ML071270283

Southern Nuclear Operating Company - Quality Assurance Topical Report Revision 2b, Enclosure 1

ML071270283
Person / Time
Site:	Hatch, Vogtle, Farley, 07200042, 07200036
Issue date:	04/30/2007
From:	George B Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
References
NL-07-0835
Download: ML071270283 (225)

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Enclosure 1 Southern Nuclear Operating Company Quality Assurance Topical Report Red-line Markup Revision Ob Page 1 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SOUTHERN NUCLEAR OPERATING COMPANY, INC.

Joseph M. Farley Nuclear Plant Unit 1 Docket No. 50-348 Joseph M. Farley Nuclear Plant Unit 2 Docket No. 50-364 Edwin I. Hatch Nuclear Plant Unit 1 Docket No. 50-321 Edwin I. Hatch Nuclear Plant Unit 2 Docket No. 50-366 Alvin W. Vogtle Electric Generating Plant Unit 1 Docket No. 50-424 Alvin W. Vogtle Electric Generating Plant Unit 2 Docket No. 50-425 Joseph M. Farley Nuclear Plant Independent Spent Fuel Storage Installation Docket 72-42 Edwin I. Hatch Nuclear Plant Independent Spent Fuel Storage Installation Docket 72-36 QUALITY ASSURANCE TOPICAL REPORT SNC-1 Version 0ab Page 2 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SOUTHERN NUCLEAR OPERATING COMPANY, INC POLICY STATEMENT Southern Nuclear Operating Company, Inc. (SNC) shall maintain and operate nuclear plants in a manner that will ensure the health and safety of the public and workers. Facilities shall be operated in compliance with the requirements of the Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) Facility Operating Licenses, and applicable laws and regulations of the state and local governments.

The SNC Quality Assurance Program (QAP) described in the SNC Quality Assurance Topical Report (QATR) and associated implementing documents provides for control of SNC activities that affect the quality of safety related nuclear plant structures, systems, and components and includes all planned and systematic activities necessary to provide adequate confidence that such structures, systems, and components will perform satisfactorily in service. The QAP may also be applied to certain equipment and activities that are not safety related, but support safe plant operations, or where other NRC guidance establishes program requirements.

The QATR is the top-level policy document that establishes the manner in which quality is to be achieved and presents SNC's overall philosophy regarding achievement and assurance of quality. Implementing documents assign more detailed responsibilities and requirements and define the organizational interfaces involved in conducting activities within the scope of the QATR. Compliance with the QATR and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the SNC QAP.

Signed J. Barnie Beasley President and Chief Executive Officer Southern Nuclear Operating Company, Inc.

Page 3 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SOUTHERN NUCLEAR OPERATING COMPANY, INC.

QUALITY ASSURANCE TOPICAL REPORT SNC-1 Version Oab Approved by:

Jeffrey T. Gasser Date Executive Vice President and Chief Nuclear Officer W. Dean Drinkard Date Manager, Quality Assurance Page 4 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report TABLE OF CONTENTS POLICY STATEMENT 2 PART I INTRODUCTION 7 SECTION 1 GENERAL .................................................................................................... 7 1.1 Scope / Applicability 7 1.2 Responsibilities 8 1.3 Interfaces with Owners 8 1.4 NQA-1 -1994 Commitments 8 PART II QUALITY ASSURANCE PROGRAM DETAILS 10 SECTION 1 ORGANIZATION .......................................................................................... 10 1.1 Organizational Structure (Design and Construction) 10 1.2 Organizational Structure (Operations Phase) 10 1.3 NQA-1 -1994 Commitment 19 Figure 11.1-1: CORPORATE ORGANIZATION CHART ................................................. 20 Figure 11.1-2: PLANT ORGANIZATION CHART ............................................................. 21 SECTION 2 QUALITY ASSURANCE PROGRAM ........................................................... 22 2.1 Responsibilities 22 2.2 Delegation of Work 22 2.3 Personnel Qualifications 23 2.4 NQA-1 -1994 Commitment 23 SECTION 3 DESIGN CONTROL ..................................................................................... 24 3.1 Design Verification 25 3.2 Design Records 25 3.3 NQA-1 -1994 Commitment 26 SECTION 4 PROCUREMENT DOCUMENT CONTROL .................................................. 26 4.1 Reviewer Qualification 26 4.2 NQA-1 -1994 Commitment 26 SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS ................................. 27 5.1 Procedure Adherence 27 Page 5 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report TABLE OF CONTENTS 5.2 NQA-1 -1994 Commitment 28 SECTION 6 DOCUMENT CONTROL ............................................................................... 28 6.1 Changes to Documents 28 6.2 NQA-1-1994 Commitment 29 SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES ..... 29 7.1 Acceptance of Item or Service 29 7.2 NQA-1-1994 Commitment 30 SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND C O MPO NENTS .................................................................................................................... 31 8.1 NQA-1-1994 Commitment 31 SECTION 9 CONTROL OF SPECIAL PROCESSES ...................................................... 31 9.1 NQA-1 -1994 Commitment 32 SECTION 10 INSPECTION ............................................................................................. 32 10.1 NQA-1-1994 Commitment 32 SECTION 11 TEST CONTROL ....................................................................................... 33 11.1 NQA-1 -1994 Commitment 33 11.2 NQA-1 -1994 Commitment for Computer Program Testing 33 SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT ............................. 33 12.1 NQA-1-1994 Commitment 34 SECTION 13 HANDLING, STORAGE, AND SHIPPING ................................................. 35 13.1 Housekeeping 35 13.2 NQA-1-1994 Commitment 35 SECTION 14 INSPECTION, TEST, AND OPERATING STATUS ..................................... 37 14.1 NQA-1-1994 Commitment 37 SECTION 15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS .............. 37 15.1 NQA-1-1994 Commitment 37 Page 6 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report TABLE OF CONTENTS SECTION 16 CORRECTIVE ACTION .............................................................................. 38 16.1 NQA-1-1994 Commitment 38 SECTION 17 QUALITY ASSURANCE RECORDS ........................................................... 38 17.1 Record Retention 38 17.2 Electronic Records 39 17.3 NQA-1-1994 Commitment 39 SECTIO N 18 AUDITS ........................................................................................................... 39 18.1 Performance of Audits 39 18.2 NQA-1-1994 Commitment 41 PART III REGULATORY COMMITMENTS 42 APPENDIX A: PLANT REVIEW BOARD 43 APPENDIX B: NUCLEAR SAFETY REVIEW BOARD 45 APPENDIX C: QUALITY ASSURANCE SURVEILLANCES 49 APPENDIX D: DEFINITIONS 50 APPENDIX E: PROCEDURES 52 APPENDIX F: QUALITY ASSURANCE OF THE INDEPENDENT SPENT-FUEL STORAGE INSTALLATION 59

Enclosure I Page 7 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report PART I INTRODUCTION SECTION 1 GENERAL This Southern Nuclear Operating Company, Inc., (SNC) Quality Assurance Topical Report (QATR) is the top-level policy document that establishes the quality assurance policy and assigns major functional responsibilities for plants operated by SNC. The QATR describes the methods and establishes quality assurance program and administrative control requirements that meet 10 CFR 50, Appendix B. The QATR is organized and formatted to conform to NRC Standard Review Plan (NUREG 0800) Sections 17.1 and 17.2 (Revision 2 - July 1981) and is based on the requirements of ASME NQA-1 -1994, "Quality Assurance Requirements for Nuclear Facility Applications," Parts I and II, except as specified in this QATR.

The Quality Assurance Program (QAP) is defined by the NRC approved regulatory document that describes the quality assurance program elements (the QATR), along with the associated corporate, fleet, and site specific implementing documents. Corporate Policies and Guidelines establish high level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAP. Nuclear fleet wide procedures establish practices for certain activities which are common to all SNC organizations performing those activities such that the activity is controlled and carried out in a manner that meets QAP requirements. Site or organization specific procedures establish detailed implementation requirements and methods, and may be used to implement Corporate Policies and Guidelines and nuclear fleet wide procedures or be unique to particular functions or work activities.

1.1 Scope/ Applicability This QATR applies to activities affecting the quality and performance of safety-related structures, systems, and components, including, but not limited to:

Designing Receiving Refueling Constructing Storing Operating Procuring Erecting Training Fabricating Installing Inspecting Cleaning Modifying Testing Handling Maintaining Shipping Repairing Safety related systems, structures, and components, under the control of the QATR, are identified for each plant. In addition, systems, structures, and components important to safety, associated with the Independent Spent Fuel Storage Installation (ISFSI), are identified for each plant (if applicable). The technical aspects of these items are considered when determining program applicability, including, as appropriate, the item's design safety function. The QAP may be applied to certain activities where regulations other than 10 CFR 50 establish QA program requirements for activities within their scope. Thus, selected elements of this QATR are applied to the "important to safety" activities of radioactive waste shipping and independent spent fuel Page 8 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report storage, as defined in 10 CFR 71 Subpart H and 10 CFR 72 Subpart G, respectively, as allowed, by 10 CFR 71.101.f and 10 CFR 72.140.d. Accordingly, application of the elements of this QATR for ISFSI is as defined in the respective 10 CFR 72.212 report for each site, as applicable.

The policy of SNC is to assure a high degree of availability and reliability of its nuclear plants while ensuring the health and safety of its workers and the public. To this end, selected elements of the Quality Assurance Program are also applied to certain equipment and activities that are not safety related or important to safety, but support safe, economic, and reliable plant operations, or where other NRC guidance establishes program requirements. These include, but may not be limited to, emergency preparedness, security, radiation protection, and fire protection. Implementing documents establish program element applicability.

1.2 Responsibilities SNC personnel engaged in activities described in this QATR shall comply with the requirements of the Quality Assurance Program. Contractors, or other organizations supporting SNC, are required to comply with the QAP established by this QATR, or with their own programs determined by SNC to include sufficient controls to meet the applicable requirements of 10 CFR 50, Appendix B. All facilities shall be operated in compliance with the applicable Code of Federal Regulations, NRC Operating Licenses, and the applicable laws and regulations of the state and local governments in which the facility is located.

Quality assurance personnel have the authority to stop work actions or plant operations when they perceive that work is not progressing in a manner that meets the quality assurance program.

1.3 Interfaces with Owners Operating service agreements exist between Southern Nuclear Operating Company, Inc. and the nuclear power plant owner organizations to establish responsibilities and authorities, consistent with each facility's NRC Operating License, for the operation and maintenance of said facilities. These agreements designate SNC as the exclusive licensee authorized to operate Joseph M. Farley Nuclear Plant, Edwin I. Hatch Nuclear Plant, and Alvin W. Vogtle Electric Generating Plant in accordance with the terms and conditions of their respective licenses.

1.4 NQA-1-1994 Commitments In establishing, implementing, and maintaining the QATR, SNC commits as described in this QATR to compliance with ASME NQA-1 -1994. QATR revisions are reviewed by SNC Senior Management and approved by the SNC Chief Nuclear Officer. Changes to this QATR will be governed by and made in compliance with 10 CFR 50.54(a).

Page 9 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report NQA-1-1994, Part I, Introduction, Section 4 SNC QAP conforms to the requirements of NQA-1-1994, Section 4. thia inide-With the fGollWing

. larifi.at*o, of the torm ".'Verfiation" Additional definitions of terms used in the QAP and not contained in the NQA-1 -1994 list of definitions are shown in Appendix D to this QATR.

- !ndepondent Verification Verification that required actien have boon completed by an individual other than the percon Who performed the Will net req uir operation OF activiW being verified. Such* erifation conflIrmtoef the identical cIon he other indicatiiie provide acIuranc o dication that the proGecibed activity iv !n fact GOIMpete. ExIIamplec Rincude, but are not limnited to; Verification of a breaker opening by ebsor in remote broakor indication !ightc; Verification of a setpOint (made With a voltmeter Or ammeter, for example) by ebsor~ing the actuation of status or indicating !ightG are the required panel -mete-rind-icated value; verification; tha a valve has been positioed by Gbcor~ing the starting Or Gtopping of flew o m~eter indications Or by rFemte valve position indicating lights-.

- ConcGurrent verification Verification by a coened individual of a component's condition as the action iGbeing performed. Exam:ples include, buit are not limiteAd- to:-e-quipment being remoeved from serviee (provided the equipmfent being remo9ved- fromF Ger00ice %Allnot cause any advese systemf condition);

lifting a lead;: removing a fuse;: and opening a link Page 10 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report PART II QUALITY ASSURANCE PROGRAM DETAILS SECTION 1 ORGANIZATION This Section describes the SNC 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 for each plant.

Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of this QATR. Management gives careful consideration to the timing, extent and effects of organizational structure changes.

1.1 Organizational Structure (Design and Construction)

Design and Construction phases of the Farley Nuclear Plant, the Hatch Nuclear Plant, and the Vogtle Electric Generating Plant (collectively "Plants") are complete.

1.2 Organizational Structure (Operations Phase)

The nuclear operations organization (Figures 11.1-1 and 11.1-2), under the direction of the president and CEO, has direct responsibility for the operation and maintenance of the Plants.

The president and CEO reports to the SNC Board of Directors.

The SNC corporate organization is responsible for assuring the availability of and providing technical support for the Plants. Support capability is available through the efforts of the SNC corporate staff. In addition to being the licensee, SNC also serves as its own architect/engineer.

The structure of the nuclear operations organization is described in the following paragraphs.

Portions of the SNC Technical Support, Corporate Services, and General Counsel and External Affairs organizations are also described in the following paragraphs. The described organizations are depicted in organization charts that are a part of this QATR.

1.2.1 CORPORATE ORGANIZATION This Section provides information concerning functions, responsibilities, and organizational structure of the corporate staff responsible for the management and technical support of the Plants. These corporate organizations provide support for operations and maintenance of the plants including general management, licensing, facility design, design review, design approval, procurement, testing, quality assurance, emergency planning, and security of the plant during the operations phase of the Plants. SNC management is responsible for directing activities of the Plant organizations, as well as the corporate support organizations. The corporate organizations function in a support role to the Plants.

Enclosure I Page 11 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.1.1 President and CEO The president/CEO is responsible for all aspects of operation of Southern Company's nuclear plants. The president/CEO is also responsible for all technical and administrative support activities provided by SNC and contractors. The president/CEO directs the chief nuclear officer/executive vice president, the vice president and general counsel, the vice president corporate services, and the vice president technical support in fulfillment of their responsibilities.

The president/CEO reports to the SNC Board of Directors with respect to all matters.

1.2.1.1.1 Chief Nuclear Officer / Executive Vice President The chief nuclear officer is responsible for the safe, reliable, and efficient operation of the Joseph M. Farley Nuclear Plant (FNP), the Edwin I. Hatch Nuclear Plant (HNP), and the Alvin W. Vogtle Electric Generating Plant (VEGP). The chief nuclear officer directs the vice president

- project (Vogtle), the vice president - project (Hatch), the vice president-project (Farley), the senior manager responsible for quality assurance, and the senior manager responsible for nuclear fleet security and emergency preparedness. The chief nuclear officer has overall responsibility for establishing quality policy and implementation of the quality program. The authority to accomplish quality assurance functions is delegated to the staff as necessary to fulfill the identified responsibilities.

SNC maintains an offsite review board (the Nuclear Safety Review Board (NSRB)) to independently assess the effectiveness of the quality assurance program. The NSRB, which is described in more detail in Appendix B to this QATR, advises the chief nuclear officer on matters related to nuclear power plant safety for all SNC plants and corporate activities.

1.2.1.1.1.1 Vice President - Project The vice president-project for each Plant reports to the chief nuclear officer regarding operation issues and support matters, and is responsible for operation and maintenance of the respective Plant over which they have authority. A vice president-project directs the nuclear plant general manager (NPGM) and the nuclear support general manager (NSGM) for each respective plant.

The vice president - project has overall responsibility for the execution of the administrative controls and quality assurance program at the respective plant to assure nuclear safety for that plant.

1.2.1.1.1.1.1 Nuclear Support General Manager (NSGM)

A NSGM (for each respective Plant) is responsible for coordinating corporate support in the areas of engineering, licensing, maintenance, planning and performance, and budgeting for that Plant. The NSGM directs the planning and performance supervisor. The incumbent is responsible to ensure that appropriate design control and engineering support are provided for the respective Plant. The SNC engineering corporate support organization for the Plant reports on a matrixed basis to the NSGM.

Page 12 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.1.1.1.2 Senior manager responsible for quality assurance The senior manager responsible for quality assurance is responsible for managing the QA program described in the QATR and for ensuring its implementation in accordance with commitments shown herein. The QA organization is composed of a staff at the corporate headquarters and at each Plant site. The QA organization provides comprehensive independent audits of safety-related activities to verify that they are in compliance with the quality assurance program. The quality assurance organization also performs QA Surveillance activities as described in Appendix C of this QATR.

1.2.1.1.1.3 Senior manager nuclear fleet security and emergency preparedness The senior manager responsible for nuclear fleet security and emergency preparedness is responsible for the overall coordination of fleet security activities and programs, the corporate emergency preparedness programs (including the common Emergency Operations Facility),

and the Access Authorization Program. The nuclear fleet security and emergency preparedness manager also has responsibility for site emergency response communication.

1.2.1.1.2 Vice President- Technical Support The vice president - technical support is responsible for providing plant specific and generic engineering support, nuclear fuel and generic special projects, design engineering for plant modifications, project management for major improvement projects, assuring that specialized engineering expertise is available as needed for normal operations and emergency situations, assessing nuclear industry issues through contact with owners and ad hoc groups, nuclear utility interfaces, and assuring that documentation and records of design activities are properly maintained. The vice president - technical support directs the vice president - engineering, senior manager responsible for special projects, and senior manager responsible for nuclear fuel.

The key functional organization within SNC providing support to the Plants is the technical support organization that provides plant support (which includes licensing), engineering support, and design modifications. SNC technical support also provides nuclear fuel contract administration, reload licensing, and special projects management. Support activities provided by these SNC organizations and contractors include, but are not limited to, the following:

A. Design engineering of plant modifications, including maintenance - related design changes, plant improvement - related design changes, and design changes or major plant additions related to new regulatory requirements and commitments. These services include both conceptual and detail design, issuance and maintenance of design drawings and specifications, review/approval of design change requests, incorporation of as-built notices, related quality assurance functions, etc.

B. Design-related evaluation and analysis.

Page 13 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report C. Evaluation and analysis which are not directly related to design (e.g., Technical Specifications changes).

D. Inservice inspection and testing (both planning and actual implementation).

E. Nuclear fuel procurement, nuclear fuel and core design, nuclear fuel reload licensing, dry storage fuel selection, nuclear fuel procurement vendor oversight F. Evaluations on licensing issues.

G. Plant chemistry support.

H. Maintenance support.

1.2.1.1.2.1 Vice President - Engineering The vice president - engineering is responsible for the plant support, project-specific engineering organizations for the Plants. These engineering organizations provide matrixed accountability to the NSGM for their associated project. In addition, the vice president -

engineering is responsible for the generic support organizations including design engineering, licensing services, PRA services, component engineering, materials and inspections services, environmental services, and engineering administrative services. The vice president -

engineering directs the plant support manager, the engineering services manager, the design modifications manager, and the engineering administrative services manager.

1.2.1.1.2.1.1 Senior manager responsible for plant support The senior manager responsible for plant support is responsible for the oversight of each project-specific support manager and respective organization. These project-specific engineering managers provide matrixed accountability to the NSGM for their associated project.

Each of these managers of plant support may draw on the expertise of the other organizations from within SNC engineering, including the design modifications corporate and/or site personnel. The senior manager responsible for plant support also directs the senior manager responsible for licensing and the senior manager responsible for probabilistic risk assessment services.

1.2.1.1.2.1.1.1 Senior manager responsible for licensing The senior manager responsible for licensing directs project-specific licensing and generic licensing activities. The licensing supervisors reporting to the senior manager responsible for licensing provide matrixed accountability to the NSGM for their associated project and are responsible for providing corporate support to Plants in matters related to licensing. Some specific responsibilities of the licensing corporate staff include:

Page 14 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report A. Primary interface with the Nuclear Regulatory Commission (NRC), evaluating regulatory information, and translating NRC requirements.

B. Maintaining the Final Safety Analysis Report (FSAR), Technical Specifications, Emergency Plan, Security Plan, and other licensing documents for each Plant.

1.2.1.1.2.1.2 Senior manager responsible for engineering services The senior manager responsible for engineering services is responsible for providing corporate support to the plants in matters related to component engineering; and maintenance, testing, and inspections at the plants. Some specific responsibilities of the engineering services corporate staff include:

A. Evaluating preventive and corrective maintenance programs and contracted maintenance services.

B. Assessing maintenance-related developments and industry trends for application by or impact on the Plants.

C. Assisting in implementation of maintenance planning and scheduling processes.

This includes outage management and long-term planning support.

D. Coordinating in-service inspection and testing program.

E. Managing chemistry issues.

F. Supporting the SNC plants with component-specific expertise and environmental qualification of equipment.

1.2.1.1.2.1.3 Senior manager responsible for design modifications The senior manager responsible for design modifications is responsible for discipline-specific design engineering functions as well as for serving as the design authority for the SNC plants.

Some specific responsibilities of the design modifications staff include:

A. Providing design modifications and engineering evaluations for the Plants.

B. Revising, controlling, and transmitting domestic drawings, design related vendor documents, and other design related documentation.

C. Providing onsite teams to design and implement minor design changes and other engineering support for maintenance as directed by the site engineering support manager.

Page 15 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.1.1.2.2 Senior manager responsible for special projects The senior manager responsible for special projects is responsible for directing the activities of the special projects organization in managing a variety of projects that are typically strategic in nature and lend themselves to be worked independent of Plant staffs until time of implementation.

1.2.1.1.2.3 Senior manager responsible for nuclear fuel The senior manager responsible for nuclear fuel is responsible for nuclear fuel procurement, fuel and core design, reload licensing, dry cask storage fuel selection, and vendor oversight.

