.sary... ORG records are

• retained accqrding to Section 8.15.

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Appendix B: Procedures Procedures are used to provide an approved, preplanned method of conducting

• activities

• *. affecting safety.

• As stated in Position C.1 : of Reguiatory Guide 1.33, Revision 2, NextEra Energy commits to* use Appen_dix A of Regulatory Guide 1 :33. as guidance for establishing* the types of procedures that are necessary to *control and support plant operation. Procedures are sufficiently detailed for a qualified in.dividual

• to perform the required function with.out direct * *

• supervision, but may IJOt provide a comph::~te. description of the system or plant *process.

• Guidance is* established to. identify the manner, in. which. procedures are to. be implemented, including identification of those tasks that require (1) the written p'r.ocedure to be present and

• followed

• step by step while the task is being. performed, * (2) the user to have commH:t:ed the*

• procedure steps to memory, (3) verification of completion of significant steps,* as by initials or sigriatures or lJSe of check-off lists. Proceduresthat are required to be present and referred to..

directly are those_qevelopec:l for extensive or cornplex jobswhere r~li_ance on r:nemory ca.nnot be

• trusted, task~*that are infrequently performed, and tasks where steps must be performed in a specified sequence:

When documentatioo of an action is specified, the necessary data.is

• recorded as the task is performed:

. The format of procedures inay vary from plant to plant; however, procedures include the following elements,<as* appropriate to the purpose*.or task covered. These elements are. not

' intended to imply _a* specific format is required:

Title/Status::.Each procedure is given a title descriptive of. the work or subject

• it addresses, and includes a revision number and/or date and an approval_status.

Purpose/Statement of Applicability:* The purpose for which the procedure is intended is dearly stated (if not clear from the title).*.

References:

Applicable references;

• including: reference* to appropriate** T~chnical Specifications, are included. References are included within the body of the procedure when: the seque*nce of: steps requires otl)e*r

• tasks to: be performed (according.to* the

. reference) prior to or concurrent with a particular step.

• Prerequisites:

Identifies. those independent actions or

• procedures that must be accomplished and plant conditions: which must exist prior to performing the procedure.

A prerequisite applicable to only a specific portion of a procedure is so identified, Prec:;autions:.. Alert* the. user to those important measures to be

• used to protect equipment and :personriel, including the public, or to avoid an abnormal or emergericy situation during. performance of the procedure. Cautionary notes applicable to specific

. steps are included in_ the main ~ody of the procedure and are. identified as such:_**

Lirhitations : and Actio11s:

Limitations. on the : :parameters. being : *controlled. cirid appropriate corrective measures to return the par~meter to the norrrial control band are specifiec;f..

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Appendix e:=. Procedures (Continued) *.

. Main Body: Contains the step-by-step instructions 'in the degree of detail necessary for

• performing the required function or task. '

Acceptance Criteria: The quantitative or qualitative criteri.a against wh16h the success or failure (as of a.test-type activity) of the s!ep or action would be judged.

Check-off Lists: Complex procedures us$ check-off lists (aka checklists)*Which may pe included as.part of the procedure or appended to it..

Certain. types, of. *procedures governing generating site activities. are common. to all plants.

Individual. plant terminology may vary from the following, and some* procedure types may* be

• combine3d.

sufficent 'procedurei ar19*maintained t6. provide appropriate, di.rection for. these.

activities.

In amplification. to the *appropriate* '3lements. above,. Sl,f Ch procEldures are. further defined as follows:*

Calibration and Test Procedures:. Contain* instructions for periodic calibration and testing of.safety related instrumentation and control systems; and for periodic calibration of measuring and test equipment used in activities affecting the quality of. these systems.

These. procedures provide for meeting surveillance: requirements arid. for assuring

... measurement accuracy adequate to keep safety related parameters within operational

. and safety :limits.

• Chemical-radiochemical Control* Procedures: Contain instructions for chemical and radiochemical activities such as the nature and frequency *Of sampling and. analyses;

• maintaining coolant quality* within prescribed limits; limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaceis or become sources of radiation _hazards d.ue to activation; cor:itrol; treatment and management of radioactive wastes and control.bf radioactive calibration sources, including shipping.

Emergency Plan Implementing Procedures: Contain instructions for activatiog the Emergency. Response

• Organization and. facilities,. protective action levels; organizing

• *

• emergency response actions; establishing necessary communications with local, state* *

• and federal agencies, and for periodically testing the procedures,. communications and alarm systems to assure they function properly. Format and content of such procedures are such that requirements of each site's NRC approved Emergency Plan* are met.

• Emerge*ncy Procedures:. Contain instructions for response to potential emergencies so

• that a trained operator. will know in advance the expected course of events th.at will identify an emergency' and the immediate actions that should be taken in response.

• Format arid content* of emergency procedures. are based on regulatory arid Owner's.

• Group( s) guidance that. identify. potential.emergency. ~onditions and* generally

• require such procedures to inc::lucle a title, symptoms to aid in identification of the nature of.the

.emergency, automatic actions to be expected from protective. systems, immediate.

• operator actions.fot operation of controls or co:nfirmation.. of automatic actions, and

• subsequent.operator actions to return the.reactor to.a normal.condition or provide. for a safe extended.shutdown period under abnormal or emergency conditions..

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Appendix B: Procedures (Continued)

'Fuel Handling Procedures: *Contain *instructions*for core alterations, accountability of '

fuel and partial <;fr complete refueling operations that include, for example, continuous monitoring-of neutron flux throughout co:re *1oading,* periodic data recording, audible ar:munciation* of abnorrrialflux i_ncreases,. and evaluatioi1 *of corEl neutron multiplication to.

verify safety of loading increments:.. Procedures are also provided for re,ceipt and inspection *of new fuel, and for fuel,movements irf the. sperit fu.el storage areas: Fuer handling procedures include pref~quisites to verify th~ status of. systems required for fuel

. handling and niovemerit;

• inspection of replacement.fuel and.confrol rods; designation of

• *. proper fools, proper conditronS: for spent fuel movement, proper conditions for fuel cask '.

' 'loading aiid movement; and status of interlocks, reactor. trip' circuits and mode switches.

These procedures provide requirements for, refueling, including proper sequence,

.c,rientation and seating of. fuel *and 'components,.rules for mi,nimurtl operable '

instrumentation, actio.ns for response tq fuel dam~ge, verification qf shutdown* rnargin; cornm1mication~ between the control room and the fuel haridling*,statiqn, indepenr;lent verification offuel and.componenUocations, :criteria for stopping.fuel movements; and

.-documentation offjnal fuel.and.component serial numbers and locations:

Maintenance Procedures:

• Contain

• instructions. in sufficient detail

• to

• permit maintenance: work to be performed correctly and safely, and include provisions for

• . conducting ' and recording results of required.. inspections or tests.

Appropriate. *

• referencing to other.procedures or vendor manuals is provided. Instructions are also provided, altho!Jgh not necessarily: in. Maintenance.Procedures;*.for equipment removal and return to service, and appropriate radiation protection measures (such as protective

. clothing aod radiaUon monitoring).