1.2.1.1.2.1.4 Senior manager responsible for engineering administrative services The senior manager responsible for engineering administrative services is responsible for document services, administration of the corrective action program in the corporate headquarters, and engineering training.

1.2.1.1.3 Vice President - Corporate Services The vice president - corporate services reports directly to the president/CEO. The vice president - corporate services is responsible for providing certain corporate administrative services including corporate security, fitness for duty, supply chain management, general services, and financial services. Reporting directly to the vice president - corporate services are the senior manager responsible for supply chain, senior manager responsible for safety and health, and senior manager responsible for information technology.

1.2.1.1.3.1 Senior manager responsible for supply chain The senior manager responsible for supply chain is responsible for procurement, procurement document control, development of sources of supply including the selection of suppliers to be awarded purchase orders or contracts, and materials management activities.

1.2.1.1.3.2 Senior manager responsible for safety and health The senior manager of safety and health is responsible for coordinating the overall Fitness-for-Duty (FFD) program among Southern Nuclear management, the corporate safety and health staff and the safety and health staff at each of the SNC nuclear plants.

Page 16 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.1.1.3.3 Senior manager responsible for information technology The senior manager responsible for information technology is responsible to provide systems development, infrastructure, and support for systems that provide nuclear quality related functions.

1.2.1.1.4 Vice President and General Counsel The vice president and general council reports directly to the president/CEO. The vice president and general counsel is responsible for compliance, employee concerns, communications, and environmental compliance activities for SNC. The vice president and general counsel directs the senior manager responsible for environmental affairs.

1.2.1.1.4.1 Senior manager responsible for environmental affairs The senior manager responsible for environmental affairs is responsible for technical support in the areas of radiological science including low-level radioactive waste activities and non-radiological environmental activities, and maintenance of dosimetry software and other programs.

1.2.2 STANDARD PLANT ORGANIZATION The onsite operating organization shall provide, as part of the normal duties of plant supervisory personnel, timely and continuing monitoring of operating activities to assist the nuclear plant general manager in keeping abreast of general plant conditions and to verify that the day-to-day operating activities are conducted safely and in accordance with applicable administrative controls. The onsite Operating organization shall include one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant, mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance.

1.2.2.1 Nuclear plant general manager The nuclear plant general manager (NPGM) is responsible for direct management of the plant, including operations, training, maintenance, refueling, and technical and administrative activities. The NPGM is responsible for:

A. Compliance with the requirements of the operating license, Technical Specifications, and quality assurance program, and B. Approval, prior to implementation, of each proposed test, experiment, or modification to systems or equipment that impact nuclear safety.

The NPGM directs the plant operations assistant general manager and the plant support assistant general manager.

Enclosure I Page 17 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SNC plants maintain a plant review board (PRB) at each plant to review overall plant operations, and advise plant site management on matters related to nuclear safety. Appendix A provides a detailed description of these PRBs.

1.2.2.1.1 Plant operations assistant general manager The plant operations assistant general manager (POAGM) is responsible for the operation of the plant. Reporting to the plant operations assistant general manager are the senior manager responsible for maintenance, the senior manager responsible for operations, the senior manager responsible for chemistry, the senior manager responsible for health physics, and the senior manager responsible for work controls.

1.2.2.1.1.1 Senior manager responsible for maintenance The senior manager responsible for maintenance directs the maintenance personnel in performance of preventive maintenance, repair of plant equipment, performance of assigned quality control measures, and maintenance support utilizing contractor craft personnel.

1.2.2.1.1.2 Senior manager responsible for operations The senior manager responsible for operations is responsible for the safe and reliable operation of the plant. This includes unit operations; day-to-day planning; technical support; preparation for and conduct of outage related activities; and overseeing outage work activities, surveillances, and tests.

In addition, 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 unexplained or unscheduled power reduction.

" The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.

• The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.

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

" The responsibility to review routine operating data to assure safe operation.

• The responsibility to take action to minimize personnel injury or damage to the facility and to protect the health and safety of the public in the event of an emergency not covered by approved procedures.

Page 18 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.2.1.1.3 Senior manager responsible for chemistry The senior manager responsible for chemistry is responsible for chemical and radiochemical activities at the plant; chemistry related engineering activities including filter / demineralizer control and hydrogen water chemistry; administrative control of effluent releases from the plant to ensure that the releases are maintained as low as reasonably achievable (ALARA) and within the required limits; and implementing primary, secondary, and component cooling water chemistry programs.

1.2.2.1.1.4 Senior manager responsible for health physics The senior manager responsible for health physics is responsible for the radiation protection and for the maintenance of all required radiation exposure records of plant support and visiting personnel; and provides radiation surveys and minimization of occupational radiation exposure (ALARA program); manages the shipping and receiving of all byproduct, source, and special nuclear material except fuel; manages the radwaste management program including radwaste cleaning / processing performed by operations; and manages the personnel dosimetry and respiratory protection programs.

1.2.2.1.1.5 Senior manager responsible for work controls The senior manager responsible for work controls is responsible for ensuring maximum advantage is taken of forced outages and load reductions to do needed repair, replacement, modification, and inspection work; working with Maintenance to ensure management control of work is accomplished through the use of an effective priority system; preparing Outage Safety Assessments in support of scheduled refueling outages; and conducting on going outage risk assessments.

1.2.2.1.2 Plant support assistant general manager The plant support assistant general manager (PSAGM) is responsible for supporting the operations and maintenance of the plant. This includes providing engineering support, training, emergency planning, nuclear security plan implementation, and performance analysis.

1.2.2.1.2.1 Senior manager responsible for engineering support The senior manager responsible for engineering support is responsible to oversee technical and engineering projects and programs in support of maintenance and operations, including but not limited to quality control inspections; evaluate nuclear, thermal, and hydraulic performance of reactor and turbine systems; provide systems engineering, discipline engineering, minor design changes and modifications; manage the site design change process; plan for contractor activities involving steam generators, reactor vessel inspections, and fuel issues; and provide reviews for potential 10 CFR 21 reportability.

Page 19 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 1.2.2.1.2.2 Senior manager responsible for plant security The senior manager responsible for plant security is responsible to maintain the security department in accordance with the security plan, training and qualification plan, and contingency plan for the Plant; control safeguards material; maintain interfaces with offsite agencies; and coordinate the security drill and exercise program.

1.2.2.1.2.3 Senior manager responsible for training and emergency preparedness The training and emergency preparedness manager is responsible for developing and maintaining a training / retraining program for plant personnel that meets requirements for INPO accreditation and that meets the security plan and emergency response plans; maintaining the training simulator; and for managing the onsite emergency preparedness effort.

1.2.2.1.3 Senior manager responsible for performance analysis The senior manager responsible for performance analysis is responsible to administer the plant corrective action program; lead analyses; develop and implement plans that work to identify and to close key performance gaps; coordinate problem solving teams to focus plant performance improvements; and develop and maintain plant performance monitoring, action tracking and communications to monitor and communicate progress in performance changes. In addition, this position is responsible for managing the document control function for the plant.

1.3 NQA-1-1994 Commitment In establishing its organizational structure, SNC commits to compliance with NQA-1 -1994, Basic Requirement 1 and Supplement 1S-1.

Enclosure I Page 20 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Figure 11.1-1: CORPORATE ORGANIZATION CHART President and SEM 1..2.1.1.3 S Vi President ce SenptioMareint Pi or-C ate ]*

• Maner an d for Special Responsible for Supply Responsible for fleResponsible

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________ i Page 22 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SECTION 2 QUALITY ASSURANCE PROGRAM SNC has established the necessary measures and governing procedures to implement the QAP as described in the QATR. SNC is committed to meeting this QAP in all aspects of work that are important to the safety and reliability of the nuclear plants as described and to the extent delineated in this QATR. Further, SNC ensures through the systematic process described herein that its suppliers of safety related equipment or services meet the applicable requirements of 10 CFR 50, Appendix B. Senior management is regularly apprised of audit results evaluating the adequacy of implementation of the QAP through the audit functions described in the Audit Section of this QATR.

2.1 Responsibilities Personnel who work directly or indirectly for SNC are responsible for the achievement of acceptable quality in the work covered by this QATR. This includes those activities delineated in Part I, Section 1.1 of this QATR. SNC personnel performing verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QAP are performed 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 qualitative acceptance criteria as applicable or 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. The senior manager responsible for quality assurance is responsible to verify that processes and procedures comply with QATR and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance.

2.2 Delegation of Work SNC retains and exercises the responsibility for the scope and implementation of an effective QAP. Positions identified in the Organization Section of this QATR may delegate all or part 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 are made at the level appropriate for its nature and effect, and with any necessary technical advice or review.

Deleaated responsibilities may also be performed under a supplier's or principle contractor's quality assurance program, provided that the supplier or principle contractor has been approved as a supplier in accordance with the QATR. Periodic audits and assessments of supplier QA proqrams are performed in accordance with Section 18 of the QATR to assure compliance with the supplier's or principle contractor's quality assurance program and implementing procedures.

In addition, routine interfaces with proiect personnel assure that quality expectations are met.

Page 23 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 2.3 Personnel Qualifications Personnel assigned to implement elements of the QAP shall be capable of performing their assigned tasks. To this end SNC establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the QAP to assure that suitable proficiency is achieved and maintained. Plant and support staff minimum qualification requirements are as delineated in each site's Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications. Sufficient managerial depth is provided to 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 established in the applicable SNC procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAP elements to be employed. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained.

The minimum qualifications of the senior manager responsible for quality assurance are that the manager holds an engineering degree, or a degree in a related science, and has a minimum of five year's experience in the areas of engineering, field construction, or plant operations. Two of these five years must involve working under a nuclear quality assurance program.

2.4 NQA-1-1994 Commitment In establishing qualification and training programs, SNC commits to compliance with NQA-1 -1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications and exceptions:

NQA-1-1994, Supplement 2S-1

- SNC Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 the same as if it were part of the Supplement. The following two alternatives may be applied to the implementation of this Supplement and Appendix:

(1) In lieu of being certified as Level 1,11, or III in accordance with NQA-1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determine who will be Page 24 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors. For the purpose of these functions, a qualified engineer is one who has a baccalaureate in engineering in a discipline related to the inspection activity (such as electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities.

• NQA-1-1994, Supplement 2S-2

- In lieu of Supplement 2S-2, for qualification of nondestructive examination personnel, SNC will follow the applicable standard cited in the version(s) of Section III and Section Xl of the ASME Boiler and Pressure Vessel Code approved by the NRC for use at SNC sites.

" NQA-1-1994, 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 demonstrate his/her ability to properly implement the audit process, as implemented by SNC, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear audit within the year preceding the date of qualification."

SECTION 3 DESIGN CONTROL SNC has established and implements a process to control the design, design changes and temporary modifications (e.g. temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) of items that are subject to the provisions of this QATR. The design process includes provisions to control design inputs, outputs, changes, interfaces, records and organizational interfaces. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output can be related to the design input in sufficient detail to permit verification. Design change processes and the division of responsibilities for design related activities are endorsed by the SNC design authority. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution and revision of design inputs and outputs. Design changes and disposition of nonconforming items as "use as is" or "repair" are reviewed and approved by the SNC design organization or by other organizations so authorized by the design authority.

Page 25 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted wires, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal verifications and status tracking.

3.1 Design Verification SNC design processes provide for design verification to ensure that items and activities subject to the provisions of this QATR are suitable for their intended application, consistent with their effect on safety. Design changes are subjected to these controls, which include verification measures commensurate with those applied to original plant design.

Design verifications are performed by competent individuals or groups other than those who performed the original design but who may be from the same organization. The verifier shall not have taken part in the selection of design inputs, the selection of design considerations, or the selection of a singular design approach, as applicable. This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, rule out certain design considerations, did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification.

If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management.

The extent of the design verification required is a function of the importance to safety of the item under consideration, the complexity of the design, the degree of standardization, the state-of-the-art, and the similarity with previously proven designs. This includes design inputs, design outputs and design changes. Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented. Verification methods 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 item's intended use.

SNC normally completes design verification activities 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 design verification is completed before relying on the item to perform its intended design or safety function.

3.2 Design Records SNC maintains records sufficient to provide evidence that the design was properly accomplished. These records include the final design output and any revisions thereto, as well as record of the important design steps (e.g., calculations, analyses and computer programs) and the sources of input that support the final output.

Enclosure I Page 26 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Plant design drawings reflect the properly reviewed and approved configuration of the plant.

3.3 NQA-1-1994 Commitment In establishing its program for design control and verification, SNC commits to compliance with NQA-1 -1994, Basic Requirement 3, and Supplement 3S-1.

SECTION 4 PROCUREMENT DOCUMENT CONTROL SNC has established the necessary measures and governing procedures to assure that purchased items (components, spares and replacement parts necessary for plant design, construction, operation, refueling, maintenance and modifications) and services 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 the original requirements to assure the items are suitable for the intended service, and are of acceptable quality, consistent with their effect on safety. Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents. These controls include provisions such that:

" Where original technical or quality assurance requirements cannot be determined, an engineering evaluation is conducted and documented by qualified staff to establish appropriate requirements and controls to assure that interfaces, interchangeability, safety, fit and function, as applicable, are not adversely affected or contrary to applicable regulatory requirements.

" Applicable technical, regulatory, administrative, quality and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR 21) are invoked for procurement of items and services. Applicable design bases and other requirements necessary to assure adequate quality shall be included or referenced in documents for procurement of items and services. To the extent necessary, procurement documents shall require suppliers to have a quality assurance program consistent with the applicable requirements of this QATR.

4.1 Reviewer Qualification Reviews required by this Section shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents.

4.2 NQA-1-1994 Commitment In establishing controls for procurement, SNC commits to compliance with NQA-1-1994, Basic Requirements 4 and Supplements 4S-1, with the following clarifications and exceptions:

Page 27 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report NQA-1-1994, Supplement 4S-1

- Section 2.3 of Supplement 4S-1 includes a requirement that procurement documents require suppliers to have a documented quality assurance program that implements NQA-1-1994, Part 1. In lieu of this requirement, SNC may require suppliers to have a documented supplier quality assurance program that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of the procurement.

With regard to service performed on a plant site by a supplier, SNC procurement documents may allow the supplier to work under the SNC quality assurance program, including implementing procedures, in lieu of the supplier having its own quality assurance program.

- Seotion 3 of Suppl..o.tA 4S1 roquiroc prOcUromont dcum.nt- to bo roviowod prorF to bid or award of contract. The quality assuranco roe'i8W of procuromont documcntS i6 satisfied through ro'AoW of the applicable prOcUroMont spocification, including the tochnical and quality prOcueromn r.quir....ts, prior to bid Or awar.d of contract.

SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS SNC has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures or drawings of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria to implement the QAP as described in the QATR. Such documents are prepared and controlled according to Part II, Section 6 of this QATR. In addition, means are provided for dissemination to plant staff of instructions of both general and continuing applicability, as well as those of short-term applicability. Provisions are included for reviewing, updating, and canceling such procedures.

5.1 Procedure Adherence The SNC policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures. Where procedures cannot be followed as written, provisions are established for making changes in accordance with Part II, Section 6 of this QATR. Requirements are established to identify the manner in which procedures are to be implemented, including identification of those tasks that require: (1) the written procedure to be present and followed step-by-step while the task is being performed, (2) the user to have committed the procedure steps to memory, (3) verification of completion of significant steps, by initials or signatures or use of check-off lists. Procedures that are required to be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, tasks that are infrequently performed, and tasks where steps must be performed in a specified sequence.

Page 28 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Administrative procedures prescribe the methods whereby plant procedures can be temporarily revised without undue delay when the need arises. Temporary procedure revisions that do not change intent of the approved procedure may be made with the concurrence of two individuals, one of which holds a senior reactor operator's license on the affected unit. Such revisions are documented and, if required, reviewed by the Plant Review Board and approved by the appropriate plant management within 14 days of implementation. In cases of emergency, personnel are authorized to depart from approved procedures when necessary to prevent injury to personnel or damage to the plant. Such procedures are logged describing the prevailing conditions and reasons for the action taken.

5.2 NQA-1-1994 Commitment In establishing procedural controls, SNC commits to compliance with NQA-1 -1994, Basic Requirement 5. In addition, as stated in position C.1 of Regulatory Guide 1.33, Revision 2, SNC commits to use Appendix A of Regulatory Guide 1.33 as guidance for establishing the types of procedures that are necessary to control and support plant operation. Appendix E of this QATR provides additional details regarding procedures developed and implemented by SNC.

SECTION 6 DOCUMENT CONTROL SNC has established the necessary measures and governing procedures to control the preparation of, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality are controlled to assure that correct documents are being employed. Such documents, including changes thereto, shall be reviewed for adequacy and approved for release by authorized personnel. The control system shall be documented and shall provide for (a) through (Ge) below:

(a) identification of documents to be controlled and their specified distribution; (b) identification of assignment of responsibility for preparing, reviewing, approving, and issuing documents; (c) review of documents for adequacy, completeness, and correctness prior to approval and issuance,-

(d) coordinating and controlling interface documents and procedures: and (e) a method for providina feedback from users to continually improve procedures and work instructions.

6.1 Changes to Documents Changes to documents, other than those defined in implementing procedures as minor changes, are considered as major changes and shall be reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization shall have access to pertinent background data or information upon which to base their approval. Minor changes to documents, such as inconsequential editorial corrections, shall not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a Page 29 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a decision shall be clearly delineated in implementing procedures.

6.2 NQA-1-1994 Commitment In establishing provisions for document control, SNC commits to compliance with NQA 1994, Basic Requirement 6 and Supplement 6S-1.

SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES SNC has established the necessary measures and governing procedures to control the procurement of items and services to assure conformance with specified requirements. Such control shall provide for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the Supplier, source inspection, audit, and examination of items or services upon delivery or completion.

7.1 Acceptance of Item or Service SNC establishes and implements measures to assure the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item's or service's importance to safety, complexity, quantity and the frequency of procurement. Verification actions include testing, as appropriate, during design, fabrication and construction activities, including those associated with plant maintenance or modifications. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier.

Measures to assure the quality of purchased items and services include the following, as applicable:

• Items are inspected, identified, and stored to protect against damage, deterioration, or misuse.

• Prospective suppliers of safety-related items and services are evaluated to assure that only qualified suppliers are used. Qualified suppliers are audited on a triennial basis.

SNC may utilize audits conducted by outside organizations for supplier qualification provided that the scope and adequacy of the audits meet SNC requirements.

Documented annual evaluations are performed for qualified suppliers to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, Nuclear Procurement Issues Committee (NUPIC), or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. 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 Page 30 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.

" 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 completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.

" Controls are imposed for the selection, determination of suitability for intended use (critical characteristics), evaluation, receipt and acceptance of commercial-grade services or "off-the-shelf" items to assure they will perform satisfactorily in service in safety related applications.

7.2 NQA-1-1994 Commitment In establishing procurement verification controls, SNC commits to compliance with NQA-1 -1994, Basic Requirement 7 and Supplement 7S-1, with the following clarifications and exceptions:

NQA-1-1994, Supplement 7S-1

- SNC considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to SNC plants are not required to be evaluated or audited.

- When purchasing commercial grade calibration services from a calibration laboratory, procurement source evaluation and selection measures need not be performed provided each of the following conditions are met:

(1) The purchase documents impose any additional technical and administrative requirements, as necessary, to comply with the SNC QA program and technical provisions. At a minimum, the purchase document shall require that the calibration certificate/report include identification of the laboratory equipment/standard used.

(2) The purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.

(3) A documented review of the supplier's accreditation shall be performed and shall include a verification of each of the following:

The calibration laboratory holds aia domestic accreditation by the National Voluntary Laboratory Accreditation Program (NVLAP) or by the American Association for Laboratory Accreditation (A2LA) as recognized by NVLAP through a-the Page 31 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report International Laboratory Accreditation Cooperation (ILAC)

Mutual Recognition Arrangement (MRA).

" The accreditation is based on ANS/ISO/IEC 17025.

" The published scope of accreditation for the calibration laboratory covers the necessary measurement parameters, ranges, and uncertainties.

- For Section 8.1, SNC considers documents that may be stored in approved electronic media under SNC control and not physically located on the plant site but which are accessible from the respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site.

- In lieu of the requirements of Section 10, Commercial Grade Items, controls for commercial grade items and services are established in SNC documents using the guidance of EPRI NP-5652 as discussed in Generic Letter 89-02 and Generic Letter 91-05.

SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS SNC has established the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life. The identification of items is maintained throughout fabrication, erection, installation and use so that the item can be traced to its documentation, consistent with the item's effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item.

8.1 NQA-1-1994 Commitment In establishing provisions for identification and control of items, SNC commits to compliance with NQA-1 -1994, Basic Requirement 8 and Supplement 8S-1.

SECTION 9 CONTROL OF SPECIAL PROCESSES SNC has established the necessary measures and governing procedures to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using qualified procedures and equipment.

Special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator,

Enclosure I Page 32 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product.

9.1 NQA-1-1994 Commitment In establishing measures for the control of special processes, SNC commits to compliance with NQA-1-1994, Basic Requirement 9 and Supplement 9S-1.

SECTION 10 INSPECTION SNC has established the necessary measures and governing procedures to implement inspections that assure items, services and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Inspection may also be applied to items, services and activities affecting plant reliability and integrity. Types of inspections may include those verifications related to procurement, 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 results shall be documented. Where quality verification inspections at plants are performed by the maintenance organization, the inspectors report to the engineering support organization while performing inspections in order to meet the independence requirements of NQA-1-1994, Supplement 1OS-1, Section 3.1.

10.1 NQA-1-1994 Commitment

- In establishing inspection requirements, SNC commits to compliance with NQA-1-1994, Basic Requirement 10, Supplement 1OS-1 and Subpart 2.4, with the clarification that follows below. In addition, for situations comparable to original new plant construction, SNC commits to compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspection requirements.

" Subpart 2.4 commits SNC to IEEE 336-1985. IEEE 336-1985 refers to IEEE 498-1985. Both IEEE 336 -1985 and IEEE 498-1985 use the definition of "Safety Systems Equipment" from IEEE 603- 1980. SNC commits to the definition of Safety Systems Equipment in IEEE 603-1980, but does not commit to the balance of that standard.

" An additional exception to Subpart 2.4 is contained in Section 12 of this QATR.

Page 33 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SECTION 11 TEST CONTROL SNC has established the necessary measures and governing procedures to demonstrate that items subject to the provisions of this QATR will perform satisfactorily in service, that the plant can 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, pre-operational tests, post-maintenance tests, post-modification tests, in-service 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. Programs also include provisions for establishing and adjusting test schedules and maintaining status for periodic or recurring tests. Tests are performed according to applicable procedures that include, consistent with the effect on safety, (1) instructions and prerequisites to perform the test, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion. Test results are documented and evaluated by the organization performing the test and reviewed by a responsible authority to assure that the test requirements have been satisfied. If acceptance criteria are not met, retesting is performed as needed to confirm acceptability following correction of the system or equipment deficiencies that caused the failure.

11.1 NQA-1-1994 Commitment In establishing provisions for testing, SNC commits to compliance with NQA-1 -1994, Basic Requirement 11 and Supplement 11S-1.

11.2 NQA-1-1994 Commitment for Computer Program Testing SNC establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, and used such that the expected output is obtained and configuration control maintained. To this end SNC commits to compliance with the requirements of NQA-1 -1994, Basic Requirement 11, Supplement 11 S-2 and Subpart 2.7 to establish the appropriate provisions.

SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT For the operations phase of the plants, SNC has established and implements procedures for the calibration and adjustment of instrument and control devices installed in the plants. The calibration and adjustment of these installed devices is accomplished through the plant maintenance programs to ensure that each plant is operated within its design and technical requirements. Appropriate documentation will be maintained for these devices to indicate the control status, when the next calibration is due, and identify any limitations on the use of the device.

SNC has also established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment that is not installed as plant

Enclosure I Page 34 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report equipment and that provides information important to safe plant operation. The provisions of such procedures cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment.

The provisions of this QATR Section are intended to 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 interval is not appropriate.

• Measuring and test equipment is labeled, tagged or otherwise controlled to indicate its calibration status and provide traceability to 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 standards have an accuracy that ensures the equipment being calibrated will be within the required tolerance.

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

Calibration standards have greater accuracy than the standards being calibrated, except where the same accuracy as the instruments being calibrated can be shown to be adequate for the service requirements.

• Measuring and test equipment found out of calibration is tagged or segregated and not used until it is successfully re-calibrated. An evaluation is performed to determine the acceptability of any items measured, inspected or tested with an out-of-calibration device from the time of the previous calibration.

12.1 NQA-1-1994 Commitment In establishing provisions for control of measuring and test equipment, SNC 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, with the following clarifications and exceptions:

• NQA-1-1994, Subpart 2.16 (ANSI/IEEE 498-1985)

- Section 5.5 of ANSI/IEEE 498-85 requires all M&TE to be labeled. SNC plants may not label certain M&TE, such as installed instrumentation, but will provide other means of identification so that appropriate controls can be implemented. This exception also applies to labeling and tagging of items requiring calibration as discussed in Section 7.2.1 of ANSI/IEEE 336-85 (NQA-1, Subpart 2.4).

Page 35 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SECTION 13 HANDLING, STORAGE, AND SHIPPING SNO has established the necessary measures and governing procedures to control the handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage or loss, and to minimize deterioration. These provisions include specific procedures, when required to maintain acceptable quality of the items important to safety.

Items are appropriately marked and labeled during packaging, shipping, handling and storage to identify, maintain, and preserve the item's integrity and indicate the need for special controls.

Special controls (such as containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels and temperature levels) are provided when required to maintain acceptable quality.

13.1 Housekeeping 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 and protection, disposal of combustible material and debris, control of access to work areas, protection of equipment, radioactive contamination control and storage of solid radioactive waste. Housekeeping practices help assure that only proper materials, equipment, processes and procedures are used and that the quality of items is not degraded. 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.

13.2 NQA-1-1994 Commitment In establishing provisions for handling, storage and shipping, SNC commits to compliance with NQA-1 -1994, Basic Requirement 13 and Supplement 13S-1. SNC also commits to compliance with the requirements of NQA-1 -1994, Subparts 2.1, 2.2, and 2.3, with the following clarifications and exceptions:

NQA-1-1994, Subpart 2.1

- Subpart 2.1, Sections 3.1 and 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, SNO plants may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. SNC establishes appropriate cleanliness controls for work on safety related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign materials prior to system closure.

Page 36 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report NQA 1994, Subpart 2.2

- Subpart 2.2, Sections 3.2 and 3.5: For items in storage, as determined by facility management, the packaging requirements described under Section 3, Packaging, may include alternate methods of affording required protection such as maintaining a storage atmosphere free from harmful contaminants in concentrations that could produce damage to the stored items, or utilizing storage practices that obviate the need for capping all openings.

- Subpart 2.2, Section 6.6, "Storage Records:" This section requires written records be prepared containing information on personnel access. As an alternative to this requirement, SNC documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However,, these records of access are not considered quality records and will be retained in accordance with the administrative controls of the applicable plant.

- Subpart 2.2, Section 7.1 refers to Subpart 2.15 for requirements related to handling of items. The 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 requirements for which there is no NRC regulatory position. In lieu of compliance with Subpart 2.15, SNC establishes and implements controls 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," SNC performs dynamic load testing over the full range of the lift using test loads at least 110% of the lift weight. Dynamic tests include raising, lowering and traversing the load. Where required, SNC complies with applicable hoisting, rigging and transportation regulations and codes.

NQA-1 -1994, Subpart 2.3 requires a written record of the entry and exit of all personnel be established and maintained for Zones 1,11, and Ill. The following exceptions are taken:

- Instead of the five-level zone designation in Subpart 2.3, Section 2.2, SNC bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

Page 37 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SECTION 14 INSPECTION, TEST, AND OPERATING STATUS SNC has established the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of this QATR in order to maintain personnel and reactor safety and avoid unauthorized operation of equipment. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

14.1 NQA-1-1994 Commitment In establishing measures for control of inspection, test and operating status, SNC commits to compliance with NQA-1-1994, Basic Requirement 14.

SECTION 15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS SNC has established the necessary measures and governing procedures to control items, including services, which do not conform to specified requirements to prevent inadvertent installation or use. Controls provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations. These controls require that an individual discovering a nonconforming condition to identify, describe, and document the nonconformance in accordance with Section 16, Corrective Action, of this QATR. Controls are provided to address conditional release of nonconforming items for use on an at risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires the approval of the Plant General Manager or his designee. Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety function. Nonconformances are evaluated for impact on operability of quality structures, systems, and components to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconformances to design requirements dispositioned repair or use-as-is, shall be subject to design control measures commensurate with those applied to the original design.

Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the Plant General Manager. Significant trends are reported to the Plant General Manager in accordance with SNC procedures, regulatory requirements, and industry standards.

15.1 NQA-1-1994 Commitment In establishing measures for nonconforming materials, parts, or components, SNC commits to compliance with NQA-1-1994, Basic Requirement 15, and Supplement 15S-1.

Page 38 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report SECTION 16 CORRECTIVE ACTION SNC has established the necessary measures and governing procedures to promptly identify, control, document, classify, and correct conditions adverse to quality. SNC procedures require personnel to identify known conditions adverse to quality and assure that corrective actions is are documented and initiated following the dotor...inati of a condition ad"orco, to quaig... in accordance with regulatory guidance and applicable quality standards. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, SNC documents establish the requirements for documentation and timely evaluation of the issue.

Results of evaluations of conditions adverse to quality are analyzed to identify trends.

Significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management.

16.1 NQA-1-1994 Commitment In establishing provisions for corrective action, SNC commits to compliance with NQA-1-1994, Basic Requirement 16.

SECTION 17 QUALITY ASSURANCE RECORDS SNC has established the necessary measures and governing procedures to ensure that sufficient records of items and activities affecting quality are developed, reviewed, approved, issued, used, and revised to reflect completed work. The provisions of such procedures establish the scope of the records retention program for SNC and include requirements for records administration, including receipt, preservation, retention, storage, safekeeping, retrieval, and final disposition. For activities governed by 10 CFR 71 or 72, these provisions address the specific requirements of Sections 71.135 and 72.174.

17.1 Record Retention Records of activities for design, engineering, procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits include the appropriate content requirements of NQA-1 -1994, Parts I and II. Such records and their retention times are based on Regulatory Position C.2, Table 1, of Regulatory Guide 1.28, Revision 3. This table addresses design, construction, and initial start-up records and will be applied to operating and decommissioning phase records that are similar in nature to the construction records. Additional operations phase records and their retention periods are identified in the respective FSAR for each plant. In addition, SNC uses the list of records in 10 CFR 71.135 and 10 CFR 72.174 to establish the types of records that will be created and retained in support of transportation and storage operations governed by 10 CFR Part 71 and Part 72, respectively. In all cases where state, local, or other agencies have more restrictive requirements for record retention, those requirements will be met.

Page 39 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 17.2 Electronic Records When using electronic records storage and retrieval systems, SNC complies with NRC guidance in RIS 2000-18, October 2000, "Guidance on Managing Quality Assurance Records in Electronic Media" including NIRMA guidelines; TG 11-1998, TG15-1998, TG16-1998, and TG21-1998. SNC will also meet the NRC Regulatory Position C.2 of Regulatory Guide 1.28, Revision 3, August 1985 except that the reference to ASME NQA-1 will be to the 1994 edition.

17.3 NQA-1-1994 Commitment In establishing provisions for records, SNC commits to compliance with NQA-1 -1994, Basic Requirement 17 and Supplement 17S-1, with the following clarifications and exceptions:

NQA-1-1994, Supplement 17S-1

- 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 SNC, the records are suitably stored in steel file cabinets or on shelving in containers, except that methods other than binders, folders or envelopes may be used to organize the records for storage.

SECTION 18 AUDITS SNC has established the necessary measures and governing procedures to implement audits to verify that activities covered by this QATR are performed in conformance with the requirements established. The audit programs are themselves reviewed for effectiveness as a part of the overall audit process. In addition to audits, SNC commits to perform surveillances as described in Appendix C to this QATR.

18.1 Performance of Audits Audits of facility activities shall be performed under the cognizance of the NSRB. Each audit shall be performed within the specified time interval with the following allowances:

Audits shall be performed at the intervals designated herein for each audit area.

Schedules shall be based on the month in which the audit starts.

A maximum extension not to exceed 25% of the audit interval shall be allowed. That is, for audits on a 24 month frequency, the maximum time between specific audits shall not exceed 30 months. Likewise, audits on an annual (12 month) frequency shall not be extended beyond 15 months.

When an audit interval extension greater than one month is used, the next audit for that particular audit area will be scheduled from the original anniversary month rather than from the month of the extended audit.

Enclosure I Page 40 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report The following audits of facility activities are required:

• The conformance of reactor and plant operation to provisions contained within the technical specifications and applicable license conditions, at least once per 24 months;

• The performance, training, and qualifications of the entire plant staff, at least once per 24 months;

• The results of actions taken to correct deficiencies occurring in plant equipment, structures, systems, or method of operation that affect nuclear safety, at least once per 24 months;

• The performance of activities required by the quality assurance program to meet the criteria of 10 CFR50, Appendix B, at least once per 24 months;

• The emergency plan and implementing procedures, at least once per 12 months;

• The security plan and implementing procedures, at least once per 24 months;

• The fire protection program, at least once per 24 months. The audit will include the fire protection program implementation, fire protection equipment, procedures, and program controls. At least once per 36 months, the audit team will include an outside qualified fire protection consultant.

• The radiological environmental monitoring program and the results thereof at least once per 24 months;

" The offsite dose calculation manual (ODCM) and implementing procedures, at least once per 24 months;

• The process control program (PCP) and implementing procedures for processing and packaging of radioactive waste, at least once per 24 months;

• The environmental protection plan (EPP), at least once per 24 months;

• Any other area of plant operation considered appropriate by the Nuclear Safety Review Board or the plant vice-president.

Audit of supplier activities shall be performed at 36 month intervals, and evaluations shall be performed at 12 month intervals. A maximum extension not to exceed 25% of the audit or evaluation interval shall be allowed. The combined time interval for any three consecutive audit or evaluation intervals should not exceed 3.25 times the specified audit or evaluation interval.

Audit schedule changes reflecting more frequent audits are required by one or more of the following conditions:

Page 41 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report

• When significant changes are made in functional areas of the QAP, such as significant reorganization or procedure revisions.

• When there is evidence that the performance or reliability of safety-related items is in jeopardy due to deficiencies or nonconformances in the QAP.

• When a systematic, independent assessment of QAP effectiveness is necessary.

• When it is necessary to verify implementation of required corrective actions.

18.2 NQA-1-1994 Commitment In establishing the independent audit program, SNC commits to compliance with NQA-1-1994, Basic Requirement 18 and Supplement 18S-1.

Page 42 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report PART III REGULATORY COMMITMENTS NRC Regulatory Guides and Quality Assurance Standards.

This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the SNC QA Program.

Southern Nuclear commits to compliance with these standards to the extent described herein. Commitment to a particular Regulatory Guide or other QA standard does not constitute a commitment to the Regulatory Guides or QA standards that may be referenced therein.

Regulatory Guide 1.8 - Qualification and Training of Personnel for Nuclear Power Plants

- Southern Nuclear meets the requirement of the applicable Technical Specifications for each plant for the selection and training of nuclear power plant personnel.

- The SNC nuclear plant qualification and training program is described in Sections 13.1 and 13.2 of the FSARs.

Regulatory Guide 1.28, Revision 3, August, 1985 - Quality Assurance Program Requirements (Design and Construction)

- Southern Nuclear meets the requirements of this regulatory guide for Construction Activities conducted by Southern Nuclear, except that ASME NQA-1 -1994 edition (as modified by the exceptions to NQA-1 -1994 as shown in this QATR) will be used in place of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1 a-1 983 Addenda.

Regulatory Guide 1.33, Revision 2, February 1978 - Quality Assurance Program Requirements (Operation)

- Southern Nuclear considers that the collective quality assurance requirements of this QATR and the QA requirements of ASME NQA-1-1994 are equivalent to ANSI N1 8.7-1976/ANS-3.2 and Regulatory Guide 1.33, Revision 2. Consequently, Southern Nuclear does not commit to ANSI N18.7-1976, or to Regulatory Guide 1.33, except that Appendix A of Regulatory Guide 1.33 shall be used as guidance for establishing the procedures required for plant operational phase activities.

Page 43 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX A: PLANT REVIEW BOARD 1.0 General The plant review board (PRB) shall advise the nuclear plant general manager (NPGM) on matters related to nuclear power plant safety for the respective plant 2.0 Membership The PRB shall be composed of a minimum of five members. The NPGM responsible for facility operations shall appoint, in writing, the members of PRB, including the PRB Chairperson and the Vice Chairperson(s) drawn from the committee members. A representative from the Quality Assurance organization shall be a non-voting member.

Alternate members shall be appointed in writing by the PRB Chairperson to serve on a temporary basis. Each alternate shall meet the minimum qualifications for the PRB member that the Alternate is replacing, and shall have the same area of expertise as the member being replaced.

3.0 Meetings The PRB shall meet at least once per calendar month, or more frequently if convened by the PRB Chairperson.

A quorum of the PRB shall consist of the Chairperson or Vice Chairperson plus two voting members, or one voting member and one designated voting alternate. However, if more than the a minimum number of members are present to meet the requirement for a quorum, a maximum of one third of the voting membership may be designated alternates.

For any PRB decision affecting site-wide issues, the Chairperson shall ensure appropriate representation.

4.0 Reviews The PRB shall be responsible for:

(a) Review of (1) all procedures and programs required by facility Technical Specifications administrative controls and changes thereto that require a regulatory evaluation under the facility's 10 CFR 50.59 and 10 CFR 72.48 screening program, (2) changes to the quality assurance program description determined to be reductions in the commitment under the provisions of 10 CFR 50.54(a), and (3) any other proposed procedures, programs, or changes thereto affecting facility nuclear safety as determined by the NPGM.

(b) Review of all proposed changes to nuclear facility Technical Specifications.

(c) Review of all proposed tests and experiments that affect nuclear safety.

Enclosure I Page 44 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report (d) Review of all proposed changes or modifications to systems or equipment that affect nuclear safety.

(e) Rendering determinations in writing or meeting minutes if any item considered under (a) through (d) above, as appropriate and as provided by 10 CFR 50.59, 10 CFR 50.92, or 10 CFR 72.48, requires a license amendment or requires a significant hazards consideration determination.

(f) Performance of special reviews and investigations and reports as requested by the Chairperson of the PRB or NPGM.

(g) Investigations of all violations of Technical Specifications, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the NPGM, Project Vice President, the CNO, and to the Chairperson of the NSRB.

(h) Review of all nuclear facility reportable events.

(i) Review of facility operations to detect potential safety hazards.

5.0 Authority The PRB shall, recommend to the NPGM written approval or disapproval in meeting minutes of items considered under Responsibilities (a) through (i) above. The NPGM will report any issues that require higher level of authority to the Project Vice President.

The PRB shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Project Vice President and the Chairperson of the NSRB of disagreement between the PRB and the NPGM. The Project Vice President shall have responsibility for resolution of any such disagreement.

6.0 Records The PRB shall maintain written minutes of each meeting and copies shall be provided to the NPGM, Project Vice President, and the PRB members. Records of the minutes shall be maintained in accordance with this QATR, Section 17.

Enclosure I Page 45 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX B: NUCLEAR SAFETY REVIEW BOARD 1.0 General The nuclear safety review board (NSRB) shall advise the chief nuclear officer (CNO) on matters related to nuclear power plant safety for all SNC plants and corporate activities. The NSRB shall function to provide independent review and audit of designated activities in the areas of:

• Nuclear power plant operations

" Nuclear engineering

• Chemistry and radiochemistry

" Metallurgy

• Nondestructive testing

• Instrumentation and control

• Radiological safety

• Mechanical and electrical engineering, and

• Administrative controls and quality assurance practices

• Other appropriate fields associated with unique characteristics of the nuclear power plants such as the independent spent fuel storage facility operation The NSRB shall report to and advise the CNO on those areas of responsibility specified in paragraphs below (Reviews and Audits) and other areas as may be assigned. The NSRB shall review the SNC audit program at least semiannually to assure that audits are being accomplished in accordance with requirements of the SNC QATR.

2.0 Membership The NSRB shall consist of at least five regular members, appointed in writing by the CNO, with no more than a minority of the members representing the onsite operating organization of any specific plant. The minimum membership of the Board will consist of the Vice President -

Farley, the Vice President - Hatch, the Vice President - Vogtle, the Vice President -

Engineering, the Nuclear Fuel Manager, and the Quality Assurance Manager. A Chairman and a Vice Chairman shall be appointed by the CNO from among the plant vice presidents for a term of one year.

Alternate members of the NSRB shall be appointed in writing by the CNO to serve on a temporary basis for a specific member. The use of alternatives shall be restricted to legitimate Page 46 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report absences of regular members. In absences of the NSRB Chairman, the Vice Chairman will assume the duties of the NSRB Chairman.

Consultants, as well as representatives from various SNC organizations, may be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

The NSRB shall be composed of members who, as a group, provide expertise to review and audit the operation of a nuclear power plant, and are capable of recognizing and evaluating potential nuclear safety problems and their effects. The Chairman and each member of the NSRB, as a minimum, shall have a bachelor's degree in engineering or related sciences and five years technical experience if which at least three years shall be in one of the following areas:

• Nuclear power plant operations

• Nuclear engineering

• Chemistry and radiochemistry

" Metallurgy

• Nondestructive testing

• Instrumentation and control

• Radiological safety

• Mechanical and electrical engineering, and

" Administrative controls and quality assurance practices Subcommittees may be appointed by the NSRB Chairman to perform designated activities.

Subcommittee actions shall be reported to and acted on by the NSRB. Subcommittee Chairmen will be members or alternate members of the NSRB.

Termination of membership on the NSRB shall be authorized in writing by the EVP.

3.0 Meetings The NSRB shall meet at least once per 6 months.

The quorum of the NSRB necessary for performance of the NSRB review functions described below shall consist of the Chairman or Vice Chairman and at least a majority of the NSRB members, including alternates. No more than a minority of the quorum shall have line responsibility for onsite operation of any specific plant and no more than two alternates shall participate as voting members in NSRB activities at any one time.

Page 47 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report 4.0 Reviews The NSRB shall be responsible for the review of:

• The 10 CFR 50.59 and 10 CFR 72.48 evaluations for

- Changes to procedures, equipment, or systems; and

- Tests or experiments completed under provisions of 10 CFR 50.59 or 10 CFR 72.48, to verify that such actions did not require prior NRC approval.

" Proposed changes to procedures, equipment, or systems which require prior NRC approval pursuant to 10 CFR 50.59 or 10 CFR 72.48 prior to submittal for NRC approval;

• Proposed tests or experiments which require prior NRC approval pursuant to 10 CFR 50.49 or 10 CFR 72.48;

• Proposed changes to the plant or ISFSI Technical Specifications or Licenses;

• Violations of codes, regulations, orders, technical specifications, license requirements, or of internal procedures or instructions having nuclear safety significance or abnormal degradation of systems designated to contain radioactive material;

• Significant operating abnormalities or deviations from normal and expected performance of plant or ISFSI equipment that affect nuclear safety;

" All reportable events;

• All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety; and

• Performance of the Plant Review Board.

5.0 Audits Audits of plant activities shall be performed under the cognizance of the NSRB. The audits to be performed are discussed in Part II, Section 18 of the QATR.

6.0 Records Records of the NSRB activities shall be prepared, approved, and distributed as indicated below:

• Minutes of each NSRB meeting shall be prepared, approved, and forwarded to the CNO within 14 days following each meeting;

Enclosure I Page 48 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report

• Reports or subcommittee meeting minutes of reviews as described above shall be prepared, approved, and forwarded to the CNO within 14 days following completion of the review, and

• Audit reports as described above shall be forwarded to the CNO and to the management positions responsible for the areas audited within 30 days after completion by the auditing organization.