Power Operation and Load Changing Procedures:

• Contain* instructions for steady-state: power operation and load changing that.include provision*s for use of control rods,

• chemic.al* shim, cpolant flow channel control, or tor any other system available for short-

'*

• or long.:term cqntrol of reactivity, rnaking peliberate. load changes and* adjusting operating par~rrieters..

. P~ocess

• Monitoring, Procedures: Contain instructions for monitoring performance of*

plant systems to.assure that core thermal marglns and c.oolant quality are maintained in acceptable status at all times, that integrity otfission product barriers is tnaintaine9,

• and

_that engineered safety features and emergency equipment are in a state of readi.ness to

• * : keep th¢ P.lant in a safe con.dition if needed. M~ximum and* minimu,tn limits for process paranJeters: are appropriately identified.**

. Radiation Control. Procedures:. Contain. instructions. for implementation of program requirements neeessary to* meet regulatory commitments.. fricludirig acquisition* of data.

'and use of equipment to perform. necessary radiation. surveys; me~surenients and evaluations for :the assessment a~d confrof of radiation hazards. Thesei procedures

. provide. requirements. for monitoring bo_th external and internal exposur:es of employees,

_ i.ltilizing *accepted. teohnique$;

• routine r~diation. surveys* of: work arei:ls; enviror:imental

• monitoring in tt:ie vicinity of the. plant; radiati.on monitoring of rnaintenance and special work: activities,. and for' maintaining. records. demonstrating the adequacy of measures

• .. taken to control radiation exposures to employees and others.*

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• Appendix 8: Procedures (Continued).

Shutdo.wn Procedures: Contain instructions for operations during controlled shutdown

• and following reactor trips, and include instructions for establishing or maintaining hot standby or cold shutdown conditions, as applicable.

The major steps involved in shutting down the piant are. specified, including instructions for such actions 'as monitoring and controlling reactivity, load re<;luction, cooldown rates, activating or deactivating equipment, and provisions for decay heclt removal.

• Check-off lists are used; as appropriate, fiJj-confirming completion of major.steps in proper sequence.:

Start-up Procedures:

Contain instructions for starting the reactor from cold or hot conditions and estabiishing power operation.. This includes. documented determination that prerequisites have been met, including. confirmation that necessary instrumentation is operable and properly set; necessary system procedures,. tests. and. calibrations have..

been completed; ahd required approvals have bel:ln obtained. The main body includes.

the major steps of the start-up sequence, i11cludirig rE3ferenGe to appropriate systems procedures.*: Start-up procedures contain check-off lists where appropriate..

System

• Procedures: Contain instructions for energizing, filling, venting; draining, starting up,. shutting down, changing modes of operation and other* instructions appropriate for: operations of systems related to the saftey. of the plant.

Separate procedures may be developed for.correcting off-normal. conditions. for those events where system complexity may 1.ead to operator uncertainty.. System procedures contain check-off lists.where appropriate.

(

Test and Inspection Procedures:

Contain the objectives, acceptance

• Criteria, prerequisites for performing the test or inspection, limiting conditions; and appropriate instructions for performing the test or inspection. These procedures also specify ariy special equipment or calibrations required to conduct the test or inspection-and provide for appropriate documentation aryd evaluation by responsible authority to assure test or

• inspection requirements have been satisfied..Where necessary, hold or witriess points are identified within the procedures and

• require appropriate approval* for:* the work= to continue beyond the designated point. These procedures providefor recording the date,

• *

• identification of those performing the test or inspection, as~found condition, corrective*

actions performed (if any), and as-left condition, as appropriate for the subject test or inspection.

While

• not specifically a. procedure *type, Temporary Procedures may be used to direct

• operations during testing, refueling,

• maintenance and modifications; to, provide guidance. in uriusual situations riot within the:scope of normal procedures; and to insure orderly and uniform

. 6pefrations for short periods wheri the plant, a system; or a component of a system is performing in a nianner not covered by existing detailed *procedures; or has been modified or affected in.

. such manner that portions of existing procedures do not apply.

• Temporary Procedures include de~ignation of the petibd of time d_uring which they may be used.

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. Appendix C:. Defi"°'itions The definitions of.terms as provided iri Section 4 of the Introduction of NQA.:f 1994 are used in. *

• interpreting the requirements of NQA-1 and other standards to. which the QATR commits. lri

. addition, definitions c1re provided for the following terms not covered in.NQA-1:

• Administrative Controls: : Rules, orders, instructions, procedures, policies, practices *

• and designations of authority and responsibility.

.. Emergency Procedures:

• See Appendix B.

Experiments: Performance of plant operations drried out under controlled conditions in order to establish characteristics or values not previously known.

Independent Assessment Planned and documented activity performed to determine by investigation, examination, observation., or evaluation qf objective evidence the adequacy of and compliance with established procequres, instructions,. drawings,* and other applicable documents, and to_ determine. the effectiveness of implementation.

. independent Assessment, as used iri tliis QATR, -is considered equivalent to the terni "audit'.';

. Independent Review: Review completed by personnel not having direct responsibility.

for the work function under review whether they* qperate as pc:1rt of an organizational unit or individual ;staff members (see Review)..

I

• Maintenance and Modification Procedures:. Written procedures.defining the policies and practices by which structures, mechanical, electrical and instrumentation and control systems, and components thereof, are kept in a condition of good repair or efficiency so that_ they are capa?le of performing their intended furictions.

Nuclear Power Plant: Any plant using a nuclear reactor to produce electric power; process steam or spac~ heating:*.

Off normal Condition Procedures: Written procedures which specify operator actions*

for restoring an operating variable to its normal controlled value when it departs from its range, or to restore normal operating conditions following a perturbation.. such actions

. are invoked following an* operator observation or an annunciator alarm indicating

• a condition which, if not corre¢ted, could degenerate into a condition requiring action under an emergency procedure.. (May be called Abnormal, Off.,normal or other term conveying the same intent.)

.. On-site Operating

• Organization:. bn~site personnel concerned:. with the : op~ration;

.maintenance and certain technical services..

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Appendix C: Defin.itions (Continued).

• **Operating Activities:

Work functions associated. : with normal operation and maintenance of the plant,. arid technical services routinely as~igned to,the. on-:site operating organization: '..

• 0°perating Procedures: Written proc:edures defining the. normal methods, mean? and limits.of operation of the nuclear power* plant, a plant syste*m or systems, or processes, inc:lud,ing actions to b~ taken by operating personriel:tor removal from and retum to service equipment on which maintenanc~ is to be or has been performed.

Operational Phase: That period of time during which.the pdncipal activity is associated with normal *operation of the plant.

This. phase of* plant life is considered to begin

... formally with commencement of init1al_fu~lloading c1nc:i ends with plant deconimissioning...

Quc11ity Instruction:.Any instruction or procedure that defines programmatic controls needed to implement the. Quality. Assurance Topical Report. These instructions and

. procedures consist of documents specifically identified as "Quality Instructions" and other equivalent administrative procedures and instructions.

• Quality Instructions do not...

inclu.de lower tier work procedures. or instructions where the. QA program. controls* are contained in

• other documents.