Page 49 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX C: QUALITY ASSURANCE SURVEILLANCES Periodic surveillances of plant activities shall be conducted to examine subjects such as plant operating characteristics and plant design and operating experience information, which may indicate areas for improving plant safety. These reviews are used to determine if the activities are being performed correctly and if human errors are being reduced as much as practical. The reviewer shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities, or other means of improving plant safety to appropriate management. A periodic summary report shall be provided to the appropriate vice president.

Persons performing QA Surveillances will be independent of performance functions, the signoff function, and the plant management chain while performing the oversight activity.

Persons performing QA Surveillances will be sufficiently qualified to properly conduct the reviews, and shall be engineers or appropriate specialists.

QA Surveillances are performed under the direction of the senior manager responsible for quality assurance.

Page 50 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX D: DEFINITIONS SNC uses the definitions of terms as provided in Section 4 of the Introduction of NQA-1-1994 in interpreting the requirements of NQA-1-1994 and the other standards to which the QATR commits. In addition, definitions are provided for the following terms not covered in NQA 1994:

Administrative controls: rules, orders, instructions, procedures, policies, practices and designations of authority and responsibility.

Construction: as used in this QATR, Construction shall mean the performance of major rework or modification activities during the Operations Phase that are similar in nature to activities performed during the construction phase such as, but not limited to, steam generator replacement, cooling tower replacement, and ISFSI installation. This program does not cover construction phase activities.

Emergency procedures: see Appendix E.

Experiments: performance of plant operations carried out under controlled conditions in order to establish characteristics or values not previously known.

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 capable of performing their intended functions.

Nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam or space 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. (May be called Abnormal, Off-normal or other terms conveying the same intent.)

On-site operating organization: on-site personnel concerned with the operation, maintenance and certain technical services.

Operating activities: work functions associated with normal operation and maintenance of the plant, and technical services routinely assigned to the on-site operating organization.

Operating procedures: written procedures defining the normal methods, means and limits of operation of the nuclear power plant, a plant system or systems, or processes, including actions to be taken by operating personnel for removal from and return to service of equipment on which maintenance is to be or has been performed.

Operational phase: that period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning.

Page 51 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Review: a deliberately critical examination, including observation of plant operation, evaluation of assessment results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions.

Supervision: direction of personnel activities or monitoring of plant 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 function or are in a state of readiness to perform their functions, and to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of safety related systems is maintained. Such functions include keeping parameters within normal bounds or acting to put the plant in a safe condition if they exceed normal bounds.

System: an integral part of nuclear power plant comprising components which may be operated or used as a separate entity to perform a specific function.

Page 52 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX E: PROCEDURES This appendix contains a description of the various types of procedures used by SNC to govern the design, operation, and maintenance of its nuclear generating plants. Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process.

Procedure format and content may vary from one location to the other. However, procedures include the following elements as appropriate to the purpose or task to be described.

" 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/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title). The systems, structures, components, processes or conditions to which the procedure applies are also clearly described.

• References Applicable references, including reference to appropriate Technical Specifications, are required. References are included within the body of the procedure when the sequence of steps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.

• Prerequisites/Initial Conditions Prerequisites/initial conditions identify 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.

" Precautions Precautions alert the user to those important measures to be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation during performance of the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.

Page 53 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report

• Limitations and actions Limitations on the parameters being controlled and appropriate corrective measures to return the parameter to the normal control band are specified.

• Main body The main body of the procedure contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.

" Acceptance criteria The acceptance criteria provide the quantitative or qualitative criteria against which the success or failure (as of a test-type activity) of the step or action would be judged.

Checklists Complex procedures utilize checklists which may be included as part of the procedure or appended to it.

Administrative Control Procedures These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire Company to those prepared at the implementing group level. These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs. In addition to the administrative controls described throughout this QATR, instructions governing the following activities are provided:

• Operating Orders/Procedures Instructions of general and continuing applicability to the conduct of business to the plant staff are provided. Examples where these are applied include, but are not limited to, job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions. Provisions are made for periodic review and updating of these documents, where appropriate.

• Special Orders Management instructions, which have short-term applicability and require dissemination, are issued to encompass special operations, housekeeping, data taking, publications Page 54 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report and their distribution, plotting process parameters, personnel actions, or other similar matters. Provisions are made for periodic review, updating, and cancellation of these documents, where appropriate.

" Plant Security and Visitor Control Procedures or instructions are developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant. Information concerning specific design features and administrative provisions of the plant security program is confidential and thus accorded limited distribution. The security and visitor control procedures consider, for example, physical provisions, such as: fences and lighting; lock controls for doors, gates and compartments containing sensitive equipment; and provisions for traffic and access control. Administrative provisions, such as: visitor sign-in and sign-out procedures; escorts and badges for visitors; emphasis on inspection, observation and challenging of strangers by operating crews; and a program of pre-employment screening for potential employees are also considered.

• Temporary Procedures Temporary procedures may be used to direct operations during testing, refueling, maintenance, and modifications to provide guidance in unusual situations not within the scope of the normal procedures. These procedures ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply.

Temporary Procedures include designation of the period of time during which they may be used and are subject to the procedure review process as applicable.

Engineering Procedures These documents provide instructions for the preparation of engineering documents, engineering analysis, and implementation of engineering programs. This includes activities such as designs; calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements.

Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and supplier and technical manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below.

Page 55 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report System Procedures These documents 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 safety of the plant. Separate procedures may be developed for correcting off-normal conditions for thope events where system complexity may lead to operator uncertainty. Appropriate procedures will also be developed for the fire protection program.

Start-up Procedures These documents contain instructions for starting the reactor from cold or hot conditions and establishing power operation. This includes documented determination that prerequisites have been met, including confirmation that necessary instruments are operable and properly set; valves are properly aligned, necessary system procedures, tests and calibrations have been completed; and required approvals have been obtained.

Shutdown Procedures These documents contain guidance for operations during controlled shutdown and following reactor trips, including instructions for establishing or maintaining hot shutdown/standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant are specified, including instructions for such actions as monitoring and controlling reactivity, load reduction and cooldown rates, sequence for activating or deactivating equipment, requirements for prompt analysis for causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal.

Power Operation and Load Changing Procedures These documents contain instructions for steady-state power operation and load changing.

These type documents include, as examples, provisions for use of control rods, chemical shim, coolant flow control, or any other system available for short-term or long-term control of reactivity, making deliberate load changes, responding to unanticipated load changes, and adjusting operating parameters.

Process Monitoring Procedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed.

Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring.

Page 56 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Fuel Handling Procedures These documents contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments.

Procedures are also provided for receipt and inspection of new fuel, and for fuel movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers (or other unique identifiers) and locations.

Maintenance Procedures These documents contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection or test instructions subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures (such as protective clothing and radiation monitoring) will be included. Additional maintenance procedure requirements are addressed in NQA-1-1994, Subpart 2.18, Section 2.2, Procedures.

Radiation Control Procedures These documents contain instructions for implementation of the radiation control program requirements necessary to meet regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees and others.

Page 57 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report Calibration and Test Procedures These documents contain instructions for periodic calibration and testing of instrumentation and control systems, and for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. These documents provide for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits.

Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and radiochemical control activities and include: the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment and management of radioactive wastes, and control of radioactive calibration sources.

Emergency Operating Procedures These documents contain instructions for response to potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate actions that should be taken in response. Format and content of emergency procedures are based on regulatory and Owner's Group(s) guidance that identify potential emergency conditions and generally require such procedures to include a title, symptoms to aid in identification of the nature of the emergency, automatic actions to be expected from protective systems, immediate operator actions for operation of controls or confirmation 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.

Emergency Plan Implementing Procedures These documents contain instructions for activating 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 facility's NRC approved Emergency Plan are met.

Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained for the nuclear facilities. The instructions for tests and inspections may be included within other procedures, such as installation and maintenance procedures, but will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection, as applicable.

Page 58 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide for appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for 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.

Page 59 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report APPENDIX F: QUALITY ASSURANCE OF THE INDEPENDENT SPENT-FUEL STORAGE INSTALLATION This Appendix F describes the administrative controls and the quality assurance (QA) program requirements applied to important-to-safety (ITS) structures, systems, and components associated with independent spent fuel storage installation (ISFSI) to assure conformance to regulatory requirements and the design bases. This program is an extension of the quality assurance program requirements described in the QATR, modified to address 10 CFR 72 Subpart G items specific to ISFSI and related support activities.

The QA program requirements described in the QATR are applicable to ISFSI items classified as ITS Category A and ITS Category B. Specific aspects of the QA program requirements described in the QATR are applied to ITS Category C items as specified in the individual subsections.

The following definitions are applicable to activities and items covered by this Appendix F:

ITS structures, systems, and components are those features of an ISFSI whose function is to:

• Maintain the conditions required to store spent fuel safely,

• Prevent damage to the spent fuel container during handling storage, or

• Provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved without undue risk to the health and safety of the public.

The definition of ITS safety categories below are based on NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety."

1. Category A - ITS Category A items include structures, components, and systems whose failure could directly result in a condition adversely affecting public health and safety. The failure of a single item could cause loss of primary containment leading to release of radioactive material, loss of shielding, or unsafe geometry compromising criticality control.

2 Category B - ITS Category B items include structures, components, and systems whose failure or malfunction could indirectly result in a condition adversely affecting public health and safety. The failure of a Category B item, in conjunction with failure of an additional item, could result in an unsafe condition.

3. Category C - ITS Category C items include structures, components, and systems whose failure or malfunction would not significantly reduce the packaging effectiveness and would not be likely to create a situation adversely affecting public health and safety.

The QA program requirements, as described in the following QATR sections and subsections, are applied to ITS Category A, B, and C items unless modified by the description below:

Page 60 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report

• Part II, Section 1 Organization The corporate organization established to support the operation of the plant also functions to support operation of the ISFSI.

Additional offsite support is provided by the spent fuel storage vendor.

Those plant organizations with responsibilities related to 10 CFR 50.59 evaluation reviews also perform the corresponding ISFSI evaluation reviews under 10 CFR 72.48.

• Part II, Section 2 QA Program QA program requirements are applied to the ISFSI and support structures, systems, and components using a graded approach based on the ISFSI item classification.

ITS Category A, B and C are identified in the respective 10 CFR 72.212 Report, as applicable. Items identified as not important to safety in the respective 10 CFR 72.212 Report are excluded from the QA program.

The plant organization has the same responsibilities for ITS Category A and Category B items as it does for other plant activities.

" Part II, Section 3 Design Control Design control measures for ITS Category A and Category B items are applied where appropriate per the controls in the QATR. Additional review concerns that are specific to the ISFSI are criticality physics, shielding, and features to facilitate decontamination.

The designs of ITS Category C items specify procurement, inspection, and testing at a level appropriate for the importance of the function performed.

• Part II, Section 4 Procurement Document Control A graded approach is applied through the use of a multi-level procurement classification system based upon the end-use of each item or service. Items procured as ITS Category A or Category B are controlled as described in the QATR. ITS Category A or Category B items procured as commercial grade are controlled by the existing commercial grade dedication program. ITS Category C items are procured as appropriate for function and safety importance, and are excluded from the provisions of 10 CFR 21.

" Part II, Section 5 Instructions, Procedures, and Drawings

• Part II, Section 6 Document Control

• Part II, Section 16 Corrective Action Page 61 of 61 Southern Nuclear Operating Company Quality Assurance Topical Report

• Part II, Section 17QA Records Records pertaining to design, fabrication, erection, testing, maintenance, and use of ITS items are maintained for the duration of the General License granted under Subpart K of 10 CFR 72 for the specific storage system.

• Part II, Section 18 Audits Audits are performed on a frequency not to exceed 24 months for quality activities related to the operation and maintenance of the ISFSI.

The QA program requirements, as described in the following identified QATR sections, are applied to ITS Category A and B items.

Part II, Section 7 Control of Purchased Material, Equipment, and Services.

Part II, Section 8 Identification and Control of Materials, Parts, and Components.

Part II, Section 9 Control of Special Processes.

Part II, Section 10 Inspection.

Part II, Section 11 Test Control.

Part II, Section 12 Control of Measuring and Test Equipment.

Part II, Section 13 Handling, Storage, and Shipping.

Part II, Section 14 Inspection, Test, and Operating Status.

Part II, Section 15 Nonconforming Materials, Parts, and Components.

Enclosure 2 Southern Nuclear Operating Company Quality Assurance Topical Report Description of Proposed Change/

Bases for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Page 1 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 1.0 Description Southern Nuclear Operating Company (SNC) is the licensed operator of the Joseph M. Farley Nuclear Plant (Farley), Edwin I. Hatch Nuclear Plant (Hatch), and Vogtle Electric Generating Plant (Vogtle). Each plant currently has a separate quality assurance program (QAP) described in Section 17.2 of its respective FSAR that provides the controls necessary to assure compliance with the requirements of 10 CFR 50, Appendix B. Each program is unique and reflects the quality assurance standards that were in effect at the time of original plant licensing, as modified in accordance with the provisions of 10 CFR 50.54(a). SNC wishes to standardize the quality assurance requirements for the SNC-operated fleet of plants in order to support establishment of common processes and increased efficiency associated with implementation of the QAP.

2.0 Proposed Change The proposed Quality Assurance Topical Report (QATR) provides the necessary controls for operation-phase activities at SNC sites. The proposed QATR will replace the existing quality assurance (QA) programs for the Farley, Hatch, and Vogtle plants described in Section 17.2 of the respective FSAR for each plant. The QATR represents a change for each plant from a QAP based on Regulatory Guide 1.28 and Regulatory Guide 1.33, to a single QATR based on American Society of Mechanical Engineers (ASME) NQA- 1-1994, as supplemented by the requirements of American National Standards Institute (ANSI) standard Ni18.7-1976. provides a summary of the changes to the Farley, Hatch, and Vogtle QAPs. This summary identifies each section of the existing QAP for each site and provides the disposition for each on a paragraph-by-paragraph basis. The disposition of each requirement is categorized as a change to the existing QAP that represents: (1) a reduction in commitments; (2) an increase in commitments; or (3) neither an increase nor reduction in commitments contained in the QAP description. Although SNC believes the items identified in Enclosure 3 as reductions in commitments meet the criteria of § 50.54(a)(3) for activities that do not reduce commitments described in the QAP, SNC has conservatively identified these items as reductions in commitments to facilitate NRC review of the proposed QATR. The changes to the Farley, Hatch, and Vogtle QAPs are illustrated in the FSAR markups provided as Enclosure 6. is a matrix describing SNC's conformance with ASME NQA- 1-1994. This enclosure identifies the location describing SNC's conformance with each of the requirements of ASME NQA- 1-1994 in the proposed QATR. Where alternatives or exceptions are proposed to ASME NQA-1 -1994 in the QATR, the precedence for the alternative or exception is cited in Enclosure 4.

Although there is significant overlap of the requirements of ASME NQA- 1-1994 and ANSI N18.7-1976, neither fully addresses the requirements acceptable to the NRC for compliance with the criteria of 10 CFR 50, Appendix B. Accordingly, the SNC QATR also incorporates specific requirements of ANSI N18.7-1976 to supplement those from ASME NQA-1-1994. Enclosure 5 provides a matrix of the requirements of ASME NQA-1-1994 and ANSI NI 8.7-1976 illustrating the differences in the standards and SNC's incorporation of the applicable requirements from ANSI N18.7-1976 into the proposed QATR.

Page 2 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 3.0 Background SNC operates the Farley, Hatch, and Vogtle plants in accordance with the provisions of 10 CFR Part 50. As part of the original license process for each plant, the quality assurance program for each was submitted to the NRC in accordance with the requirements of § 50.34(b)(6)(ii) to provide the managerial and administrative controls necessary to satisfy the requirements of 10 CFR Part 50, Appendix B. These programs were based on the requirements of Regulatory Guide 1.28 (Safety Guide 28) and Regulatory Guide 1.33 (Safety Guide 33) which endorsed the methods of ANSI N45.2 and ANSI N18.7, respectively, as an acceptable basis for a QAP required to meet 10 CFR Part 50, Appendix B. Additional regulatory guides were also issued that endorsed the daughter standards of ANSI N45.2 (e.g., ANSI N45.2.1, N45.2.2, etc.) necessary to assure compliance with the requirements of 10 CFR Part 50, Appendix B. The QAPs for Farley, Hatch, and Vogtle have been modified in accordance with the provisions of 10 CFR 50.54(a) over the life of the plant as necessary to assure continued compliance with the requirements of 10 CFR 50, Appendix B.

Due to the different vintage of each plant, the regulatory guidance applicable to each plant for compliance with the requirements of 10 CFR 50, Appendix B, varies. As a result, the existing QAPs for Farley, Hatch, and Vogtle contain different commitments and requirements. In an effort to standardize operation of its nuclear facilities, SNC has elected to combine the existing QAP requirements for Farley, Hatch, and Vogtle into a single program described in the proposed QATR (Enclosure 1).

SNC's approach for the QATR is generally consistent with the precedence established by other licensees that have submitted topical reports applicable to multiple sites for compliance with 10 CFR Part 50, Appendix B. These include topical reports submitted by Exelon, Nuclear Management Company (NMC), and Dominion and approved by the NRC as an acceptable method for compliance with the requirements of 10 CFR Part 50, Appendix B. Additional information regarding the topical reports submitted by these licensees is provided in Section 5.0 below.

4.0 Technical Analysis Changes to the Farley, Hatch, and Vogtle QAPs are generally categorized as follows:

• Category 1 - Changes from commitments to ANSI N45.2 and corresponding daughter standards to a commitment to NQA- 1-1994 (Section 4.1)

• Category 2 - NRC-approved alternatives/SNC clarifications to NQA- I-1994 (Section 4.2)

• Category 3 - NRC-approved implementation of ANSI N18.7 (Section 4.3)

• Category 4 - Reduction in detail contained in the QAP (Section 4.4)

• Category 5 - Use of generic titles/organization charts (Section 4.5)

Page 3 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Additional detail is provided in the following paragraphs corresponding to the numbers shown in parentheses above for each category of changes.

4.1 Category 1 - Changes to Commitments to ANSI N45.2 Category 1 changes represent changes to the commitments to ANSI N45.2, including the corresponding daughter standards, described in the Farley, Hatch, and Vogtle QAPs to a commitment to ASME NQA- I-1994, as described in the proposed QATR. Changes to specific commitments contained in the Farley, Hatch, and Vogtle QAPs associated with ANSI N45.2, including the corresponding daughter standards are described below.

4.1.1 Regulatory Guide 1.28 Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction) provided NRC endorsement of ANSI N45.2, Quality Assurance Program Requirements for Nuclear Facilities, and included supplemental requirements in Section C, Regulatory Positions. The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.28 as follows:

• Hatch - Regulatory Guide 1.28, Revision 2, dated February 1979 (ANSI N45.2-1977)

" Farley - Safety Guide 28, dated June 7, 1972 (ANSI N45.2-1971)

" Vogtle - Safety Guide 28, dated June 7, 1972 (ANSI N45.2-1971)

ASME NQA- 1-1994 incorporates the scope of activities previously addressed by Regulatory Guide 1.28 and ANSI N45.2 for design and construction activities.

Accordingly, the proposed QATR represents a change to commitments in the QAP description from Regulatory Guide 1.28 and ANSI N45.2, as cited above, to NQA 1994, as delineated in Enclosure 4.

Page 4 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.1.2 Regulatory Guide 1.30 Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment, provided NRC endorsement of ANSI N45.2.4-1972, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations (ANSI N45.2.4-1972 is also designated as IEEE Standard 336-1971), as an adequate basis for compliance with the pertinent quality assurance requirements of 10 CFR 50, Appendix B. Although the title of ANSI N45.2.4-1972 indicates that it is applicable to design and construction phase activities, Regulatory Guide 1.30, Regulatory Position C.3, extends the applicability of ANSI N 45.2.4-1972 to operation phase activities.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.30 as follows:

• Hatch - Safety Guide 30, dated August 11, 1972 (ANSI N45.2.4-1972/IEEE 336-1971)

" Farley - Safety Guide 30, dated August 11, 1972 (ANSI N45.2.4-1972/IEEE 336-197 1)

• Vogtle - Safety Guide 30, dated August 11, 1972 (ANSI N45.2.4-1972/IEEE 336-1971)

ASME NQA-1-1994 incorporates IEEE 336-1985 by reference for the quality assurance requirements applicable to installation, inspection, and testing of instrumentation and electric equipment. The proposed QATR represents a change to commitments contained in the QAP description from Safety Guide 1.30 and ANSI N45.2.4/IEEE 336, as cited above, to ASME NQA-1 -1994/IEEE 336-1985.

4.1.3 Regulatory Guide 1.37 Regulatory Guide 1.37, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-cooled Nuclear Power Plants, provides NRC endorsement of ANSI N45.2. 1, Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants, as an adequate basis for compliance with the pertinent quality assurance requirements of 10 CFR 50, Appendix B. Although the title of ANSI N45.2.1 indicates that it is applicable to design and construction phase activities, Regulatory Guide 1.37, Regulatory Position C.2, states that many of the requirements and recommendations of the standard are also appropriate for operation phase activities.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.37 as follows:

Page 5 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B

• Hatch - Regulatory Guide 1.37, dated March 16, 1973 (ANSI N45.2.1-1973)

" Farley - Regulatory Guide 1.37, dated March 16, 1973 (ANSI N45.2.1-1973)

• Vogtle - Regulatory Guide 1.37, dated March 16, 1973 (ANSI N45.2.1-1973)

ASME NQA- 1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory guide 1.37 and ANSI N45.2.1-1973 for cleanliness of fluid systems and associated components. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.37 and ANSI N45.2.1, as cited above, to ASME NQA- 1 -1994, as delineated in Enclosure 4.

4.1.4 Regulatory Guide 1.38 Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water Cooled Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.2, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants during the Construction Phase, as an adequate basis for compliance with the pertinent quality assurance requirements of 10 CFR 50, Appendix B. Although the title of ANSI N45.2.2 indicates the standard is applicable to construction phase activities, Regulatory Position C.4 of Regulatory Guide 1.38 extends applicability of the standard to operation phase activities.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.38 as follows:

" Hatch - Regulatory Guide 1.38, dated March 16, 1973 (ANSI N45.2.2-1972)

• Farley - Regulatory Guide 1.38, dated March 16, 1973 (ANSI N45.2.2-1972)

• Vogtle - Regulatory Guide 1.38, dated March 16, 1973 (ANSI N45.2.2-1972)

ASME NQA- 1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.38 and ANSI N45.2.2-1972 for packaging, shipping, receiving, storage, and handling of items or components.

Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.38 and ANSI N45.2.2, as cited above, to ASME NQA-1 -1994, as delineated in Enclosure 4.

Page 6 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.1.5 Regulatory Guide 1.39 Regulatory Guide 1.39, Housekeeping Requirements for Water-cooled Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.3, Housekeeping During the Construction Phase of Nuclear Power Plants, as an adequate basis for compliance with the pertinent quality assurance requirements of 10 CFR 50, Appendix B.

Although the title of ANSI N45.2.3 indicates the standard is applicable to construction phase activities, Regulatory Position C.2 of Regulatory Guide 1.39 extends applicability of the standard to operation phase activities.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.39 as follows:

" Hatch - Regulatory Guide 1.39, dated March 16, 1973 (ANSI N45.2.3-1973)

• Farley - Regulatory Guide 1.39, dated March 16, 1973 (ANSI N45.2.3-1973)

• Vogtle - Regulatory Guide 1.39, Revision 2, dated September 1977 (ANSI N45.2.3-1973)

ASME NQA-1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.39 and ANSI N45.2.3-1973 for housekeeping requirements. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.39 and ANSI N45.2.3, as cited above, to ASME NQA-l-1994, as delineated in Enclosure 4.

4.1.6 Regulatory Guide 1.58 Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel, provided NRC endorsement of ANSI N45.2.6, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants, as an adequate basis for compliance with the pertinent quality assurance requirements of 10 CFR 50, Appendix B. Although the title of ANSI N45.2.6 indicates the standard is applicable to construction phase activities, Regulatory Position C. 1 of Regulatory Guide 1.58 states that the requirements should be considered generally applicable to other phases of plant life, including the operations phase.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.58 as follows:

• Hatch - Regulatory Guide 1.58, dated August 1973 (ANSI N45.2.6-1973)

Page 7 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B

• Farley - Regulatory Guide 1.58, Revision 1, dated September 1980 (ANSI N45.2.6-1978)

• Vogtle- Regulatory Guide 1.58, Revision 1, dated September 1980 (ANSI N45.2.6-1978)

ASME NQA-1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.58 and ANSI N45.2.6 for qualification of inspection, examination, and testing personnel. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.58 and ANSI N45.2.6, as cited above, to ASME NQA 1994, as delineated in Enclosure 4.

4.1.7 Regulatory Guide 1.64 Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.11, Quality Assurance Requirements for the Design of Nuclear Power Plants, as an adequate basis for compliance with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.64 as follows:

• Hatch - Regulatory Guide 1.64, dated October 1973 (ANSI N45.2.1 1, Draft No. 3, Revision 1, dated July 1973)

• Farley - Regulatory Guide 1.64, Revision 2, dated June 1976 (ANSI N45.2.11-1974)

• Vogtle - Regulatory Guide 1.64, Revision 2, dated June 1976 (ANSI N45.2.1 1-1974)

ASME NQA-I-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.64 and ANSI N45.2.11 for design of nuclear power plants. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.64 and ANSI N45.2.1 1, as cited above, to ASME NQA-l-1994, as delineated in Enclosure 4.

4.1.8 Regulatory Guide 1.74 Regulatory Guide 1.74, Quality Assurance Terms and Conditions, provided NRC endorsement of ANSI N45.2. 10, Quality Assurance Terms and Definitions, as acceptable for use in describing and implementing quality assurance programs for design, construction, and operation of nuclear power plants.

Page 8 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.74 as follows:

• Hatch - Regulatory Guide 1.74, dated February 1974 (ANSI N45.2.10-1973)

• Farley - Regulatory Guide 1.74, dated February 1974 (ANSI N45.2.10-1973)

• Vogtle - Regulatory Guide 1.74, dated February 1974 (ANSI N45.2.10-1973)

ASME NQA- 1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.74 and ANSI N45.2. 10 for design of nuclear power plants. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.74 and ANSI N45.2.10, as cited above, to ASME NQA-1-1994, as delineated in Enclosure 4.

4.1.9 Regulatory Guide 1.88 Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records, provided NRC endorsement of ANSI N45.2.9, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.88 as follows:

• Hatch - Regulatory Guide 1.88, dated August 1974 (ANSI N45.2.9-1974)

• Farley - Regulatory Guide 1.88, dated August 1974 (ANSI N45.2.9-1 974)

" Vogtle-Regulatory Guide 1.88, Revision 2, dated October 1976 (ANSI N45.2.9-1974)

ASME NQA-1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.88 and ANSI N45.2.9 for design of nuclear power plants. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.88 and ANSI N45.2.9, as cited above, to ASME NQA-I-1994, as delineated in Enclosure 4.

Page 9 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.1.10 Regulatory Guide 1.94 Regulatory Guide 1.94, Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.5, Supplemental Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.94 as follows:

• Hatch - Regulatory Guide 1.94, Revision 1, April 1976 (ANSI N45.2.5-1974)

• Farley - None (ANSI N45.2.5-1974)

• Vogtle - ANSI N45.2.5-1978 (Vogtle is not currently committed to Regulatory Guide 1.94)

ASME NQA-1 -1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.94 and ANSI N45.2.5 for installation of structural concrete and structural steel. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.94 and ANSI N45.2.5, as cited above, to ASME NQA-1-1994, as delineated in Enclosure 4.

4.1.11 Regulatory Guide 1.116 Regulatory Guide 1.116, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems, provided NRC endorsement of ANSI N45.2.8, Supplemental Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B. Although the title of ANSI N45.2.8 indicates the standard is applicable to construction phase activities, Regulatory Position C.2 of Regulatory Guide 1.116 states that the requirements should be considered applicable during the operations phase.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.116 as follows:

• Hatch - Regulatory Guide 1.116, Revision O-R, dated May 1977 (ANSI N45.2.8-1975). Although the Hatch QAP cites the date of Revision O-R to be May 1977, this date is the date the title page Page 10 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B was revised to remove the words "For Comment." The correct date for Revision O-R is June 1976.

• Farley - None (ANSI N45.2.8-1974, Draft 3, dated April 1974)

• Vogtle -Regulatory Guide 1.116, Revision O-R, dated June 1976 (ANSI N45.2.8-1975)

ASME NQA-1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.116 and ANSI N45.2.8 for installation, inspection, and testing of mechanical equipment and systems.

Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.116 and ANSI N45.2.8, as cited above, to ASME NQA- 1-1994, as delineated in Enclosure 4.

4.1.12 Regulatory Guide 1.123 Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.13, Quality Assurance Requirements for control of Procurement of Items and Services for Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.123 as follows:

• Hatch - Regulatory Guide 1.123, Revision 1, dated July 1977 (ANSI N45.2.13-1976).

• Farley - None (ANSI N45.2.13, Draft 2, Revision 4, dated April 1974)

• Vogtle -Regulatory Guide 1.123, Revision 1, dated July 1977 (ANSI N45.2.13-1976)

ASME NQA-1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.123 and ANSI N45.2.13 for control of procurement of items and services. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.123 and ANSI N45.2.13, as cited above, to ASME NQA-1-1994, as delineated in Enclosure 4.

4.1.13 Regulatory Guide 1.144 Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.12, Requirements for Auditing of Page 11 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Quality Assurance Programs for Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.144 as follows:

Hatch - Regulatory Guide 1.144, Revision 1, dated September 1980 (ANSI N45.2.12-1977).

• Farley - None (ANSI N45.2.12, Draft 3, Revision 4, dated February 1974)

SVogtle -Regulatory Guide 1.144, Revision 1, dated September 1980 (ANSI N45.2.12-1977)

ASME NQA- 1-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.144 and ANSI N45.2.12 for auditing of quality assurance programs. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.144 and ANSI N45.2.12, as cited above, to ASME NQA-I-1994, as delineated in Enclosure 4.

4.1.14 Regulatory Guide 1.146 Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, provided NRC endorsement of ANSI N45.2.23, Qualification of Quality Assurance Program Personnel for Nuclear Power Plants, as an adequate basis for complying with the pertinent requirements of 10 CFR 50, Appendix B.

The existing Farley, Hatch, and Vogtle QAPs include commitments to Regulatory Guide 1.146 as follows:

• Hatch - Regulatory Guide 1.146, dated August 1980 (ANSI N45.2.23-1978).

" Farley - Regulatory Guide 1.146, dated August 1980 (ANSI N45.2.23-1978)

" Vogtle - Regulatory Guide 1.146, dated August 1980 (ANSI N45.2.23-1978)

ASME NQA- I-1994 provides the necessary requirements to address the scope of activities formerly addressed by Regulatory Guide 1.146 and ANSI N45.2.23 for qualification of audit personnel. Accordingly, the proposed QATR represents a change to commitments contained in the QAP description from Regulatory Guide 1.146 and ANSI N45.2.23, as cited above, to ASME NQA-1-1994, as delineated in Enclosure 4.

Page 12 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.2 Category 2 - NRC-approved Alternatives to NQA-1-1994 Category 2 changes represent alternatives to NQA- 1-1994 previously approved by the NRC that are proposed to be included in the QATR. Conformance of the proposed QATR to NQA-1-1994 is described in Enclosure 4. Enclosure 4 includes a list of each section of NQA- 1-1994,Section I and II, and identifies the location of the requirement in the proposed QATR, along with any clarifications or alternatives incorporated in the proposed QATR. Alternatives to NQA- 1-1994 incorporated in the proposed QATR have been previously approved by the NRC as an acceptable basis for compliance with the pertinent requirements of 10 CFR 50, Appendix B and the precedence for each is cited. Clarification of the requirements of NQA- 1-1994 described in the proposed QATR is listed below and where applicable, the precedence is cited.

4.2.1 NQA-1-1994, Part I, Section 1.4 SNC utilizes the terms and definitions provided in NQA-1-1994 to interpret the requirements of NQA- 1-1994, as well as other standards to which SNC commits to in the proposed QATR. Additional terms and definitions are provided in Appendix D of the QATR. The terms and definitions contained in the proposed QATR are identical to those contained in Appendix C of the NMC QATR approved by NRC Safety Evaluation Report (SER) dated March 24, 2005, with the exception of the following clarifications:

Construction - Construction shall mean the performance of major rework or modification activities during the operations phase that are similar in nature to activities performed during the construction phase such as, but not limited to, steam generator replacement, cooling tower replacement, and ISFSI installation. This program does not cover construction phase activities.

Independent VerF6fffieain Ver-ificationt that requir-ed actionis have been operatien or-activity being v~erified. Sueh verificationt will nlOt rFur confirmation of the identical action when other-indications provid assuanee Or indieatien that the prescr-ibed activity is in fect ceomplete.

Examnples incelude, but are noet limited to: vefificationt of a br~eakr opening by obsef-ving rmemte breaker: indieaticn lights; verificationi of a setpeint (made with a voltmeter Or ammfifeter, fOr examfple) by obser,'ing the actuationt or status of indicating lights are the required pael mfeter indicated value; ver-ificationt that a valve has been positioned by ebsefrving the starting Or Stoppinig Of flow on mneter-indicationts er-by r-emote valAve vesitimfn indieating lights-.

Zr Page 13 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B T abemurdefnitio n fieaove Verification by a senond individual of a ci mpofont'ssondition as the action is being performed. Examps i42 Nlude, but nct 2Am-1 ppelimited tc: equipmpent being ed fm r (proVided the equipment being rcmoved froft vihecause will p noatd ny advAd e sys1tem asndition), lifting a lead, remenving a fuse, and The above definitions provide clarification regarding how the requirements of NQA-1I- 1994, Part 1, Section 1.4 will be met and does not represent a change or deviation from the standard.

4.2.2 NQA-1-1994, Supplement 2S-1, Appendix 2A-1 Supplement 2S-1, Supplementary Requirements for the Qualification of Inspection and Test Personnel, will include use of the guidance provided in Appendix 2A- 1 the same as if it were part of the Supplement. The following two alternatives may be applied to the implementation of the requirements of this Supplement and Appendix:

(1) In lieu of being certified as Level i, 11, or Iio in accordance with NQA- 1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors. For the purposes of these functions, a qualified engineer is one who has a baccalaureate in engineering in a discipline related to the inspection activity (such as, electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities.

This alternative is consistent with the Dominion Nuclear Facility Quality Assurance Program Description (NFQAPD), Section 2.5.5 and Appendix C, Section 6.2, approved by NRC SER dated September 9, 2005, Paragraphs 4.3.1.2 and 4.3.1.3 Page 14 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.2.3 NQA-1-1994, Supplement 2S-2 In lieu of Supplement 2S-2 for qualification of nondestructive examination personnel, SNC will follow the applicable standard cited in the version(s) of Section III and Section XI of the ASME Boiler and Pressure Vessel Code approved by the NRC for use at SNC sites.

This exception is consistent with NMC QATR, Section A.5, approved by NRC SER dated March 24, 2005, Section 3.3.1 with the SNC addition of the qualification requirements of ASME Section III, as applicable.

4.2.4 NQA-1-1994, Supplement 2S-3 In lieu of the requirement that prospective lead auditors participate in a minimum of five (5) audits in the previous three (3) years, the prospective lead auditor shall demonstrate his/her ability to properly implement the audit process, as implemented by SNC, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear audit within the year preceding the date of qualification.

This change is consistent with NMC QATR Section A.5 and the corresponding NRC SER dated March 24, 2005, Section 3.3.1.

4.2.5 NQA-1-1994, Supplement 4S-1 (a) Section 2.3 of this Supplement 4S-1 includes a requirement that procurement documents require suppliers to have a documented quality assurance program that implements NQA- 1-1994, Part 1. In lieu of this requirement, SNC may require suppliers to have a documented supplier quality assurance program that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of the procurement.

This exception is consistent with NMC QATR Section B.4, determined to provide an acceptable basis for conformance with the requirements of 10 CFR 50, Appendix B, as documented by the corresponding NRC SER dated March 24, 2005, modified to address NRC Request for Information to Constellation Generation Group, dated May 15, 2006.

(b) Section 2.3 of Supplement 4S-I includes a requirement that procurement documents require suppliers to have a documented quality assurance program, including implementing procedures. As clarification regarding services performed on a plant site by a supplier, SNC procurement documents may allow the supplier to work under the SNC quality assurance program, including implementing procedures, in lieu of the supplier having Page 15 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B its own quality assurance program.

This item provides clarification regarding how the requirements of NQA 1994, Supplement 4S-1, Section 2.3, will be met and does not represent a change or deviation from the standard.

(e)- Sectien 3 of Supplement 45 1 requires procurement docuiments to b r-eviewed prier to bid Or award of eenf naet. As a elar-ifieation to ti reQuir t, Squality assu1e view of prurement douments wil be sAisfipeid though review of the applniable protunrment specificatigo, including the technieal and quality pcesch ment requirements, prier tebid or award of contraet.

This itemprovides clarificatien regarding how the requirements of NQA 1 1994, Supplement 4 1,7Section 3, will bemet and does not represent a change ordeviationfromthe standard.

4.2.6 NQA-1-1994, Supplement 7S-1 (a) SNC considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to SNC plants are not required to be evaluated or audited.

This item provides clarification regarding how the requirements of NQA-1-1994, Supplement 7S-s are implemented and does not represent a change or deviation from the standard.

(b) When purchasing commercial grade calibration services from a calibration laboratory, procurement source evaluation and selection measures need not be performed provided each of the following conditions are met:

(i) The purchase documents impose any additional technical and administrative requirements, as necessary, to comply with the SNC QA program and technical provisions. At a minimum, the purchase document shall require that the calibration certificate/report include identification of the laboratory equipment/standard used.

(ii) The purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.

(iii) A documented review of the supplier's accreditation shall be performed and shall include a verification of each of the following:

Page 16 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B

- The calibration laboratory holds a* domestic accreditation by the National Voluntary Laboratory Accreditation Program (NVLAP) or by the American Association for Laboratory Accreditation (A2LA) as recognized by NVLAP through athe International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).

- The accreditation is based on ANS/ISO/IEC 17025.

- The published scope of accreditation for the calibration laboratory covers the necessary measurement parameters, ranges, and uncertainties.

This alternative is consistent changes to the Palo Verde QAP requested by Arizona Public Service y-letter dated September 5, 2004, approved by NRC SER dated September 28, 2005.

(c) Section 8.1, SNC considers documents that may be stored in approved electronic media under SNC control and not physically located on the plant site but which are accessible from the respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site.

This item provides clarification regarding how the requirements of NQA-1-1994, Supplement 7S-1, Section 8.1, will be met and does not represent a change or deviation from the standard.

(d) In lieu of the requirements of Section 10, Commercial Grade Items, controls for commercial grade items are established in SNC documents using the guidance of EPRI NP-5652 as discussed in Generic Letter 89-02 and Generic Letter 91-05.

This item is consistent with the requirements of the existing Farley, Hatch, and Vogtle QAPs for procurement of commercial grade items and as a result, does not represent a change to the Farley, Hatch, and Vogtle QAP requirements. Additionally, this alternative is consistent with Section 7.5 of the Dominion NFQAPD, as approved by the corresponding NRC SER dated September 9, 2005, with the addition of Generic Letter 91-05, as recommended by NRC Request for Additional Information for Constellation Generation Group, dated May 15, 2006.

4.2.7 NQA-1-1994, Subpart 2.4 (a) For clarification, SNC commitment to Subpart 2.4 results in SNC commitment to IEEE 336-1985 which refers to IEEE 498-1985. Both Page 17 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B IEEE 336-1985 and 498-1985 use the definition of "safety system equipment" from IEEE 603-1980. SNC commits to the definition of safety system equipment in IEEE 603-1980 but does not commit to the balance of IEEE 603-1980.

This item provides clarification only and does not represent an exception or deviation from NQA-I-1994.

(b) Section 7.2.1 of ANSI/IEEE 336-1985 requires all items requiring calibration to be labeled or tagged. In lieu of this requirement, SNC may not label or tag certain items requiring calibration but will provide other means of identification so that appropriate controls can be implemented.

I This exception is consistent with NMC QATR Section B.9 and Section 3.3.2 of the corresponding NRC SER dated March 24, 2005.

4.2.8 NQA-1-1994, Subpart 2.16 Section 5.5 of ANSI/IEEE 198-1985 requires all measuring and test equipment (M&TE) to be labeled. In lieu of this requirement, SNC may not label certain M&TE, such as installed instrumentation, but will provide other means of identification so that appropriate controls can be implemented.

This exception is consistent with NMC QATR Section B.9 and Section 3.3.2 of the corresponding NRC SER dated March 24, 2005.

4.2.9 NQA-1-1994, Subpart 2.1 Subpart 2.1, Sections 3.1 and 3.2 establish criteria for classifying items into cleanness classes and requirements for each class. In lieu of the cleanness classes system of Subpart 2.1, SNC plants may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. SNC establishes appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign materials prior to system closure.

This exception is consistent with that contained in Section B.7 of the NMC QATR, as discussed in NRC SER, dated March 24, 2005, Section 3.3.2.

4.2.10 NQA-1-1994, Subpart 2.2 (a) In lieu of the requirements of NQA-I -1994, Subpart 2.2, Sections 3.2 and 3.5, as determined by facility management for items in storage, the Page 18 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B packaging requirements described under Section 3, Packaging, may include alternate methods of affording required protection such as maintaining a storage atmosphere free from harmful contaminants in concentrations that could produce damage to the stored items, or utilizing practices that obviate the need for capping all openings.

This alternative is consistent with Dominion NFQAPD, Section 13.3, as approved by NRC SER dated September 9, 2005.

(b) In lieu of the requirements of NQA-1-1994, Subpart 2.2, Section 6.6, which requires written records to be prepared containing information on personnel access, SNC documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However, these records of access are not considered quality records and will be retained in accordance with the administrative controls of the applicable plant.

This alternative is consistent with Dominion NFQAPD, Section 13.3, as approved by NRC SER dated September 9, 2005.

(c) In lieu of the requirement of NQA- 1-1994, Subpart 2.2, Section 7.1 which provides the requirements for hoisting, rigging and transporting of items for nuclear plants, SNC establishes and implements controls 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," SNC performs dynamic load testing over the full range of the lift using test loads at least 110% of the lift weight. Dynamic tests include raising, lowering and traversing the load. Where required, SNC complies with the applicable hoisting and transportation regulations and codes.

This alternative is consistent with NMC QATR Section B.7, as approved by NRC SER dated March 24, 2005.

Page 19 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 4.2.11 NQA-1-1994, Subpart 2.3 In lieu of the five-level zone designation required by Subpart 2.3, Section 2.2, SNC bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

This alternative is consistent with NMC QATR Section B.7, as approved by NRC SER dated March 24, 2005.

4.2.12 NQA-1-1994, Supplement 17S-1 In lieu of Supplement 17S-1, Section 4.2(b) which 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, hard-copy records maintained by SNC will be stored in steel file cabinets or on shelving in containers, except that methods other than binders, folders or envelopes may be used to organize the records for storage.

This alternative is consistent with Section B. 15 of the NMC QATR, approved by NRC SER dated March 24, 2005.

4.3 Category 3- Implementation of ANSI N18.7-1976 Category 3 changes represent changes to the Farley, Hatch, and Vogtle QAPs to incorporate the applicable requirements from ANSI N18.7-1976 into the QATR.