• For example, Quaiity Instruction includes the* plant procedure or instruction that defines the programmatic requirements for control. ofM&TE but not the: procedure for calibrating a particular piece of M& TE.

Quality Related:

This.classification is applied to selected equipmerit, components, structures and services designed to support and/or protect the safety function of safety

• related equipment. Quality Assurance Program elements are applied with a graded approach to. quality to an extent that is commensurate with the item's importance. to safety. Implementing documents establish*program,elerhent applicability.

These include those items or related services that are not safety related and are in one or more of the following categories:**

• Revision 22

.1; Equipment, components : and structures

• designed.. to meet

• seismic requirements or whc,se. fciilure could:

. (a) damage safety related equipment such that the *equipment would be prevented from*perforrriihg its safety function, or (b) result in releases exceeding the exposure guidelines of the Offsite Dose

• Calculation Manual.

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• Appendix C:. Definitic:>ns (Continued)

Revision 22 2. Fire protection equipment, systems and features:

(a) that minimize the adverse effects offires on safety related and "the quality related* structures, systems* and components identified in this definition, and

-(b) whose failure cir inadvertent operation could significantly impair the safety

• • .*function of $tructures, systems and coniponents; _and

_ -(c) that is required for 10 CFR 50 Appendix R compliance (10 CFR 50 Appendix.F~ licensed plants only), or (d) that is required for compliance _with the_ nuclear safety. goal and radioactive release goal of NFPA 805 (NFPA 805 license plants only).

The : above

• definition _addresses: the minimum scope of Fire Protection Equipment that is classified as Quality Related.

Site specific definitions. :

and/or commitments take precedence; 1f _more restrictive. *. (

3. A partial or total loss of.function of a radi6active* confinement system that

_ could result in: an accidental, unplanned, or uncontrolled release of

• radioactivity exceeding the Offsite Dc:ise Calculation Manual limits. *

4. Equipment whose failure undefnormal operating conditions or an anticipated

. transient, results in:

(a) exceeding a safety limit specified in theTechnical Specifications, or*

. (b) initiation of a UFSAR Design Basis Accident, or.

(c) the rea.ctor coolant system not being iri a controlled or design condition

.. while operatin~ o_r shutdown.

5.

• Instrumentation,

• equipment,

• components, or structures required to be operable by the Technical Specifications..

6.

• Instrumentation that is essential to preventing or monitoring release of radioactive material to the environment which could exceed the guideline$ of the Offsite Dose Calculation Manual.

7: Instrumentation used in post accident monitoring and classified as Category 3 :.

in response to the requirements of Regulatory Guide 1.97.. (Some Category-2 instruments :n,ay also be classified as Qu~lity Relate~,)

8.

• Items or services that are subject to unique q1,mlity assurance requirements due to specific NRC imposed reg,ulatory requirements.,

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Appendix C_:

• Definitions (Continued) -

- Review:* A deliberately critical examination, including observation of plant_ operation, -

evaluation of assessment results, procedures, certain comtemplated actions, and after-the-fact investigations of abnormal conditions.

- Supervision: Direction of personnel activities or monitqring of plarit functions by an' *

• individual responsible and accountable for the_ activities they direct or monitor.

_ Surveillance Testing: Periodic testing to verify that safety related structures,_ systems

. and components continue:to =tunction or are in a state of readiness to perform their

.. functions, and to -~>rovide assurance that failures. or substandard performance do not remair, undet~cted and that the required reliability of safety related systems is maintained. Such functions include keeping parameters wit~in norm_a_l bounds o_r acting to put the plant in a safe coridition if they exceed hormal bounds.

System: Ari integral part of nuclear power plant comprising components which may be operated or used as a separate entity to perform a specific function.

• Revision 22

• 61 of 84 May 28, 2019

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Appendix D: Revision Summaries Revision 0, 01/19/07 New Program

• NRC SE dated December 29, 2006 Subsequent organizational change, which added the Chief Operating Officer (COO), was reviewed in accordance with 10 CFR50.54(a) and determined not to constitute a reduction in commitment.

Revision 1, 02/11/08 Organizational changes and editorial corrections Add ISFSI as required assessment topics Site Security assessment topic was clarified to indicate that it includes safe uards contin enc lans Revision 22

• Organizational changes and editorial corrections were reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

.62 of 84 Assessment topic added is in accordance with 10 CFR 72, SubpartG.

Assessment of safeguards contingency plans is in accordance with 10 CFR 50.54(P)

May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 2, 06/20/08 Add NextEra Energy Point Beach, LLC to the scope of FPL-1 The scope of the Engineering and Configuration Management assessment topic was clarified to indicate that it includes determination of QAP applicability to SSCs and classification of SSCs The scope of the corrective action program and self-assessment topic was clarified to indicate that it includes Operating Experience Make an editorial correction The Introduction was clarified to indicate that nuclear safety related items may be identified in a Q-List.

The commitment to General Design Criteria I was corrected to indicate that some plants are committed to the 1967 proposed draft.

Provide an alternate exception to NQA-1, Appendix 2A-1, for qualification / certification of inspection personnel applicable to Point Beach only.

Revise FPL's commitment to Regulatory Guide 1.28, Regulatory Position C.1, to reflect the alternate exception for Point Beach.

To reflect or anizational chan es

• Changes for NextEra Energy Point Beach, LLC were reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment

• The clarifications and corrections were reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment

• The alternate exception to NQA-1, Appendix 2A-1, which is only applicable to Point Beach, is contained in the current NextEra Energy Point Beach, LLC, QATR (NextEra Energy PB-1), therefore, there is no change in commitment.

• Organizational changes were reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 3, 02/06/09 Organizational changes

• Organizational changes to 'align with fleet concepts Editorial corrections Grammatical corrections

• Clarifications for electronic records New Compliance Order Update audit requirement basis for FFD/AA

• Editorial and grammatical corrections Clarification for electronic records Revision 22 63 of 84 May 28, 2019

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Revision 4, 06/27/09 Remove "FPL Energy" nomenclature and replace with "NextEra

• This is a name change only and does not affect any commitments.

~M

• Revision 5, 08/28/09 Organizational changes Title corrections Grammatical corrections Standardizing on FPL/NextEra Energy NUPIC reference clarification Standardizin on Nuclear Oversi ht

• Organization changes, grammatical corrections, NextEra Energy nomenclature changes, and Nuclear Oversight name changes were reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 6, 03/05/1 O Revise Chief Nuclear Officer's new titre to Executive Vice President and Chief Nuclear Officer Correct title and update responsibilities of Vice President Fleet Support Remove position of Vice President Nuclear Plant Support Remove position of Vice President Nuclear Capital Projects Add new position of Vice President Fleet Outages Planning and Execution

• This change reflects recent organizational changes, title changes, and realignment of responsibilities that were reviewed in accordance with 1 O CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 22 64 of 84 May 28, 2019

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Revision 7, 06/18/10 Company name change from FPL Group to NextEra Energy 13asi.$JerMee:¥ng}OC~~EHJ **

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• This is a company name change only with corresponding CEO and COO title changes. This was reviewed in accordance with 10 CFR 50.54 a and determined not to constitute a reduction in commitment.