Regulatory Guide 1.33, Revision 2, provides NRC endorsement of ANSI N 18.7-1976 and includes regulatory positions that represent the NRC conditions of its endorsement of the standard.

Enclosure 5 provides a comparison of the requirements of ANSI N 18.7-1976 and NQA-1-1994. This comparison identifies specific requirements of ANSI N18.7-1976 that are not addressed by NQA-1-1994. For those items not addressed by NQA-1-1994, Enclosure 5 provides an excerpt from the proposed QATR that describes SNC conformance with ANSI N18.7-1976.

SNC has addressed the conditions contained in Regulatory Guide 1.33, Revision 2, in the proposed QATR as follows:

Page 20 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Regulatory Position C. 1 of Regulatory Guide 1.33, Revision 2, requires the preparation of many procedures to carry out an effective quality assurance program. Regulatory Guide 1.33, Revision 2, Appendix A provides a list of procedures that should used as guidance to ensure minimum procedural coverage for plant operating activities, including maintenance activities.

Part III of the proposed QATR, Regulatory Commitments, states the following:

Southern Nuclear considers that the collective quality assurance requirements of this QATR and the QA requirements of ASME NQA-1-1994 are equivalent to ANSI N18. 7-1976/ANS-3.2 and Regulatory Guide 1.33, Revision 2. Consequently, Southern Nuclear does not commit to ANSI Ni 8. 7-1976, or to Regulatory Guide 1.33, except that Appendix A of Regulatory Guide 1.33 shall be used as guidance for establishing the procedures requiredfor plant operationalphase activities.

" Regulatory Position C.2 of Regulatory Guide 1.33, Revision 2, provides a list of standards to be included as part of ANSI NI 8.7-1976. SNC believes that Regulatory Position C.2 is no longer considered valid, as the referenced standards and guidance have now been incorporated into ASME NQA- I-1994, addressed in Part III of the proposed QATR or addressed in the respective FSAR for each plant, as applicable.

" Regulatory Position C.3 of Regulatory Guide 1.33, Revision 2, requires that proposed changes to technical specifications or license amendments should be reviewed by the independent review body prior to their submittal to the Commission for approval.

This requirement is incorporated in QATR Appendix B, Section 4. Accordingly, the requirement of Regulatory Position C.3 of Regulatory Guide 1.33, Revision 2, is a commitment in the QA program description contained in the proposed QATR and therefore, a commitment to Regulatory Position C.3 is not necessary.

" Regulatory Position C.4 of Regulatory Guide 1.33, Revision 2, requires that audits of operational phase activities be performed with a frequency commensurate with their safety significance and goes on to provide specific guidance regarding required audit frequencies.

In lieu of audit topics and frequencies in accordance with Regulatory Guide 1.33, Revision 2, Regulatory Position C.4, Section 18.1 of the proposed QATR provides the audit frequencies that have been reviewed by the NRC and found to provide an acceptable basis for compliance with 10 CFR 50, Appendix B, as described in NRC SER to SNC dated June 17, 2005.

Page 21 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B

• Regulatory Position C.5 of Regulatory Guide 1.33, Revision 2, requires that specific ANSI N18.7-1976 guidelines be treated instead as requirements.

In lieu of compliance with Regulatory Guide 1.33, Revision 2, Regulatory Position C.5, SNC has established appropriate equivalent requirements within the QATR, as demonstrated in Enclosure 5.

The proposed QATR implements ANSI N18.7-1976 in a manner that is generally consistent with the Dominion NFQAPD previously approved by the NRC as an acceptable basis for meeting the requirements of 10 CFR 50, Appendix B, as described in SERs dated September 9, 2005.

4.4 Category 4 - Reduction in QAP Description Detail Category 4 changes represent changes that result in a reduction in the level of detail currently provided in the Farley, Hatch, and Vogtle QAPs described in Section 17.2 of the respective FSAR for each. This reduction in detail could be considered a reduction in commitments contained in the QAP descriptions. However, the proposed QATR does not reiterate the contents of NQA- I-1994 but instead, includes commitments to individual sections of NQA-1-1994, where applicable. This change is generally consistent with the NMC QATR and the Dominion NFQAPD determined by the NRC to provide an acceptable basis for meeting the requirements of 10 CFR 50, Appendix B.

4.5 Category 5 - Use of Generic Titles/Organization Charts Category 5 changes represent a change from the site-specific organization charts provided in Section 17.2 of the respective FSAR for each plant to generic organization charts contained Part II, Section 1 of the proposed QATR. The proposed change will result in deletion of the following FSAR figures:

Hatch - FSAR (Unit 2) Figure 17.2-1 Farley - FSAR Figure 17.2-1 Vogtle - FSAR Figure 17.2.1-1 The generic organization charts provided in the proposed QATR are supported by a narrative description in Part ii, Section 1, of the QATR.

Page 22 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B 5.0 Regulatory Analysis The requirements of 10 CFR 50.34(b) applicable to applicants for a license issued pursuant to 10 CFR Part 50 require the applicant to provide a Final Safety Analysis Report (FSAR) that describes the facility, presents the design basis and the limits on its operation, and presents a safety analysis of the structures, systems, and components. 10 CFR 50.34(b)(6)(ii) requires that applicants include in the FSAR a description of the managerial and administrative controls to be used to assure safe operation of the facility and a discussion of how the applicable requirements of 10 CFR 50, Appendix B, will be satisfied.

10 CFR 50.54 invokes conditions on licenses granted in accordance with the provisions of 10 CFR Part 50. These provisions include 10 CFR 50.54(a) which requires licensees to implement, pursuant to 10 CFR 50.34(b)(6)(ii), the quality assurance program described or referenced in the FSAR. As a result, Farley, Hatch, and Vogtle currently implement three separate QAPs described in Section 17.2 of the respective FSAR for each plant.

The provisions of 10 CFR 50.54(a) allow licensees to make changes to the QAP described in the FSAR. 10 CFR 50.54(a)(3) allows licensees to make changes to a previously approved QAP description included or referenced in the FSAR without prior NRC approval provided the change does not reduce the commitments in the program description as accepted by the NRC. In addition to changes involving administrative improvements, and clarifications, spelling corrections, punctuation, or editorial items, the following changes are not considered to be reductions in commitments:

(i) The use of a QA standard approved by the NRC which is more recent than the QA standard in the licensee's current QA program at the time of the change; (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided the bases of the NRC approval are applicable to the licensee's facility; (iii) The use of generic organizational position titles that clearly denote the position function, supplemented as necessary by descriptive text, rather than specific titles; (iv) The use of generic organizational charts to indicate functional relationships, authorities, and responsibilities, or alternately, the use of descriptive text; (v) The elimination of quality assurance program information that duplicates language in quality assurance regulatory guides or quality assurance standards to which the licensee is committed; and (vi) 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.

Changes to the QAP which result in a reduction in the commitments contained in the program description must be submitted to the NRC in accordance with the provisions of 10 CFR 50.54(a)(4) for approval prior to implementing the proposed change.

Page 23 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Although SNC believes the proposed changes to the Farley, Hatch, and Vogtle QAP meet the criteria of 10 CFR 50.54(a)(3) for changes that do not require NRC approval prior to implementation, SNC has elected to submit the proposed changes in accordance with the provisions of 10 CFR 50.54(a)(4) for NRC approval. Accordingly, SNC requests NRC approval of the proposed QATR provided in Enclosure I of this submittal as a replacement for the existing Farley, Hatch, and Vogtle QAPs described in the respective FSAR for each plant.

The following provides a summary of the proposed changes to the Farley, Hatch, and Vogtle QAPs and provides the regulatory basis for continued compliance with the requirements of 10 CFR 50, Appendix B. The SNC change categories described below correspond to the change categories described in Section 4 of this enclosure.

5.1 Category 1 Category 1 changes to the Farley, Hatch, and Vogtle QAPs represent changes to commitments from ANSI N45.2, including the corresponding daughter standards, to a commitment to ASME NQA-1-1994, as described in the proposed QATR. The NRC has reviewed NQA-I-1994 in conjunction with QA topical reports submitted by Exelon, Nuclear Management Company, and Dominion, and determined that NQA-1 -1994, as supplemented by ANSI N 18.7-1976, provides an acceptable basis for compliance with the requirements of 10 CFR 50, Appendix B. 1 '2 ,3' Although SNC believes that 10 CFR 50.54(a)(3) would allow implementation of the proposed QATR based on NQA- I- 1994, as supplemented by ANSI N 18.7-1976, without prior NRC approval, SNC has elected to submit the proposed QATR to the NRC for review and approval in accordance with the provisions of 10 CFR 50.54(a)(4).

5.2 Category 2 Category 2 changes represent alternates to NQA- 1-1994 that have been previously approved by the NRC as an acceptable basis for compliance with the requirements of 10 CFR 50, Appendix B, which are incorporated in the proposed QATR. Although these changes are a subset of Category 1 and do not technically represent direct changes to the existing Farley, Hatch, and Vogtle QAPs, these changes are highlighted in this manner to facilitate NRC review of the proposed QATR.

As stated above, Category 2 changes have been reviewed by the NRC and determined to provide an acceptable basis for compliance with the requirements of 10 CFR 50, Appendix B. SNC has reviewed the NRC-approved alternatives incorporated into the proposed QATR and the corresponding NRC SER which provides the basis for NRC acceptance of each alternative and believe these alternatives to be applicable to Farley, Hatch, and Vogtle.

That is, both SNC and the licensee for which the alternative was originally approved are required to meet the requirements of 10 CFR 50, Appendix B. NRC determination that NQA- 1-1994, as modified by NRC-approved alternatives to NQA- 1-1994, provides an Page 24 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B acceptable basis for compliance with 10 CFR 50, Appendix B, is directly applicable to Farley, Hatch, and Vogtle.

Although SNC believes 10 CFR 50.54(a)(3) would allow it to implement the proposed NRC-approved alternatives to NQA-1-1994 without prior NRC approval, SNC has elected to submit the proposed QATR, including the proposed alternatives to NQA- I-1994, to the NRC for review and approval in accordance with the provisions of 10 CFR 50.54(a)(4).

5.3 Category 3 Category 3 changes are changes to the Farley, Hatch, and Vogtle QAPs associated with implementation of ANSI Ni18.7-1976 required to facilitate implementation of a single QATR. Enclosure 5 provides a comparison of the requirements of ANSI N18.7-1976 and ASME NQA-1-1994 and describes SNC conformance with the applicable requirements of ANSI N18.7-1976. Alternatives to the requirements of ANSI N18.7-1976 are identified and the bases for each provided in Enclosure 5.

Historically, Farley, Hatch, and Vogtle have each included a commitment to ANSI NI 8.7 as part of their respective QAPs. However, the proposed QATR incorporates the applicable requirements of ANSI N18.7-1976 necessary to supplement NQA-1 -1994 as a basis for compliance with 10 CFR 50, Appendix B, in lieu of a specific commitment to ANSI N18.7-1976. This approach is consistent with that employed by NMC and Dominion in their respective QA topical reports which have been determined by the NRC to meet the requirements of 10 CFR 50, Appendix B.

Although SNC believes 10 CFR 50.54(a)(3)(ii) would allow implementation of the proposed NRC-approved alternatives to ANSI N18.7-1976 without prior NRC approval, SNC has elected to submit the proposed QATR, including the proposed alternatives to ANSI Ni18.7-1976, to the NRC for review and approval in accordance with the provisions of 10 CFR 50.54(a)(4).

5.4 Category 4 Category 4 changes are changes that represent a reduction in the level of detail currently provided in the Farley, Hatch, and Vogtle QAPs. The reduction in level of detail is due primarily to the requirements formerly contained in ANSI N45.2, including the daughter standards, being incorporated into NQA-I-1994. The provisions of 10 CFR 50.54(a)(3)(v) allow licensees to eliminate quality assurance program information that duplicates language in quality assurance regulatory guides or quality assurance standards to which the licensee is committed without prior NRC review and approval. Accordingly, the proposed QATR identifies the applicable commitments to NQA- 1-1994 and where applicable, does not repeat requirements contained in NQA-1-1994. The controls provided by the QATR and commitments to quality assurance regulatory guides and quality assurance standards contained therein provide the basis continued compliance with the requirements of 10 CFR 50, Appendix B.

Page 25 of 25 Description of Proposed Change/Basis for Concluding the Revised Program Continues to Satisfy 10 CFR 50, Appendix B Although SNC believes 10 CFR 50.54(a)(3)(v) would allow removal of the level of detail contained in the Farley, Hatch, and Vogtle QAPs necessary to implement the proposed QATR without prior NRC approval, SNC has elected to submit the proposed QATR to the NRC for review and approval in accordance with the provisions of 10 CFR 50.54(a)(4).

5.5 Category 5 Category 5 changes represent the replacement of organization charts contained in the Farley, Hatch, and Vogtle QAPs with a generic organization chart that is supported with narrative text. This change is consistent with the precedence established by NMC and Dominion in their QA topical reports and approved by the NRC as an acceptable basis for compliance with the applicable requirements of 10 CFR 50, Appendix B.

The provisions of 10 CFR 50.54(a)(3)(iv) allows licensees to make use of generic organizational charts to indicate functional relationships, authorities, and responsibilities and to do without prior NRC approval. Although SNC believes 10 CFR 50.54(a)(3)(iv) would the replacement of the existing organization charts contained in the Farley, Hatch, and Vogtle QAPs with the generic organizational chart contained in the proposed QATR without prior NRC approval, SNC has elected to submit the proposed QATR, including the generic organization chart, to the NRC for review and approval in accordance with the provisions of 10 CFR 50.54(a)(4).

6.0 References

1. NRC Safety Evaluation Report, Approval of Proposed Revision 70 of Quality Assurance Topical Report EGC-IA, Rev. 70, in accordance with 10 CFR 50.54(a)

Requirements for Exelon/Amergen Plants, dated December 24, 2002.

2. NRC Safety Evaluation Report, Approval of Nuclear Management Company Quality Assurance Topical Report, dated March 24, 2004.

3. NRC Safety Evaluation Report, Approval of Dominion Nuclear Connecticut and Virginia Electric and Power Company Quality Assurance Program Description Topical Report for Millstone Power Station Unit Nos. 1, 2, and 3, North Anna Power Station Units 1 and 2, and Surry Power Station Unit Nos. I and 2, dated September 9, 2005.

Enclosure 3 Southern Nuclear Operating Company Quality Assurance Topical Report Existing QA Programs vs. QATR Comparison Matrix Existing QA Programs vs. QATR Comparison Matrix Page I of 85 Section 1 Joseph M. Farley Nuclear Plant

Reference:

FSAR 17.2 - Operations Quality Assurance Program, Revision 20, dated January 2006 Current GA Program QATR Section R/N/I Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) 17.2 (1) Part I, Section 1(1) QATR establishes QA program and N Both the existing QAP description and the administrative control requirements proposed QATR provide appropriate that meet 10 CFR 50, Appendix B, controls to assure continued compliance while existing FSAR 17.2 commits with the requirements of 10 CFR 50, to compliance with 10 CFR 50, Appendix B.

Appendix B "...as delineated in Regulatory Guide 1.33, dated November 3, 1972, 'Quality Assurance Requirements (Operation)."'

17.2 (2) Part I, Section 1(1) QATR commits to compliance with N As stated in the NRC SER for NMC dated, ASME NQA-I-1 994, as March 24, 2005, NQA-I-1 994, as supplemented by the applicable supplemented by N18.7-1976, provides an requirements of ANSI N18.7-1976 acceptable basis for a quality assurance described in the QATR, in lieu of program required to meet the requirements "ANSI N45.2-1971 and ANS 3.2 of 10 CFR 50, Appendix B.

(now ANSI N18.7-1972)."

17.2 (3) Part I, Section 1.1 (2); N Table 17.2A-1 is being relocated to the 10 Appendix F CFR 72.212 Report 17.2 (4) Intentionally not Note 2 - cross reference to N18.7 is N Reference Part III, Regulatory Guide 1.33 included no longer applicable, clarifications 17.2 (N18.7 table) Intentionally not Note 2 - cross reference to N18.7 is N Reference Part IIl, Regulatory Guide 1.33 included no longer applicable, clarifications Existing QA Programs vs. QATR Comparison Matrix Page 2 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences RDNor Basis for Acceptability (paragraph) 17.2 (5, incl. table) Part III, Regulatory QATR Part III does not include 10 N Non-QA Program related regulatory guides Commitments CFR citations as SNC is required to have been intentionally deleted from the QA comply with the regulation without Program Description as this document is a separate commitment cited in the intended to only address QA Program QATR. QATR Part III lists the QA topics. Commitments to applicable Program related Regulatory Guides Regulatory Guides are shown in FSAR to which SNC is committing. Appendix 3A.

17.2 (6) Policy Statement N Not a commitment 17.2 (7) Part I, Section 1.1(1) OQAPM is replaced by the QATR. N through 1.1(3) 17.2 (8) Part I, Section 1.1 (2) N 17.2.1 Part II, Section 1; Note 3: No longer commits to R Staff sizing will be adjusted as needed to Appendix C specific QA Staff sizing ensure auditing and other QA activities are conducted as committed in the QATR.

17.2.2 (1) Intentionally not N Historical information only. Not a included commitment.

17.2.2 (2) Part I, Sections 1 The stated purpose of the QATR is N and 1.1 to assure compliance with the requirements of 10 CFR 50, Appendix B, as stated in Part I, Section 1. Section 17.3 of the FSAR will not be changed as a result of the QATR.

Existing QA Programs vs. QATR Comparison Matrix Page 3 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/Nol Description Section/ (paragraph) Differences (Note 1) Basis for Acceptability (paragraph) 17.2.2 (3) Part II, Section 2 N 17.2.2 (4) Part, II, Sections 2.1 Note 2 N and 5 17.2.2 (5) Part II, Section 2.3 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 2 and Supplement 2S-4.

These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.2 (6) Part II, Section 2.3 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 2S-4. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.2 (7) Part II, Section 2.3 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 2 (see Paragraph 3).

These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 4 of 85 Section 1 Joseph M. Farley Nuclear Plant Current GA Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.2 (8) Not addressed Deletion of the cross reference to N This statement is a cross-reference to the Sections 13.1.3 and 13.2. conduct of operation provided in FSAR Section 13. The qualifications and training program requirements for the plant staff described in FSAR Sections 13.1.3 and 13.2 are not impacted by the proposed QATR.

17.2.2 (9) Part II, Section 2.4 Personnel assigned to perform N The proposed QATR includes a inspections and tests may be commitment to NQA-1 -1994, including qualified based on experience, Supplements 2S-1 and 2S-2. These education, and demonstrated requirements are equivalent to those abilities in lieu of establishing levels contained in the specified paragraph of the for inspectors. current QA program description.

Exceptions to Supplements 2S-1 and 2S-2 are identified in Enclosure 4.

17.2.2 (10) Part II, Section 2.4 Personnel assigned to perform N The proposed QATR includes a inspections and tests may be commitment to NQA-1-1994, including qualified based on experience, Supplements 2S-1 and 2S-2. These education, and demonstrated requirements are equivalent to those abilities. contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 2S-1 and 2S-2 are identified in Enclosure 4.

Existing QA Programs vs. QATR Comparison Matrix Page 5 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) 17.2.2(11) Part II, Section 9.1 N The propose QATR includes a commitment to NQA-1 -1994, including Supplement 9S-1.

Section 3.3 of NQA-1-1994, Supplement 9S-1 provides equivalent requirements to those contained in the specified paragraph of the current QA program description.

17.2.2 (12) Part II, Section 2.4 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplements, 2S-1 and 2S-3. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 2S-1 and 2S-3 are identified in Enclosure 4.

17.2.2 (13) Part I, Section 1.4 The OQAPM for Farley will be N (Bullet 1) deleted and replaced by the QATR which will be controlled by the EVP/Chief Nuclear Officer 17.2.3 Part II, Section 3 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 3. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3.1 (1) Part II, Section 3 N The proposed QATR includes a commitment to NQA-1 -1994, Supplement Existing QA Programs vs. QATR Comparison Matrix Page 6 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph)Differences Basis for Acceptability (paragraph) 3S-1 in lieu of ANSI N45.2.11-1974.

Paragraph 5 of Supplement 3S-1 provides requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3.1 (2) Part II, Sections 3.3 Note 2 N The proposed QATR includes a and Section 6.2; commitment to NQA-1 -1994, including Appendix A and Supplements 3S-1 and Supplement 6S-1.

Appendix B Paragraph 5 of Supplement 3S-1 and Paragraph 1 of Supplement 6S-1 provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Equivalent requirements for PRB and SRB review are provided in Appendices A and B, respectively.

17.2.3.1 (3) Part II, Section 3.1 Note 2 N (3) Design Verification Existing QA Programs vs. QATR Comparison Matrix Page 7 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/N/I Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) 17.2.3.1 (4) Part II, Sections 3.3, Note 2 N The proposed QATR includes a 16, and 17.2; commitment to NQA-1 -1994, including Appendices A and B Supplement 3S-1 and Supplement 17S-1.

Paragraphs 5 and 7 of Supplement 3S-1, and Supplement 17S-1 provide equivalent requirements to those contained in the specified paragraph of the current QA program description. Equivalent requirements for PRB and SRB review are provided in Appendices A and B, respectively.

17.2.3.1 (5) Part II, Section 18 Note 2 17.2.3.1 (6) Intentionally not QATR does not require cognizant 10 CFR 50 Appendix B and other QA included management to review abnormal standards do not address operating operating experiences at other experience. OE is an input to the SNC facilities. corrective action program.

17.2.3.1 (7) Part II, Section 7.1, bullet 2 17.2.3.2 (1) Part II, Section 7 Note 2 - Nuclear Fuel Contractors' Reference 17.2.4 (4); This is covered by the QA Programs will be reviewed and program for auditing suppliers at frequency evaluated along with all other established by NUPIC. Also, surveillances supplier QA Programs. are performed by Nuclear Fuels.

17.2.3.2 (2) Intentionally not Not a commitment included Existing QA Programs vs. QATR Comparison Matrix Page 8 of 85 Section 1 Joseph M. Farley Nuclear Plant Current GA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) 17.2.3.2 (3) Intentionally not Note 2 N included 17.2.3.2 (4) Part II, Section 18 Audit of fuel vendors is included in N (supplier audits) generic commitment to audit supplier activities 17.2.3.2 (5) Intentionally not QATR does not require technical R 10CFR50, Appendix B and NQA-1-1994 do included assistance from fuel fabrication be not require use of the fuel fabricator to do provided to support nuclear fuel receipt inspections.

receipt inspection.

17.2.4 (1) Part II, Section 4; Note 2 N Part II, Section 1.3.1.1 17.2.4 (2) Part II, Sections 4.2 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 4 and Supplement 4S-1.

These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 4S-1 are identified in Enclosure 4.

17.2.4 (3) Intentionally not Note 2 N included 17.2.4 (4) Part II, Sections 4 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Existing QA Programs vs. QATR Comparison Matrix Page 9 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section RDNor Description Section/ Differences Basis for Acceptability (paragraph)

Basic Requirement 4 and Supplement 4S-1.

These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 4S-1 are identified in Enclosure 4.

17.2.4 (5) Part II, Section 4 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 4 and Supplement 4S-1.

These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 4S-1 are identified in Enclosure 4.

17.2.4 (6) Part II, Section 18 N and 18(2)(bullet 4) 17.2.5 (1) Part II, Section 5 Note 2: QATR requires "activities I The proposed QATR includes a affecting quality" in lieu of "all commitment to NQA-1-1994, including safety related activities" Basic Requirement 5. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.5 (2) Part II, Section 5 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 5. These requirements are equivalent to those contained in the Existing QA Programs vs. QATR Comparison Matrix Page 10 of 85 Section 1 Joseph M. Farley Nuclear Plant Current OA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) specified paragraph of the current QA program description 17.2.5 (3) Part II, Sections 5 Note 2 N 17.2.5 (4) Part II,Section18 Note 2 N 17.2.5.1 Part II, Section 5; Note 2 N Regulatory Guide 4.15 commitment is being Appendix E moved to FSAR Chapter 11 17.2.5.2 Appendix A; Part II, N Section 6.1 17.2.6(1) Intentionally not N Not a commitment - Historical included 17.2.6 (2) Part II, Section 5 N 17.2.6 (3) Intentionally not Note 2 N included 17.2.6 (4) Part II, Section 18 Note 2 N 17.2.7(1) Part II, Sections Note 2 N The proposed QATR includes a 1.2.1.1.3.1,4, and 7 commitment to NQA-1 -1994, including Supplement 4S-1. The existing FSAR describes the organizational responsibilities of Supply Chain which is addressed in QATR Part II, Section 1.2.1.1.3.1. These requirements are equivalent to those contained in the specified paragraph of the Existing QA Programs vs. QATR Comparison Matrix Page 11 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences Basis for Acceptability (paragraph) current QA program description.

17.2.7 (2) Part II, Section 7.2 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 7S-1. Paragraph 3.1 of Supplement 7S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

+ + +

17.2.7 (3) Part II, Sections 7.2 Note 2 N The proposed QATR includes a and 15 commitment to NQA-1 -1994, including Supplement 7S-1. Paragraphs 8.2.3 and 9 of Supplement 7S-1, in conjunction with QATR Part II, Section 15, provide requirements equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7 (4) Part II Section 18 and Note 2 Part II, Section 7.1 17.2.7 (5) Part II Section 18 and Note 2 Part II, Section 7.1 17.2.7 (6) Part II Section 18 Note 2 Existing QA Programs vs. QATR Comparison Matrix Page 12 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/N/I Description Section/ (paragraph) Differences Basis for Acceptability (paragraph) 17.2.7 (7) Part II, Section 7.1 QATR no longer requires material R The proposed QATR includes a that is to be used as-is undergo a commitment to NQA-1 -1994, including PRB recommendation and NPGM Supplement 7S-1, which includes action to accept prior to its use in requirements that are generally equivalent the plant. to those contained in the specified paragraph of the current QA program description.

As stated in Enclosure 4, the proposed QATR includes the clarification that SNC considers documents that may be stored in approved electronic media under SNC control and not physically located on the plant site but accessible from the respective nuclear facility site as meeting NQA-1 -1994 requirements for documents to be available at the site.

17.2.8 (1) Part II, Section 8.1 The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 8. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.8 (2) Part I, Section 1.1; Part II, Section 8 17.2.8 (3) Part II, Sections 7 Note 2 The proposed QATR includes a and 8.1 commitment to NQA-1 -1994, including Supplement 8S-1. Paraqraph 3.3 of Existing QA Programs vs. QATR Comparison Matrix Page 13 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ Differences R/N/o Basis for Acceptability (paragraph)

Supplement 8S-1 includes requirements that, in conjunction with Part II, Section 7 of the QATR, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.8 (4) Part II, Sections 1, Note 2 N The proposed QATR includes a 8.1, and 18 commitment to NQA-1 -1994, including Basic Requirement 8. These requirements, in conjunction with Part II, Sections 1 and 18, of the QATR, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.8 (5) Part II, Sections 4, N The proposed QATR includes a 8.1, and 18 commitment to NQA-1 -1994, including Basic Requirement 8 and Supplement 8S-1.

Paragraph 3.3 of Supplement 8S-1 includes requirements that, in conjunction with Part II, Sections 4, 8.1, and 18, of the QATR, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.9(1) Part II, Section 9 N 17.2.9 (2) Part II, Sections 4 Note 2 N The proposed QATR includes a and 9.1 commitment to NQA-1 -1994, including Basic Requirement 9 and Supplement 9S-1.

These requirements, in conjunction with QATR Part II, Section 4, provide Existing QA Programs vs. QATR Comparison Matrix Page 14 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ Differences R/N/I Basis for Acceptability (paragraph) requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.9 (3) Part II, Section 18 Note 2 N 17.2.10(1) Part II, Section 10 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 1OS-1. These requirements, in conjunction with QATR Part II, Section 10, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (2) NQA-1-1994, The items listed in the FSAR to be R NQA-1-1994 has been previously Supplement 1OS-1 documented for each inspection is determined by the NRC to provide an Paragraph 9 generally the same as that acceptable basis for a QAP required to contained in NQA-1-1994, meet 10 CFR 50, Appendix B.

Supplement 1OS-1; however, it is not clear that the "identification of any instruments or special equipment used" must be included.

In addition, it is not clear that "acceptance and rejection criteria" must be included.

17.2.10 (3) Part II, Section 10.1 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including 1OS-

1. Paragraphs 3.2 and 5.1 of Supplement Existing QA Programs vs. QATR Comparison Matrix Page 15 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/NoI Description Section/ (paragraph) Differences (Note 1) Basis for Acceptability (paragraph) 1oS-1 provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (4) Part II, Sections 1 Note 2 N The proposed QATR includes a and 10.1 commitment to NQA-1-1994, including 10S-

1. Paragraph 3.2 of Supplement 1OS-1, in conjunction with QATR Part II, Section 1, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (5) and (6) Part II, Section 1 Note 2 N Does not change the commitment to do proper reviews of inspection procedures.

Note: 1OS-1, Paragraph 3.2. requires that inspections be done by qualified persons.

17.2.10 (7A) Part II, Section 10.1 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 10. These requirements provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (7B) Part II, Section 10.1 Note 2 N Intentionally not included, except last sentence is NQA-1-1994, Supplement 10S-1, Paragraphs 2 and 3.1.

17.2.10 (7C) Part II Section 10 Note 2 N Existing QA Programs vs. QATR Comparison Matrix Page 16 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section RDNen Description Section/ (paragraph) Differences (Note 1) Basis for Acceptability (paragraph) 17.2.10 (7D) Part II, Sections 1 Note 2 N and 10 17.2.10 (7E) Part II, Section 18 Note 2 N 17.2.11 (1) Part II, Section 11.1 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 11S-1. Paragraph 2 of Supplement 11S-1 provides requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (2) Part II, Section 11 Note 2 N 17.2.11 (3) Part II, Section 5.2 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 5. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (4) Part II, Section 11.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 11S-1. Paragraph 5 of Supplement 11S-1 provides requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 17 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/Nor Description Section/ (paragraph) Differences N1Basis for Acceptability (paragraph) (paagrph 17.2.11 (5) Part III; Part II, Note 2 N See Enclosure 2 for the disposition of Section 10.1 Regulatory Guides that endorsed ANSI N45.2, including daughter standards.

17.2.11 (6) Part II Section 18 N 17.2.12 (1) Part II, Section 12.1 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 12 and Supplement 12S-1. Basic Requirement 12 and Paragraph 3.1 of Supplement 12S-1 provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (2) Part II Sections 2.4 N The proposed QATR includes a and 12 commitment to NQA-1 -1994, including Basic Requirement 12 and Supplements 2S-4 and 12S-1. These requirements, in conjunction with QATR Part II, Section 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (3) Part II Section 12 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 12S-1. Paragraph 3.2 of Supplement 12S-1, in conjunction with QATR Part II, Section 12, provide requirements that are equivalent to those Existing QA Programs vs. QATR Comparison Matrix Page 18 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ Differences RDNor Basis for Acceptability (paragraph) contained in the specified paragraph of the current QA program description.

17.2.13(1) Part II, Sections 4 N The proposed QATR includes a and 13 commitment to NQA-1 -1994, including Basic Requirement 13. These requirements, in conjunction with QATR Part II, Section 4, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.13 (2) Part II, Sections 7, N The proposed QATR includes a 13, 15, and 18 commitment to NQA-1 -1994, including Supplement 13S-1, Subpart 2.1, and Subpart 2.2. These requirements, in conjunction with QATR Part II, Sections 7, 13, 15, and 18, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to NQA-1 -1994, Subparts 2.1 and 2.2 are identified in Enclosure 4.

17.2.13 (3) Part II, Section 13.2 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Subpart 2.3. These requirements, in conjunction with QATR Part II, Sections 13, are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 19 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph)Differences Basis for Acceptability (paragraph) program description.

Exceptions to NQA-I-1 994, Subpart 2.3, are identified in Enclosure 4.

17.2.13 (4) Part II, Section 13.2 The proposed QATR includes a commitment to NQA-1-1994, including Subpart 2.1. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to NQA-1-1994, Subpart 2.1 are identified in Enclosure 4.

17.2.13 (5) Part II, Section 18 This FSAR section is a partial list of R Note 4 the activities that QA will audit.

The QATR Part II, Section 18 includes a requirement that QA will audit the performance of activities required by the quality assurance program to meet the criteria of 10 CFR 50, Appendix B. This covers the intent of the FSAR detailed paragraph, but is less detailed.

17.2.13 (6) Part II, Section 18 This FSAR section is a partial list of R Note 4 the activities that QA will audit.

The QATR Part II, Section 18 includes a requirement that QA will audit the performance of activities required by the quality assurance Existing QA Programs vs. QATR Comparison Matrix Page 20 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences RDNor Basis for Acceptability (paragraph) program to meet the criteria of 10 CFR 50, Appendix B. This covers the intent of the FSAR detailed paragraph, but is less detailed.

17.2.14(1) Information only Note 2 N 17.2.14 (2) Part II, Section 14 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 14. These requirements, in conjunction with QATR Part II, Sections 14, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.14 (3) Part II, Section 18 Note 2 N 17.2.15(1) Part II, Section 15 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 15 and Supplement 15S-1. These requirements, in conjunction with QATR Part II, Section15, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15 (2) Appendix A The QATR does not require the R The PRB charter incorporated into the PRB to review the acceptance of proposed QATR is consistent with that nonconforming material that is contained in Dominion Nuclear Facility determined during receipt Quality Assurance Program Description, inspection to be acceptable for use approved by NRC SER dated September 9, Existing QA Programs vs. QATR Comparison Matrix Page 21 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program OATR Section Description Section/ (paragraph)Differences Basis for Acceptability (paragraph) as-is. 2005.

17.2.15 (3) Part II, Section 18 QATR does not require the R The PRB charter incorporated into the following detail shown in the FSAR: proposed QATR is consistent with that "After the PRB recommends to contained in Dominion Nuclear Facility accept as is or to reject or rework Quality Assurance Program Description, an item and a decision is made by approved by NRC SER dated September 9, the NPGM, the QA staff will 2005.

selectively audit design, segregation, rework, or acceptance activities performed to comply with the decision. Rather, the QATR states "This FSAR section is a partial list of the activities that QA will audit. The QATR Part II, Section 18 includes a requirement that QA will audit the performance of activities required by the quality assurance program to meet the criteria of 10 CFR 50, Appendix B.

This covers the intent of the FSAR detailed paragraph, but is less detailed."

17.2.15 (4) Part II, Section 18 17.2.16 (1) Part II, Section 16 Note 2 17.2.16 (2) Part II, Section 16; Appendix A and Existing QA Programs vs. QATR Comparison Matrix Page 22 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences Basis for Acceptability (paragraph)

Appendix B 17.2.16 (3) Part II, Section 15 Note 2 17.2.16 (4) Part II, Section 18 Note 2 17.2.17 (1) Part II, Sections 9 The proposed QATR includes a and 17, and commitment to NQA-1 -1994, including Appendix F Basic Requirements 9 and 17, and Supplement 17S-1. These requirements, in conjunction with QATR Part II, Section 17, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.17 (2) Part II, Section 17 The proposed QATR includes a commitment to NQA-1-1994, including Supplement 17S-1. Paragraph 4.2 of Supplement 17S-1, in conjunction with QATR Part II, Section 17, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.17 (3) Part II, Section 18 17.2.17 (4) Part II, Section 17.2 Commitment to RIS 2000-18 satisfies this commitment 17.2.17 (5) Part II, Section 18 Note 2 Existing QA Programs vs. QATR Comparison Matrix Page 23 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/NoI Description Section/ Differences Basis for Acceptability (paragraph) 17.2.17 (6) Part II, Section 18 Note 2 N 17.2.17 (7) Part II, Section 18 Note 2 N 17.2.17 (8) Part II, Section 18 Note 2 N 17.2.18 (1) Part II, Section 18.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 18. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.18 (2) Part II, Sections 2.4 N The proposed QATR includes a and 18.2 commitment to NQA-1-1994, including Basic Requirement 18 and Supplement 2S-

3. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to NQA-1-1994, Supplement 2S-3, are identified in Enclosure 4.

17.2.18 (3) Part II, Section 2.4; 3 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 2S-3. Paragraph 3.3 of Supplement 2S-3 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to NQA-1 -1994, Supplement Existing QA Programs vs. QATR Comparison Matrix Page 24 of 85 Section 1 Joseph M. Farley Nuclear Plant Current GA Program QATR Section Description Section/ Differences RDN/I Basis for Acceptability (paragraph) 2S-3, are identified in Enclosure 4.

17.2.18 (4) Part II, Section 18 N 17.2.18 (5) Part II, Section 18 N 17.2.18 (6) Part II, Section 18 N 17.2.18 (7) Part II Section1; Part N The proposed QATR includes a II, Section 18 commitment to NQA-1-1994, including Basic Requirement 18. These requirements, in conjunction with Part II, Section 18, of the QATR, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.18 (8) Part II, Section 18.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 18, which provides requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.18 (9) Part II, Sections 18 N and 18.1 17.2.18 (10) Part II, Section 18.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 18S-1. Paragraph 3.1 of Supplement 18S-1 includes requirements that are equivalent to those contained in the Existing QA Programs vs. QATR Comparison Matrix Page 25 of 85 Section 1 Joseph M. Farley Nuclear Plant Current QA Program QATR Section R/eNo Description Section/ (paragraph) Differences (Note 1) Basis for Acceptability (paragraph) specified paragraph of the current QA program description.

17.2.19 Part I, Section 1.2 N 17.2.20 Heading only N 17.2.20.1 Heading only N 17.2.20.1.1 Part 1, Section 1.2 Note 2 N 17.2.20.1.2 Appendix A QATR contains a different PRB R The PRB charter incorporated into the Charter than that shown in the proposed QATR is consistent with that FSAR. contained in Dominion Nuclear Facility Quality Assurance Program Description, approved by NRC SER dated September 9, 2005.

17.2.20.2 Appendix B N 17.2.20.3 Part II, Sections 3 & Note 2 N 5; Appendix A Supplement 17.2A Appendix F N Table 17.2A-1 N Moved to Farley 10 CFR 72.212 report for ISFSI Table 17.2-1 Part II, Section 1 and Note 3: No longer commits to R Staff sizing will be adjusted as needed to Appendix C specific QA Staff sizing ensure auditing and other QA activities are conducted as committed in the QATR.

Existing QA Programs vs. QATR Comparison Matrix Page 26 of 85 Section 1 Joseph M. Farley Nuclear Plant NOTES:

1. R = Reduction in Commitment N = Not a reduction in Commitment I = Increase in Commitment

2. Wording in the QATR establishes equivalent requirements or commitments, even though there may be a reduction in the level of detail.

3. The QATR describes the standard organization for SNC. The wording is different from that of the existing FSAR, but the structure is the same.

4. The commitment previously included is not required to meet 10 CFR 50, Appendix B, or other quality assurance standards.

Existing QA Programs vs. QATR Comparison Matrix Page 27 of 85 Section 2 Edwin I. Hatch Nuclear Plant

Reference:

FSAR 17.2 - Quality Assurance Program During the Operations Phase, Revision 23B, dated November 2005 Current GA Program QATR Section R/N/o Description Section/ Differences Basis for Acceptability (paragraph) 17.2 (1) Part I, Section 1; Part N SNC commits to requirements equivalent to III, Regulatory Guide Regulatory Guide 1.33 / N1 8.7-1976 as 1.33 discussion described in the QATR.

17.2 (2) Part I, Section 1.1(2); N Appendix F 17.2 (3) Part I, Section 1.2, N The proposed QATR includes a and Part II, Section 2 commitment to NQA-1 -1994, including Basic Requirement 2. Basic Requirement 2, in conjunction with QATR, Part I, Section 1.2, and Part II, Sections 2, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.1 Intentionally not Note 3 N Information only - not a commitment included 17.2.2.1 (1) Intentionally not N Information only- not a commitment included 17.2.2.1 (2) Part I, Section 1.1(2) N 17.2.2.1 (3) Part I, Section 1.1(2) N 17.2.2.1 (4) Intentionally not N Information only - not a commitment included Existing QA Programs vs. QATR Comparison Matrix Page 28 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.2.1 (5) Part II, Sections 2.4 Note 2 N The proposed QATR includes a and 5 commitment to NQA-1 -1994, including Basic Requirement 2. Basic Requirement 2, in conjunction with QATR Sections 2 and 5, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.2.2 (1) Part II, Section QA program approval moved to 1.2.1.1.1; and CNO instead of Project VP Appendix B 17.2.2.2 (2) Part I, Section 1(2) N 17.2.2.2 (3) Part II, Section 2 (1); N Section 7.1 (bullet 2);

and Section 18.1 (3) 17.2.2.2 (4) Part II, Section 2.1 N QATR replaces the QA program described in FSAR Chapter 17.2, and requires compliance by all personnel who work directly or indirectly for SNC.

17.2.2.3 (1) Part II, Section 2.1 N 17.2.2.3 (2) Part II, Section 1 N Existing QA Programs vs. QATR Comparison Matrix Page 29 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences RDNor (Note 1) Basis for Acceptability (paragraph) 17.2.2.4 (1) Part 2, Sections 2.3 N The proposed QATR includes a and 2.4 commitment to NQA-1 -1994, including Supplements 2S-3 and 2S-4. These requirements, in conjunction with QATR Part II, Section 2.3, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 2S-3 and 2S-4 are identified in Enclosure 4.

17.2.2.4 (2) Part II, Sections 2.3 N The proposed QATR includes a and 2.4 commitment to NQA-1 -1994, including Supplement 2S-4. These requirements, in conjunction with QATR Part II, Section 2.3, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-4 are identified in Enclosure 4.

17.2.2.4 (3) Part II, Section 2.3; N The proposed QATR includes a NQA-1 -1994 commitment to NQA-1 -1994, including Supplement 2S-4 Supplement 2S-4. These requirements, in conjunction with QATR Part II, Section 2.3, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-4 are Existing QA Programs vs. QATR Comparison Matrix Page 30 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section R/N/I Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) identified in Enclosure 4.

17.2.3(1) Part II, Section 5 N 17.2.3 (2) Part II, Sections 3 Note 2 N The proposed QATR includes a and 7 commitment to NQA-1-1994, including Supplements 3S-1 and 7S-1. These requirements, in conjunction with QATR Part II, Sections 3 and 7, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.3 (3) Part II, Sections 3, 6, N The proposed QATR includes a 16, and 17 commitment to NQA-1-1994, including Supplement 3S-1. Paragraph 4 of Supplement 3S-1, in conjunction with QATR Part II, Sections 3, 6, 16, and 17, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (4) Appendices A and B N 17.2.3 (5) Part II, Section 3.3 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 3S-1. Paragraph 5 of Supplement 3S-1 provides requirements that are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 31 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) program description.