Revision 8, 10/22/10 Revise Table 1 Remove Table 2

• 'This change implements a restructuring of audit topic areas for the NextEra Energy Nuclear Oversight Auditing process to align with the Corporate Functional Area Manager (CFAM) areas. This will improve the effectiveness of reporting identified issues and support fleet standardization. This was reviewed in accordance with 1 o*cFR 50.54 a and determined not to constitute a reduction in commitment.

Revision 9, 02/18/11 To add an additional exception to NQA-1-1994 requirements for In-Storage Maintenance to Section 8.7.

Organizational Change creating position of Vice President Organizational Support and realigning organizational responsibilities from Vice President Fleet Support and adding the position of Director IT Business Solutions IM Nuclear Systems to Section A.2, Organization and the organizational chart to support c ber securit ro ram interface.

• This change provides an exception that provides greater flexibility in evaluating vendor recommendations as they apply to In-Storage Maintenance. This change was reviewed in accordance with 1 O CFR 50.54, and it was determined not to constitute a reduction in commitment based on the fact that this exception has been approved by the NRC for other nuclear utilities.

• This change creates a new position of Vice President Organizational Support, and realigns responsibilities previously assigned to the VP Fleet Support. Realignment of responsibilities was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 22 65 of 84 May 28, 2019

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Revision 10, 07/29/11 Organizational change to remove the position of Director Plant Support from the site organization chart.

• This change deletes an unused position from the QATR organizational chart. This change was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 11, 02/10/12 Organizational change eliminating Vice President Nuclear Engineering Support and the Vice President Organizational Support positions. All of the responsibilities/functions currently reporting to these two positions will be aligned under the Vice President Nuclear Fleet Support. Functional position descriptions from the two eliminated positions are being moved into Section A.2.3.b Vice President Fleet Support, which is renamed Vice President Nuclear Fleet Su ort.

• This change eliminates the Vice President Nuclear Engineering support and the Vice President Organizational Support, and realigns all responsibilities under the Vice President Nuclear Fleet Support. This change was reviewed in accordance with 10 CFR 50.54(a) and was determined not to constitute a reduction in commitment.

Revision 12, 07/03/12

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• Administrative change to: (1) Institute the NextEra Energy logo; (2)

• This change incorporates administrative changes. This change was Clarify Section A.7.3 based on Confirmatory Action Letter EA-08-172 reviewed in accordance with 10 CFR 50.54.{a) and determined not to dated 10/20/08 (bulleted item # 24).

constitute a reduction in commitment.

• Administrative change to: (1) Delete the limit on alternates

• This change incorporates administrative changes. This change was consistent with Seabrook Station License Amendment 34; (2) Clarify reviewed in accordance with 10 CFR 50.54(a) and determined not to Appendix B applicability to audit topics.

constitute a reduction in commitment.

• Administrative change to: (1) Change title to Vice President Nuclear

• This change incorporates administrative changes. This change was Fleet Technical Support; (2) Standardize to NextEra Energy; (3) reviewed in accordance with 10 CFR 50.54(a) and determined not to Update title to President and Chief Executive Officer.

constitute a reduction in commitment.

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Revision 12, 07/03/12

• Organizational change to: (1) Realigned a number of positions that reported up through the Vice President and Chief Strategy, Policy and Business Process Improvement Officer. As a result of these changes Vice President and Chief Information Officer will report to Vice Chairman and Chief Financial Officer. {2) An organizational announcement made on March 16, 2012 that relates to the future retirement of the Chairman and CEO. Effective July 1, 2012, the CEO will be re laced b the President and CEO.

• An organizational announcement was made on April 19, 2012 identifying a new position titled General Manager Issue Management, which reports to the Vice President Nuclear Fleet Technical Support. Two existing positions will be aligned under this General Manager, which is the Nuclear Engineering Chiefs Manager and the Nuclear Component Support & Inspection Manager. One General Manager title was changed from Functional Area Support to Nuclear CFAM.

• An organizational announcement was made by the Chief Nuclear Officer on May 24, 2012 outlining the following changes that affect the QATR:

A new position of Vice President CF AM and Outage Support was created that reports to the Vice President Nuclear Fleet Technical Support.

A new position of Vice President Organizational Effectiveness was created that reports to the Vice President Nuclear Fleet Technical Support.

A new position of General Manager of Operations has been created that reports to the Vice President CFAM and Outage Support.

The new position of General Manager Issue Management has been renamed General Manager Engineering Rapid Response Team ERRT.

• This change incorporates organizational changes. This change was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

• This change incorporates organizational changes. This change was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

• This change incorporates organizational changes. This change was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 22 67 of 84 May 28, 2019

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Revision 13, 04/01/13 Restructured section C.3 "Independent Assessment in its entirety by modifying the sequence of paragraphs within this section and making the following changes:

This change was evaluated in accordance with 10 CFR 50.54(a) requirements against the guidance in NUREG 0800, Standard Review Plan (SRP). The SRP requires a commitment to audit compliance with the requirements of 1 OCFR 50 Appendix B. NextEra Energy FPL-1 Quality Assurance Topical Report contains this commitment in section A.7 "Regulatory Commitments~. The SRP does not require that a specific listing of either audit topics or applicable Appendix B criteria be described in the QATR.

In addition, a note included in both the previous and proposed revisions to the QATR that applies to the Table 1 & 2 assessment topics, states "Topic titles in these tables may vary; however, all program elements (i.e. applicable regulatory requirements and all 1 OCFR50 Appendix B criteria) will be covered as identified in implementing procedures".

Regrouped and consolidated internal audit topics to improve the efficiency and effectiveness of audit process execution. In support of this revision, Table 1 lists topics that are audited on either a fixed frequency or on a variable frequency as governed by an Expert Panel process. Table 2 lists the topics that are audited on a fixed frequency that is prescribed by regulatory requirements. As part of this change a more detailed list of applicable 10 CFR 50 Appendix B criteria, governing regulations and the corresponding audit frequencies has been removed from the QATR and has been added to an implementing procedure.

Restructuring this section also clarifies the distinction between requirements that are applicable to the use of the fixed audit scheduling and the variable frequency audit scheduling methods.

An organizational announcement dated July 3, 2012 made by Vice President; Nuclear Fleet Technical Support rearranged a number of positions reporting to him. As part of this announcement, the position of General Manager Engineering Rapid Response Team was eliminated.

This change is consistent with the FPL Topical Quality Assurance Report that existed before transitioning to the QATR in that it only contained a list of audit topics and a statement that all criteria in.

Appendix B to 10 CFR Part 50 would be audited. The program met the SRP and was approved by the NRC.

Therefore removing the more detailed list of applicable 10 CFR 50 Appendix B criteria, governing regulations and the corresponding audit frequencies from the QATR does not constitute a "reduction in commitment'.

• This change incorporates organizational changes and was reviewed in accordance with 10 CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 22 68 of 84-May 28, 2019

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NextEra Energy Quality Assurance Topical Report (FPL-1)

Revise Section A.7, Regulatory Commitments for plants with an NFPA 805 Fire Protection licensing bases Revise A endix C "Fire Protection E ui ment" definition This change identifies the Regulatory guide and NEI commitments that implement the NFPA 805 Licensing requirement. This change was reviewed in accordance with 10 CFR 50.54(a) and was determined not to constitute a reduction in commitment.

Revision 15, 09/01/14 Note: Since this QATR revision incorporates multiple Quality Program Revision Request (QPRR) packages, in some cases, pending QPRR revisions were impacted by subsequent QPRR revisions.

QPRR QR032: The site organizational chart was modified to show the Shift Technical Advisor (STA) position reporting to the "Shift Manager" position.

QPRR QR033: The position of General Manager Organizational Effectiveness was introduced. The Emergency Preparedness and Chemistry CFAMs were included under the VP CFAM and Outage Support. The Director IT Business Solutions IM Nuclear Systems dotted line reporting function was moved from the Vice President Nuclear Fleet Technical Support to the new General Manager Organizational Effectiveness position. An editorial change in QATR Section C.1 changed the word "can" to "may" to be consistent with QATR Section A.5 (third bullet, last sentence).

QPRR QR035: A change to the recently incorporated definition for Fire Protection Equipment was made to clarify what is specifically meant when referring to Quality-Related Fire Protection Equipment.

This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is an Organizational revision and persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including, sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is an Organizational revision and persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

This change was evaluated in accordance with 10 CFR S0.54(a) requirements and the requirements of Regulatory Guide 1.205, December 2009, Risk-Informed, Performance-Based Fire. Protection For Existing Light-Water Nuclear Power Plants.

Since this change to the NextEra Energy quality assurance program description addresses the addition of a, new commitment, it does not constitute a..,reduction in existing commitments. This change is a non-intent administrative change being made because the term "important to safety" is an undefined term. There is no reduction in commitment.

Revision 22 69 of 84 May 28, 2019

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Revision 15, 09/01/14 Note: Since this QATR revision incorporates multiple Quality Program Revision Request (QPRR) packages, in some cases, pending QPRR revisions were impacted by subsequent QPRR revisions.

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QPRR QR036: The positions of Vice President Fleet Support This *change was evaluated in accordance with 10 CFR 50.54(a)

Services and Director Fleet Design Engineering were created. The requirements. The change is an Organizational revision and persons and Vice President CFAM and Outage Support and the General organizations performing quality assurance functions continue to have the Manager Organizational Effectiveness were realigned to report to requisite authority and organizational freedom, including sufficient the Vice President Fleet Support Services position. The Director independence from cost and schedule when opposed to safety Fleet Design Engineering reports to the Vice President Fleet considerations and therefore this is not considered a reduction in Technical Support.

The positions of Vice President Extended commitment.

Power Uprate (EPU), EPU Project Implementation, and EPU Site Director have been eliminated due to completion of the EPU projects.

Clarification of the reporting chain for the Director IT J?usiness Solutions IM Nuclear Systems has been provided as part of this change.

The position of Vice President Organizational Effectiveness was eliminated.

QPRR QR037: Project Momentum changes have been made to incorporate Fleet Design Engineering and Interfaces with Power Generation for Turbine Generators, large pumps and motors, thermal performance, and the Fleet Performance and Diagnostic Center. "NextEra Energy President and Chief Executive Officer"

..,, title changed to "NextEra Energy Chairman and Chief Executive Officer".

QPRR QR038: The Nuclear Materials Manager position was eliminated at each site, and the Integrated Supply Chain (ISC) was reorganized.

The * "Executive Vice President Engineering, Construction & Corporate Services" title has changed to "Executive Vice President Engineering, Construction, and ISC".

QPRR QR041: "Executive Vice President and Chief Nuclear Officer" title changed to "President and Chief Nuclear Officer, Nuclear Division".

This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is an Organizational revision and persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations. The interfaces established with Power Generation will not affect any quality or safety-related functions described in the QATR.

Therefore these changes are not considered reductions in commitments and continue to meet 1 OCFR 50 Appendix B requirements.

This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is an Organizational revision and persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom necessary to perform their quality assurance functions and therefore this is not considered a reduction in commitment.

This change reflects and administrative title change that was reviewed in accordance with 1 O CFR 50.54(a) and determined not to constitute a reduction in commitment.

Revision 22 70 of 84 May 28, 2019

• NextEra Energy Quality Assurance Topical Report (FPL-1)

~evision 16, 12/19/14 QR039: NextEra nuclear plants with a renewed Facility Operating License are committed to satisfy the intent of NUREG-1800, Branch Technical Position IQMB-1, "Quality Assurance for Aging Management Programs," and/or NUREG-1801 elements. The 10 CFR Part 50, Appendix 8 quality assurance program provides for corrective actions, the confirmation process, and administrative controls for Aging Management Programs (AMP) for license renewal. The scope of this existing QA program is expanded to include non-safety-related structures and components that are subject to an Aging Management Review (AMR) for license renewal.

AR 01921585 identified that this issue was identified during the NRC License Renewal Inspection at PDA.

QR040: Revise Section A.2.1.2.d, General Manager Organizational Effectiveness to modify the "Licensing" functional responsibility to read: "Licensing, including licensing actions". Also, revise Section A.2.2.1.b, Licensing Manager to delete the words licensing actions" from this position.

This change is to show that the "licensing actions" are performed at the Corporate level.

QR042: Revise Section A.2.1.2.1, Director Nuclear Assurance, through Nuclear Oversight Manager{s), to address the responsibility

. for the performance of receipt inspection to verify that purchased items comply with procurement documents at stations where receipt inspection is performed by the Nuclear Oversight Organization. (

Reference:

AR 1984358)

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This change was evaluated in accordance with 10 CFR 50.54{a) and NUREG-1800 and 1801 requirements. The change is documenting previous commitments identified in the SER's that approved the renewed Facility Operating Licenses and is including these commitments in Section A.7 Regulatory Commitments. This change is not changing any requirements or commitments currently in the QATR and is not considered a reduction in commitment.

This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is documenting the relocation of the licensing functional responsibility for "licensing actions" from the site Licensing organizations to the Corporate Licensing organization and does not change how this function is performed. This is not considered a reduction in commitment.

This change was evaluated in accordance with 10 CFR 50.54{a) requirements. The change is documenting the additional responsibilities of the Director Nuclear Oversight and does not change how the function is performed. This is not considered a reduction in commitment.

Revision 22 71 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 17, 04/1'3/1. 5

• QR043: Remove alternative Independent Assessment scheduling methodology utilizing the review and evaluation by an expert panel (Flexible Audit Scheduling) from Section C.3, Independent Assessment.

• QR044:

Organizational Announcement from Mano

Nazar, President, Nuclear Division and Chief Nuclear Officer dated March 3, 2015.

Section A.2, Organization--New positions, descriptions, and reporting relatiol')ships for Nuclear Chief Operating Officer; Vice President Projects Design and Execution, Director Fleet Regulatory Projects, General Manager Fleet Projects, and General Manager Fleet Engineering.

Appendix E,

Corporate Organization Chart--Organization Relationships of Key Management and Functional Groups (Corporate) for Nuclear Chief Operating Officer, Vice President Projects Design and Execution, and Director Fleet Regulatory Projects. Move General Manager Fleet Engineering to report to the VP Fleet Support Services.

Delete VP. Fleet Technical Support. Align General Manager Fleet Projects and Director Fleet Design Engineering under VP Projects Design and Execution.

This change was evaluated in accordance with 10 CFR 50.54(a) requirements.

ASME NQA-1-1994 states that audits shall be scheduled at a frequency commensurate with the status and importance of the activity. It does not specify either a flexible or fixed audit scheduling process.

The deletion of the flexible audit scheduling process is not a reduction in commitment since the remaining fixed audit scheduling process continues to meet the QATR basis document and 10 CFR 50.

This change was evaluated in accord~mce with 10 CFR 50.54(a) requirements. The change is an organizational revision and persons and organizations performing quality functions continue to have the requisite authority and organizational freedom; including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

Revision 22 72 of 84 May 28, 2019

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Revision 18, 11/20/15 QR045: Change "Director of Emergency Preparedness" to "Manager of Emergency Preparedness" due to the position Director of Emergency Preparedness being downgraded to Manager of Emergency Preparedness when the Director of Emergency Preparedness retired.

QR046: This revision has been prepared to incorporate the Vice President Fleet Technical Support organizational announcement made on April 30, 2015, and the Chief Nuclear Officer organizational announcement made on August 11, 2015.

The April 30, 2015 announcement contains the addition of a General Manager CFAMs and Projects CFAM position and the realignment of the Director Fleet Design Engineering under the Vice President Fleet Technical Support. The August 11, 2015 announcement contains the realignment of the Nuclear Operations and Fleet Technical Support functions to the Chief Nuclear Officer.

This revision also streamlines the A.2 Organization and Appendix E Corporate Organization Chart QATR sections to show senior management and interfacing positions reporting to the Chief Nuclear Officer and above.

QR047: The proposed revision to the QATR Appendix C has been submitted by Engineering in order to align fleet procedures, site procedures and the QATR by adding the following two additional categories to the definitionwf "Quality Related":

(1) Instrumentation used in post accident monitoring and classified as Category 3 in response to the requirements of Regulatory Guide 1.97 (some Category 2 instruments may also be classified as Quality Related); and (2) Items or services that are subject to unique quality assurance requirements due to specific NRC imposed regulatory requirements.

• This is a position title change only and does not affect any commitments.

• This change was evaluated in accordance with 10 CFR 50.54(a) requirements. The change is an Organizational revision and persons and organizations performing quality functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

• Selected elements of the Quality Assurance Program are applied to certain quality related equipment and activities that are not safety related, but support safe and reliable plant operations, or where other regulatory or industry guidance establishes program requirements. This quality related classification is applied to selected equipment, components, structures and services designed to support and/or protect the safety function of safety related equipment.

• The proposed revision to the QATR definition of "Quality Related" was evaluated in accordance with 10 CFR 50.54(a) requiremenJs and determined to not constitute a reduction to the commitments in the quality assurance program description as accepted by the NRG. This evaluation was based upon the proposed revision adding additional non safety related categories to the definition of "Quality Related".

Therefore, the proposed revision is not considered to be a reduction in commitment.

Revision 22 73 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

QR048: The changes incorporated within this revision include both Administrative and Organizational (Conforming) changes.

The conforming change results from a senior management organizational. announcement and will be distributed "For Information Only" to affected organizations as described by NA-AA-210-1000, Section 4.3.B. (2). The administrative change incorporates a functional responsibility description which was omitted from QATR Section A.2.1.2.h (Revision 18). As provided by NA-AA-210-1000, Section 4.3.C. (1), administrative changes only require approval of the NOS QAPRC member, the QAPRC Chairperson and the Director Nuclear Assurance.

• This change was evaluated in accordance with 10 CFR 50.54(a),

Conditions of License requirements and NA-AA-210-1000, Quality Assurance Program Administration (Attachment 1 ). The Organizational and Administrative Changes described do not result in reduction of any QA Program commitment for the following reasons: (1) Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the " requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations (paragraph vi). (2) Quality Assurance program changes involving administrative improvements and clarifications, spelling corrections, punctuation or editorial items. (paragraph vii)

Revision 22 74 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

QR049: Update Section 8.4, Procurement Controls, Alternate Accreditation for laboratory testing facilities. NRC RIS 2016-01 accepts the methodology of NEI 14-05a for expanding the accreditation organizations of ISO/IEG 17025:2005 to ILAC (International Laboratory Accreditation Corporation)

MRA signatories.

This accreditation acceptance is used in lieu of source surveillance of M& TE equipment calibrations or tests.

QR049:

Update Sections A.2, Organization and Appendix E, Organization Charts with Chief Nuclear Officer (CNO)

Organization Announcement Dated August 11, 2016:

Fleet Support:

Vice President for Organizational Effectiveness arta Learning will have responsibility for Security, Training, Licensing, Corporate Functional Area

Managers, Continuous Improvement Program, Nuclear Oversight and the new Performance Improvement* and Assessment group, including Performance Improvement.

This position will report directly to the Chief Nuclear Officer.

Project Controls: A new organization will be established for Project Controls that will report to the Vice President Project Controls & Strategic Alliances in an effort to make the organization more streamlined. The Project Controls team will realign under the Vice President Project Controls &

Strategic Alliances. The Vice President Projects will continue to lead projects and report directly to the CNO.

Site Engineering Directors: Directors of Engineering at the sites will now report to the Site Vice Presidents.

This change was evaluated in accordance with 10 CFR 50.54(a),

Conditions of License requirements and NA-AA-210-1000, Quality Assurance Program Administration (Attachment 1 ).

The Organizational and Administrative Changes described do not result in reduction of any QA Program commitment for the following reasons:

Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost* and schedule when opposed to safety considerations.

(paragraph vi)

Quality Assurance program changes involving administrative improvements and clarifications, spelling corrections, punctuation or editorial items. (paragraph vii)

The use of a quality assurance alternative or exception approved by an NRC safety evaluation provided that the bases of the NRC approval are applicable to NextEra Energy Nuclear Plants. (paragraph ii )

Revision 22 75 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPLw1)

Revision 20, 02/17/17 Engineering Fleet: Vice President Nuclear Fleet Engineering Support will report directly to the CNO along with five direct reports who will lead

Programs, Probabilistic Risk Assessment, Equipment Reliability, Fuels and Chiefs. The CNO and Vice President Nuclear Fleet Engineering Support will work together to redefine functional core business, roles and responsibilities. The Nuclear Engineering Director Fleet will oversee the Chiefs organization and report to the Vice President Nuclear Fleet Engineering Support.

Outage Managers: The Outage Managers will continue to report to the site but will now also be matrixed to the Vice*

President Fleet Outage. The fleet Outage organization and Vice President Fleet Outage will report to the Vice President Projects. The Vice President Projects and Vice President Fleet Outage will continue to refine the *roles and responsibilities to outage performance.

Site Leadership: The Seabrook Site Vice President, as part of individual development, will lead Point Beach performance in addition to responsibilities serving as the Site Vice President, which will report directly to the CNO. The Point Beach Site Vice President, will report directly to the Seabrook Site. Vice President and have a dotted line reporting relationshi to the CNO.

Revision 22 76 of 84

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QR049:

Update Sections A.2, Organization and Appendix E, Organization Charts with Chief Nuclear Officer (CNO)

Organization Announcement Dated January 3, 2017:

Regional Support:

To provide increased oversight to the plants, Regional Vice Presidents have been appointed to the

• Southern Region (St. Lucie and Turkey Point) and Northern Region (Duane Arnold, Point Beach, and Seabrook). The Site Engineering c;lirectors will report directly to the Regional Vice Presidents, as-will Emergency Preparedness and Licensing managers.

Site Leadership: As part of Accelerate, the roles of Site Vice President and Plant General Manager (PGM) will be merged into one streamlined role with the title of Site Director starting in 2017 with a targeted completion at all sites by mid-2018.

These positions will report to the Regional Vice Presidents.

The Site Director role will be responsible for Operations, Work Control, Maintenance, Radiation Protection, Chemistry, Outage, Performance Improvement, Safety and Training.

Fleet Support:

The Vice President Projects will take over responsibility for Engineering in addition to the current role leading Projects, combining it into one organization, inclusive of governance and oversight of fleet outages. The Business Operations, Project Control and Accounting teams will report to the Chief Financial Officer. New Nuclear Projects (Turkey Point 6 & 7) will report directly to the CNO.

The Nuclear Assurance Manager will return to reporting to the CNO.

Revision 22 77 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 21, 04/21/17 QR050: Update the following sections:

A.7, Regulatory Commitments and 8.15, Records:

Add Reference To 10 CFR 73.70 (AR 2181687).

• This change involves the addition of reference to 1 O CFR 73, Physical Protection of Plant and Materials fo QATR Section A. 7.1. The change also involves clarification to the requirements in QATR Section 8.15, Records for the security record retention and quality.

Revision 22

• In establishing requirements for records, the QATR commits to NQA 1 Supplement 17S-1 and NQA-1 Non-mandatory Appendix 17A-1.

• Non-mandatory Appendix 17 A-1, Section 3.6 identifies the Physical Security Plan and procedures as records which must be maintained for the lifetime of the plant.

• Records required by the security plan and procedures that meet the definition of a Quality Assurance Record are required to be retained as Quality Assurance Records and only those Quality Assurance Records that meet the criteria for lifetime QA Records require lifetime retention.

Storage and retention of Security Records and records required to be maintained by Security as Quality Assurance records as described by 10 CFR 73.70, 10 CFR 73.55(q) and the Physical Security Plan, will be specified in applicable Security procedures.

• 10 CFR 73.55 (q) and 10 CFR 73 provide clarification to the requirements regarding record retention times for records.

• The addition of references 10 CFR 73.55 (q) and 10 CFR 73.70 is an Administrative improvement that does not result in a reduction in commitment. Compliance to all provisions of the Commission approved Physical Protection plan described by 10 CFR 73 is required as part of the licensing bases.

• The changes to QA TR Sections A. 7 and 8.15 are Administrative changes as described by 10 CFR 50.54 (vii) because it involves an improvement which clarifies security record retention and quality requirements.

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NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 21, 04/21/17 C.3, Independent Assessment, Paragraph 3:

Revise Paragraph 3, which refers to all independent assessments verifying procedure review and revision controls.

B.4, Procurement Control, Bullet, 3:

Clarification to Regulatory Guide 1.28, Position C.3.2 for auditing and evaluation of suppliers.

• A change is made to QA TR Section C.3; paragraph 3; to clarify the procedure review scope during the assessment/audit process.

• Audits include a comprehensive evaluation of activities and the procedures used to control those activities.

• Procedure development,* review, approval, issue, use, revision and review are evaluated as part of the QA Programs audit which is performed on a biennial basis.

• The change to QA TR Section C.3 is an Administrative change as described by 1 O CFR 50.54 (vii) because it involves clarification of the assessment /audit scope.

• Regulatory Guide 1.28 Revision 3, position C.3.2.2 states that the licensee should perform annual evaluations of suppliers. This evaluation should be documented and should take into account, where applicable, (1) review of supplier. furnished documents and records such as certificates of conformance, nonconformance notices, and corrective actions; (2) results of previous source verifications, audits, and receiving inspections; (3) operating experience of identical or similar products furnished by the same supplier; and (4) results of audits from other sources, e.g., customer, ASME, or NRC audits.

• The current QATR takes exception for position C.3.2.2 where the information described therein is reviewed on a continuous basis 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.

• This proposed QATR revision will allow the option to continue to take exception with Regulatory Guide 1.28, Revision 3, position C.3.2.2 for continuous supplier reviews while also allowing the option for compliance with position C.3.2.2 for annual supplier reviews. The current QA TR wording was written to only allow implementation of the exception process for continuous supplier reviews.

Revision 22 79 of 84 May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 21, 04/21/17 Appendix E, Site Organization Chart:

Show IT Business Solutions Manager in a dotted box, which reports to a Corporate position.

• The change to 8.4, Procurement Control is an Administrative change as described by 1 O CFR 50.54 (vii) because it involves clarification of the su lier review recess.

• This change is to correct an administrative error made during development of QATR Revision 20 describing the reporting responsibilities between the IT Business Solutions Manager and the Site Director. The change is an Administrative change as described by 1 O CFR 50.54 (vii) and is not considered a reduction in commitment.

Revision 22, 05/28/19 QR052: Section A.2 Organization & Appendix Site Organization Chart.

Change the Department Name from Information Management to Information Technology.

Revision 22

• tBasis for Meetin '10CFR'SO;'~.. **

This change was evaluated in accordance with 10 CFR 50.54(a),

Conditions of License requirements and NA-AA-210-1000, Quality Assurance Program Administration (Attachment 1 ).

The Organizational and Administrative Changes described do not result in reduction of any QA Program commitment for the following reasons:

80 of 84 Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority-and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations.

(paragraph vi)

Quality Assurance program changes involving administrative improvements and clarifications, spelling corrections, punctuation or editorial items. (paragraph vii)

The use of a quality assurance alternative or exception May 28, 2019

NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 22, 05/28/19

• • , Cffange/R,~a~oo.fqr Ql1~nge*'+;..,,.,,, }';;:*: ;, A.:.: '.,t, ".;,.,. 8Efsi~*fQtM~etino<10'CFR50,. * *....

QR063: This revision has been prepared to update the QATR to reflect the current organizational structure and update the table for the independent assessments to reflect that the Maintenance and Work Management audits are now performed as one audit versus two (change made to NA-AA-202-1000,Audit Topic Selection and Scheduling, Rev 11)

QR054: Change was to incorporate change to the reporting relationship for Emergency Preparedness and Licensing and also for Performance Improvement and Training.

QR066: Update the QATR (Section 8.4) to reflect the NRG provisional acceptance of ISO/IEC 17025 (2017 edition) applicable during the transition period set to expire on November 30, 2020 to allow accredited laboratories to transition from the current 2005 edition as provided by ISO approved by an NRG safety evaluation provided that the bases of the NRG approval are applicable to NextEra Energy Nuclear Plants. (paragraph ii )

Organizational changes:

These changes were evaluated in accordance with 1 O CFR 50.54(a) requirements. The changes is an Organizational revision and persons and organizations performing quality functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations and therefore this is not considered a reduction in commitment.

Change in audits:

The table was changed to reflect that the Maintenance and Work Management audits are now performed as one audit versus two.

As both areas are still audited there is no reduction in commitment.

These changes are no longer applicable and required changes are in QR053.

The NRG performed an independent review of ISO/IEC 17025:2017 and a gap analysis concluding that ISO 17025:2017 did not decrease or remove any of the technical and quality requirements that provided the basis for the NRC's initial recognition of the ILAC accreditation process. As a result, the NRG concluded that licensees and suppliers of basic components may procure calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017 in lieu of performing Revision 22 81 of 84 May 28, 2019

,I Revision 22 NextEra Energy Quality Assurance Topical Report (FPL-1)

Revision 22, 05/28/19 a survey as part of the commercial-grade dedication process in accordance with the NRC's SE of NEI 14-05A for the transition period provided by ISO.

Based on the above basis, the change described does not result in a reduction of any QA Program commitment as a result of the following: The use of a quality assurance alternative or exception approved by an NRG safety evaluation provided that the bases of the NRC approval are applicable to NextEra Energy Nuclear Plants.

ara ra h ii.

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Appendix E: Organization Charts Chart 1 of 2: Corporate NextEra Energy Quality Assurance Topical Report (FPL-1)

ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (CORPORATE)

EXECUTIVE VlCEPRESIDENT

!!IIGIHEERl!IG, OO!ISlllUCTIO!I & ISC VICE PRESIOEIIT l!IT£GAATED SUl'l'LY CIWl

( OFF-Sl!E If) )

VICE PRESIDENT l(EWNUCLEAR Revision 15 ENT NUCI..EIIR DMSION VlCE PRESIDENT NUCLEAR DMS!ON&

Cl{JEF NUCI.EAA OFFICER jCNO)'

GENERA!.M.\\111\\GER CFAMS

(

OIMIIIE[!) )

Revision 22 SllE DIREClORS I PI.AIIT GE/laW. -

sm:

EHGIHEER!ljG DIRECTORS 83 of 84 SEIIIOR OIRECTOII PROJECTS&

CONS'llWCllON SllE CESIG!f

!!IIG!IIEBWIG MANAGERS EXECI.ITIVE VICE PRalOEIIT CFO VlCE PRESIDENT CIQ SENIOII DlllECTOR ITSUS!llESS SOLIITIO!iS IT TECHNOLOGY DIR.ECTOR 8US1NESS INFORMATION TECH!!OLOGY l.EAOSl May 28, 2019

Appendix E: Organization Charts Chart 2 of 2: Site NextEra Energy Quality Assurance Topical Report (FPL-1)

ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (SITE)

CHEM!SlRY MANAGER TRAINING SITE MANAGER OPERATIONS SITE DIRECTOR SITE DIRECTORS/ PGM

!!AINTE!WlCE SllE DIRECTOR RADIATION PROTECTION MANAGER Revision 10 ENGIMEERJNG SITE DIRECTORS ENGfllEERING SITE MANAGER *PROGRMIS ENGINEERING SITE MANAGER. SYS'll;MS I

SITE I !

OESfGN hlANAGER I

I

• -*-*-*-*-*-*..J NUC!.EM ASSURANCE I

t.lANAGBl

-*-*-*-*-* I (1) Seabrook d.Qes not hav~ Shift T4N:hn1cal Advisors-this. position co111bined with Shift Manager 1 SRO

(:l) Meets position cf Opi,r.ations Sup,;rvisor Revision 22 SHIFT TECHNICAL ADVISORS (11 1T BUSINESS SOLUT!Ol'IS I..!~~---j

-Org3Jlizational titles are generic-specific site organizational titles may differ-r*-*-*-*..

84 of 84 Denotes direct reporting relationship to corporate organization, but physically loc_ated at sites May 28, 2019

0

. Organization Chart

EXECUTIVE VICE PRESIDENT ENGINEERING, CONSTRUCTION & ISC VICE PRESIDENT INTEGRATED SUPPLY CHAIN

(

)

ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (CORPORA TE)

Revision 15 CHAIRMAN CHIEF EXECUTIVE OFFICER (CEO)

PRESIDENT NUCLEAR DMSION VICE PRESIDENT NUCLEAR DMSION&

CHIEF NUCLEAR OFFICER (CNO)'

I SENIOR DIRECTOR VICE PRESIDENT VICE PRESlDENT DIRECTOR

FINANCE, NEW NUCLEAR CORPORATE NUCLEAR ASSURANCE NUCLEAR FLEET SUPPORT

& ASSESSMENT I

GENERAL MANAGER GENERAL MANAGER SENIOR DIRECTOR CFAMS FLEET ENGINEERING PROJECTS&

CONSTRUCTION DIRECTOR FLEET DESIGN ENGINEERING

---

~------------------------

--- -----~------ ---------- --

(

ON.SITE (1) )

SITE DIRECTORS/

SITE SITE PLANT GENERAL SITE DESIGN MANAGERS ENGINEERING ENGINEERING NUCLEAR ASSURANCE DIRECTORS MANAGERS MANAGERS EXECUTIVE VICE PRESIDENT :

CFO VICE PRESIDENT CIO SENIOR DIRECTOR IT BUSINESS SOLUTIONS IT TECHNOLOGY DIRECTOR BUSINESS INFORMATION TECHNOLOGY LEADER

ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (SITE)

CHEMISTRY MANAGER SAFETY HEALTH MANAGER TRAINING SITE MANAGER OPERATIONS SITE DIRECTOR I

OPERATIONS ASST.

MANAGER* LINE l

SHIFT MANAGER f2)

I SHIFT TECHNICAL ADVISORS (1)

SITE DIRECTORS I PGM

\\

MAINTENANCE SITE DIRECTOR WORK MANAGEMENT -

SITE MANAGER RADIATION PROTECTION MANAGER Licensing Manager -

I Emergency Preparedness Manager I

IT I

BUSINESS I

SOLUTIONS I

j ___

LEADER ___ j Revision 10 ENGINEERING SITE DIRECTORS E:NGINEERING SllE MANAGER-PROGRAMS ENGINEERING SITE MANAGER *SYSTEMS L.

SECURITY SITE MANAGER SllE DESIGN MANAGER i_ *-*-*-' - *-. _.f I

NUCLEAR j

A~:=:E I

I L*-*-*-*-*-*

(1) Seabrook does not have Shift Technical Advisors--thls position combined with Shift Manager/ SRO (2) Meets position of Operations Supervisor

--Organizational titles are generic-specific site organizational titles may differ-Denotes direct reporting relationship to corporate organization, but physically located at sites