17.2.4 Part II, Sections 4 N and 5 17.2.4.1 (A) Part II, Sections 4 Note 2 N and 8 17.2.4.1 (B) Part II, Sections 1, Note 2 N The proposed QATR includes a 1.2.1.1.3.1, and 4.2 commitment to NQA-1-1994, including Supplement 4S-1. These requirements, in conjunction with QATR Part II, Sections 1, 1.2.1.1.3.1, and 4.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4.1 (C) Part II, Section 4(1) Note 2 N 17.2.4.1 (D) Part II, Section 4 N 17.2.4.1 (E) Part II, Section Note 2 N 1.2.1.1.3.1 17.2.4.1 (F) Part II, Section 17 Note 2 N 17.2.4.1 (2) Part II, Section 4.1 Note 2 N 17.2.4.1 (3) Part II, Section 18 N Existing QA Programs vs. QATR Comparison Matrix Page 32 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ Differences R/N/I Basis for Acceptability (paragraph) 17.2.5 Part II, Section 5 N 17.2.5.1 (1) Part II, Sections 5 Note 2 N and 6; Appendix A 17.2.5.1 (2) Appendix E N 17.2.5.1 (3) Part II, Sections 3.2 Note 2 N The proposed QATR includes a and 3.3 commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Paragraph 5 of Supplement 3S-1, in conjunction with QATR Part II, Section 3.2, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.5.2 (1) Part II, Sections 5 N QA audits functional areas, including and 18 procedure control process 17.2.5.2 (2) Intentionally not N Information only - not a commitment included 17.2.6.1 (1) Appendix A; Part II, N Section 6 17.2.6.1 (2) Part II, Section 6.1 N 17.2.6.1 (3) Part II, Sections 1 Note 2 N The proposed QATR includes a and 6 commitment to NQA-1 -1994, including Basic Requirement 6. These requirements, in conjunction with QATR Part II, Sections 1 Existing QA Programs vs. QATR Comparison Matrix Page 33 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program Description Section/ QATR Section (paragraph) Differences R/Nol Basis for Acceptability (paragraph) and 6, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.6.2 (1) Part II, Section 1 Note 2 N 17.2.6.2 (2) Appendices A & B Note 2 N 17.2.6.3 Part II, Sections 5 N and 6 17.2.7 Part II, Section 7 N 17.2.7.1 (1) Part II, Section 7.1 N The proposed QATR includes a (bullet 2) commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Paragraph 10 of Supplement 7S-1, in conjunction with QATR Part II, Section 7.1, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.1 (2) Part II, Sections 1,7, N The proposed QATR includes a and 18 commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraph 10 of Supplement 7S-1, in conjunction with QATR Part II, Sections 1, 7, and 18, are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 34 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ Differences R/N/o Basis for Acceptability (paragraph) program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.1 (3) Part II, Sections 7.1 Note 2 N and 18 17.2.7.1 (4) Part II, Sections 7.1 Note 2 N and 18 17.2.7.1 (5) Part II, Section 7.2 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraph 3 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.1 (6) Part II, Section 7.1 N (bullet 2) 17.2.7.2 (1) Part 2, Section 7.1 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Supplement 7S-1, in conjunction with QATR Part II, Section 7.1, are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 35 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current OA Program QATR Section Description Section/ Differences R/eNo Basis for Acceptability (paragraph)

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.2 (bullet 1) NQA-1 -1994 Note 2 N The proposed QATR includes a Supplement 7S-1 commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.2 (bullet 2) Part II, Sections 5 & N 7.1 17.2.7.3 (1) Part II, Section 7.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Paragraph 8.2.3 of Supplement 7S-1, in conjunction with QATR Part II, Section 7.1, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (2) NQA-1 -1994, N The proposed QATR includes a Supplement 7S-1, commitment to NQA-1-1994, including Paragraph 8.2.3 Supplement 7S-1. The requirements of Paragraph 8.2.3 of Supplement 7S-1 are Existing QA Programs vs. QATR Comparison Matrix Page 36 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section D eNor Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (3) Part II, Section 8 N 17.2.7.3 (4) Part II, Section 18 N 17.2.8 (1) Part II, Section 8.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 8 and Supplement 8S-

1. The requirements of Basic Requirement 8 and Paragraph 3 of Supplement 8S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.8 (2) Part II, Section 18 N and Section 7 17.2.8 (3) Part II, Sections 8, N 13, and 15 17.2.9 (1) Part II, Sections 9 N and 18 17.2.9 (2) Part II, Section 18 N 17.2.10 (1) Part II, Section 10 N The proposed QATR includes a Existing QA Programs vs. QATR Comparison Matrix Page 37 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/Nol Basis for Acceptability (paragraph) commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraph 9 of Supplement 1OS-1, in conjunction with QATR Part II, Section 10, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (2) Part II, Section 12.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 12. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (3) Part II, Sections 1 & Note 2 N 10 17.2.10 (4) Part II, Section 10 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 1OS-1. The requirements of Paragraphs 4 and 6.1 of Supplement 1OS-1, in conjunction with QATR Part II, Section 10, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (5) Part II, Section 10.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraphs 6 of Supplement 1OS-1 are Existing QA Programs vs. QATR Comparison Matrix Page 38 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current GA Program QATR Section RDNat Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (6) Part II, Section 18 N 17.2.11 (1) Part II, Section 11; N The proposed QATR includes a and NQA-1-1994, commitment to NQA-1 -1994, including Supplement 11S-1, Supplement 11S-1. The requirements of Paragraphs 3 and 4 Paragraphs 3 and 4 of Supplement 11S-1, in conjunction with QATR Part II, Section 11, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (2) Part II, Sections 6 Note 2 N The proposed QATR includes a and 11 commitment to NQA-1-1994, including Supplement 11S-1. The requirements of Paragraph 5 of Supplement 11S-1, in conjunction with QATR Part II, Sections 6 and 11, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (3) Part II, Sections 6 Note 2 N and 18; Appendix A 17.2.12 (1) Part II, Section 12 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 12 and Supplement 12S-1. These requirements, in conjunction Existing QA Programs vs. QATR Comparison Matrix Page 39 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ Differences R/N/o Basis for Acceptability (paragraph) with QATR Part II, Section 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (2) Part II, Section 12 N The proposed QATR includes a and Section 12 (3) commitment to NQA-1 -1994, including (bullet 3) Supplement 12S-1. The requirements of Paragraph 3.2 of Supplement 12S-1, in conjunction with QATR Part II, Section 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (3) Part II, Section N 12(3)(bullet 4) 17.2.12 (4) Part II, Section N 12(3)(bullets 2 & 5) 17.2.12 (5) Part II, Section 18 N 17.2.13 (1) Part II, Section 13.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 13S-1. The requirements of Paragraph 2 of Supplement 13S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.13 (2) Part II, Sections 7, Note 2 N Existing QA Programs vs. QATR Comparison Matrix Page 40 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 13, and 18 17.2.14 (1) Part II, Section 14.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 14. The requirements of Basic Requirement 14 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.14 (2) Part II, Sections 14 Note 2 N The proposed QATR includes a and 18 commitment to NQA-1-1994, including Basic Requirement 14. The requirements Basic Requirement 14, in conjunction with QATR Part II, Sections 14 and 18, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15(1) Part II, Section 15 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 15. The requirements Basic Requirement 15, in conjunction with QATR Part II, Section 15, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15 (2) Part II, Sections 15 Note 2 N and 16 Existing QA Programs vs. QATR Comparison Matrix Page 41 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current GA Program QATR Section R/N/o Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) 17.2.15 (3) Part II, Section 16 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 16. The requirements Basic Requirement 16, in conjunction with QATR Part II, Section 16, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15(4) Part II, Section 16 N 17.2.15 (5) Part II, Sections 15 Note 2 N and 16 17.2.15(6) Part II, Section 16 N 17.2.15(7) Part II, Section 18 N 17.2.16(1) Part II, Section 16 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 16. The requirements Basic Requirement 16, in conjunction with QATR Part II, Section 16, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.16 (2) Part II, Section 16 Note 2 N 17.2.16(3) Part II, Section 16 Note 2 N Existing QA Programs vs. QATR Comparison Matrix Page 42 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) 17.2.17 (1) Part II, Section 17 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 17. The requirements Basic Requirement 17, in conjunction with QATR Part II, Section 17, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.17 (2) Part II, Section 1 N 17.2.17 (3) Part II, Section 17.2 N 17.2.17 (4) Part II, Sections 10.1 Note 2 N The proposed QATR includes a and 17 commitment to NQA-1-1994, including Supplement 1OS-1. The requirements Paragraph 9, Supplement 1OS-1, in conjunction with QATR Part II, Sections 10.1 and 17, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.17 (5) Part II, Section 17.2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 17S-1. The requirements of Paragraph 4 of Supplement 17S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 17S-1 are identified in Enclosure 4.

Existing QA Programs vs. QATR Comparison Matrix Page 43 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section R/N/o Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.17 (6) Part II, Section 18 N 17.2.18(1) Part II, Section 18 N 17.2.18 (2) Part II, Section 18.1 N 17.2.18 (3) Part II, Section 18.1 N 17.2.18 (4) Part II, Section 18.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 18S-1. The requirements of Supplement 18S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.18 (5) Part II, Section 2.4 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 2S-3. The requirements of Supplement 2S-3 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-3 are identified in Enclosure 4.

17.2.18 (6) Part II, Section 18.2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 18S-1. The requirements of Supplement 18S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 44 of 85 Section 2 Edwin I. Hatch Nuclear Plant Current QA Program QATR Section Description Section/ (paragraph) Differences Basis for Acceptability (paragraph) 17.2.18.1 (1) Part II, Section 18.1 17.2.18.1 (2) Part II, Section 18.1 Supplement 17.2 A Appendix G Table 17.2-1 Appendix E Note 2 Table 17.2-2 This table is identified in the FSAR as historical information. The table will be retained as-is and a reference to Table 17.2-2 will be incorporated in Section 17.2.

Table 17.2A-1 10 CFR 72.212 Relocated to Hatch 10 CFR 72.212 report Report for ISFSI NOTES:

1. R = Reduction in Commitment N = Not a reduction in Commitment I = Increase in Commitment

2. Wording in the QATR establishes equivalent requirements or commitments, even though there may be a reduction in the level of detail.

3. The QATR describes the standard organization for SNC. The wording is different from that of the existing FSAR, but the structure is the same.

4. The commitment previously included is not required to meet 10 CFR 50, Appendix B, or other quality assurance standards.

Existing QA Programs vs. QATR Comparison Matrix Page 45 of 85 Section 3 Vogtle Electric Generating Plant

Reference:

FSAR 17.2 - Operations Quality Assurance Program, Revision 13, dated January 31, 2006 Current QA Program QATR Section Description Section/ (paragraph) Differences R/N/o1)

(Note Basis for Acceptability (paragraph) 17.2(1) Part I, Section 1 and N Policy Statement 17.2 (2) Part I, Section I CNO now approves QATR 1.2.1.1.1 17.2 (2A) Part I, Section 1.2 N 17.2 (2B) Part I, Section 1; Part N II, Section 5 17.2 (2C) Part I, Section 1.1 N 17.2 (2D) NQA-1-1994 Basic N The proposed QATR includes a Requirement 2; Part commitment to NQA-1-1994, including II, Sections 2.1 and Basic Requirement 2. The requirements of 11 Basic Requirement 2, in conjunction with those contained in QATR Part II, Sections 2.1 and 11, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2 (2E) Part II, Section 11 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 2. The requirements of Basic Requirement 2, in conjunction with those contained in QATR Part II, Section 11, are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 46 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) program description.

17.2 (2F) Part II, Section 10 N 17.2 (2G) Part II, Section 2.3 N 17.2 (2H) Part II, Section 2; and N The proposed QATR includes a Appendix B commitment to NQA-1 -1994, including Basic Requirements 2 and 18. The requirements of Basic Requirements 2 and 18, in conjunction with those contained in QATR Part II, Section 2, and QATR Appendix B, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2 (3) Part I, Section 1; and N SNC does not commit to Regulatory Guide Part III (Regulatory 1.33/N18.7-1976, but meets the Guide 1.33) requirements Regulatory Guide 1.33/N1 8.7-1976, as described in the QATR.

17.2 (4) Part II, Section 1 N 17.2.1 Part II, Section 1 N Describes the new organization structure for 17.2.1.1 New Standard SNC without decreasing commitments.

Organization 17.2.1.4 Description 17.2.1.5 17.2.1.6 Existing QA Programs vs. QATR Comparison Matrix Page 47 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/Nol Basis for Acceptability (paragraph) 17.2.1.1.1 Appendix B N 17.2.1.2 Part II, Section 1 N New Standard Organization Description 17.2.1.2.1 Appendix A N 17.2.1.3 Part II, Section 1 No longer identifies the specific R Staff size will be adjusted as needed to 17.2.1.3.1 New Standard number of QA personnel at the site ensure audits and other quality assurance Organization activities are conducted as committed in the 17.2.1.3.2 Description, Section QATR 17.2.1.3.3 2, Appendix C 17.2.2 (1) Part II, Section 2 N 17.2.2 (2) Part I, Section 1.1 N 17.2.2 (3) Part II, Sections 2 N The proposed QATR includes a and 5 commitment to NQA-1 -1994, including Basic Requirement 2. The requirements of Basic Requirement 2, in conjunction with those contained in QATR Part II, Sections 2 and 5, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.2 (4) Part I, Section 1.2 N SNC does not commit to Regulatory Guide 1.33/N18.7-1976, but meets the requirements of these standards as Existing QA Programs vs. QATR Comparison Matrix Page 48 of 85 Section 3 Vogtle Electric Generating Plant Current GA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) described in the QATR.

17.2.2 (5) Part II, Section 2.1 N 17.2.2 (6) Part II, Sections N 1.2.1.1.1 and 18 17.2.2 (7) Part II, Sections 2.3 N The proposed QATR includes a and 2.4 commitment to NQA-1-1994, including Supplement 2S-4. The requirements of Supplement 2S-4, in conjunction with those contained in QATR Part II, Sections 2.3 and 2.4, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.2 (8) Part II, Section 2.4 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 2S-3. The requirements of Supplement 2S-3 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-3 are identified in Enclosure 4.

17.2.2 (9) Part II, Section 2.4 N The proposed QATR includes a commitment to NQA-1-1994, including Supplements 2S-3 and 2S-4. The requirements of Supplements 2S-3 and 2S-4 are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 49 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/NoI Description Section/ Differences Basis for Acceptability (paragraph) program description.

Exceptions to Supplement 2S-3 are identified in Enclosure 4.

17.2.2 (10) Part I, Section 1.4 N 17.2.2(11) Part I, Section 1.4, N and Part II, Section 18 17.2.3 (1) Part II, Section 3 N 17.2.3 (2) Part II, Section 3; N Appendices A and B 17.2.3 (3) Part II, Sections 3.1 N The proposed QATR includes a and 3.3 commitment to NQA-1 -1994, including Basic Requirement 3 and Supplement 3S-1.

The requirements of Basic Requirement 3 and Supplement 3S-1, Paragraph 5, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (4) Part II, Section 3; N The proposed QATR includes a NQA-1-1994 commitment to NQA-1-1994, including Basic Requirement 3 and Supplement 3S-1.

The requirements of Basic Requirement 3 and Supplement 3S-1, Paragraphs 3 and 5, are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 50 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) program description.

17.2.3 (5) Part II, Section 5.1 N 17.2.3 (5A) Part II, Section 3.3 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 2, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (5B) Part II, Section 3.3 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (5C) Part II, Sections 3.2 N The proposed QATR includes a and 3.3 commitment to NQA-1-1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 3, in conjunction with QATR Part II, Sections 3.2 and 3.3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (5D) Part II, Section 7.2 N The proposed QATR includes a commitment to NQA-1-1994, including Existing QA Programs vs. QATR Comparison Matrix Page 51 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences R/NoI Basis for Acceptability (paragraph)

Supplement 7S-1. The requirements of Supplement 7S-1, Paragraph 10(a), are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.3 (5E) Part II, Section 5 N 17.2.3 (5F) Part II, Section 3.3 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 6, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (5G) Part II, Section 3.3 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 3.1(a), are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (6) Intentionally deleted I Removing this wording reduces the limitation to the specific areas to which design controls apply.

Existing QA Programs vs. QATR Comparison Matrix Page 52 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences R/Nol Basis for Acceptability (paragraph) 17.2.3 (7) Part II,Sections 3.1 N The proposed QATR includes a and 3.3 commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 4, in conjunction with those contained in QATR Part II, Sections 3.1 and 3.3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (7A) Part II,Sections 3.1 N The proposed QATR includes a and 3.3 commitment to NQA-1 -1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 4, in conjunction with those contained in QATR Part II, Sections 3.1 and 3.3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (7B) Part II,Section 3 N Less detail, same intent 17.2.3 (7C) Part II,Sections 3.1, N The proposed QATR includes a (Paragraph 3) and commitment to NQA-1-1994, including 3.3 Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 4.2.3, in conjunction with those contained in QATR Part II,Sections 3.1 and 3.3, are equivalent to those contained in the specified

_paragraph of the current QA program Existing QA Programs vs. QATR Comparison Matrix Page 53 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/N/I Description Section/ Differences Basis for Acceptability (paragraph) description.

17.2.3 (7D) Part II, Section 3 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraphs 4.2.1 and 4.2.3, in conjunction with those contained in QATR Part II, Section 3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (7E) Part II, Section 3.1, N Paragraph 3 17.2.3 (7F) Part II, Sections 3.1 N The proposed QATR includes a and 3.3 commitment to NQA-1-1 994, including Supplement 3S-1. The requirements of Supplement 3S-1, Paragraph 4.2, in conjunction with those contained in QATR Part II, Sections 3.1 and 3.3, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (7G) Part II, Section 3.1, N Paragraph 4 17.2.3 (8) Part II, Section 18 N 17.2.3 (9) Part II, Section 16.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Existing QA Programs vs. QATR Comparison Matrix Page 54 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/NoI Description Section/ Differences Basis for Acceptability (paragraph)

Basic Requirement 16. The requirements of Basic Requirement 16 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3 (10) Part II, Section 6 N The proposed QATR includes a commitment to NQA-1-1994, including Basic Requirement 6. The requirements of Basic Requirement 6, in conjunction with those contained in QATR Part II, Section 6, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.3(11) Part II, Sections 2.3 N and 6 17.2.3 (12) Part II, Section 18 N 17.2.4 (1) Part II, Sections 4 N The proposed QATR includes a and 7 commitment to NQA-1 -1994, including Basic Requirements 4 and 7, and Supplements 4S-1 and 7S-1. These requirements are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 4S-1 and 7S-1 are identified in Enclosure 4.

17.2.4 (2) Intentionally not N Information only - not a commitment Existing QA Programs vs. QATR Comparison Matrix Page 55 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences R/N/I Basis for Acceptability (paragraph) included 17.2.4 (2A) Part II, Sections 1,4, N and 5 17.2.4 (2B) Part II, Section 2.4 N The proposed QATR includes a and 4.2 commitment to NQA-1-1994, including Supplements 2S-4 and 4S-1. Supplement 2S-4 and Paragraph 3 of Supplement 4S-1 provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4 (2C) Part II, Section 4.1 Does not require reviewer to be R Although NQA-1994 does not require and 4.2 independent of originator Independent review of procurement documents, NQA-1 -1994, Supplement 4S-1, Paragraph 3, has been found acceptable by the NRC as the basis for a QAP required to meet 10 CFR 50, Appendix B. Section 4.2 of the proposed QATR includes a commitment to NQA-1 -1994, Supplement 4S-1 with the exceptions identified in Enclosure 4. Elimination of the independent review requirement has been previously approved by the NRC for the Dominion Nuclear Facility Quality Assurance Program Description (NFQAPD) as documented by NRC SER dated September 9, 2005.

Existing QA Programs vs. QATR Comparison Matrix Page 56 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.4 (2D) Part I, Sections 1 and The QATR does not require QA R Note 4: NQA-1-1994 has been determined 1.2; Part II, Sections Manager review of supplier QA by the NRC to provide an acceptable basis 1, 1.2.1.1.1.2, and programs. for a QAP required to meet 10 CFR 50, 7.1 Appendix B. NQA-1-1994 does not require QA Manager review of supplier QA programs documents. Accordingly, the QATR does not require the QA Manager to review supplier QA programs.

17.2.4 (2E) Part II, Section 4.2 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 4S-1. Paragraph 2.2 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4 (2F) Part II, Section 4.2 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 4S-1. Paragraph 2.5 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

Existing QA Programs vs. QATR Comparison Matrix Page 57 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/N/I Basis for Acceptability (paragraph) 17.2.4 (2G) Part II, Section 4.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 4S-1. Paragraph 2.5 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4 (2H) Part II, Section 4.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 4S-1. Paragraph 2.4 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4 (21) Part II, Section 4.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 4S-1. Paragraph 4 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are Existing QA Programs vs. QATR Comparison Matrix Page 58 of 85 Section 3 Vogtle Electric Generating Plant Current GA Program QATR Section R/NoI Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) identified in Enclosure 4.

17.2.4 (2J) Part II, Section 4.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 4S-1. Paragraph 3 of Supplement 4S-1 includes requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.4 (3) Part II, Section 18 N 17.2.5 Part II, Section 5 and N The proposed QATR includes a Part III (Regulatory commitment to NQA-1 -1994, including Guide 1.33) Basic Requirement 5. Basic Requirement 5, in conjunction with QATR Section II, Part 5, and QATR Part III (Regulatory Guide 1.33) provides requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.5.1 (1) 1 st sentence is INFO N only; 2 nd sentence is Appendix A; and Part II, Sections 6 and 6.1 17.2.5.1 (2) Appendix E and Part N II, Section 5 (3 rd Existing QA Programs vs. QATR Comparison Matrix Page 59 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences RDNor Basis for Acceptability (paragraph) sentence) 17.2.5.1 (3) Part II, Section 3.2 N 17.2.5.1 (4) Not included - info N only 17.2.5.1.1 Appendix E N Not a commitment (as written) 17.2.5.1.1 (A) Part II, Section 5.2; N Part III (Regulatory Guide 1.33) 17.2.5.1.1 (B) Appendix E N 17.2.5.1.1 (C) Appendix E N 17.2.5.1.1 (D) Appendix E N 17.2.5.1.1 (E) Appendix E N 17.2.5.1.1 (F) Appendix E N 17.2.5.1.1 (G) Appendix E N 17.2.5.1.1 (H) Intentionally not N TSIP is complete - requirement is no longer included needed 17.2.5.1.1 (I) Intentionally not N The commitment to have procedures for the included subject programs is contained in the plant Technical Specifications. Accordingly, there is no need to list the specific programs in Existing QA Programs vs. QATR Comparison Matrix Page 60 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) the QATR Appendix E.

17.2.5.1.2 Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (1) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (2) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (3) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (4) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (5) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (6) Part II, Section 6 R Note 4: Procedures will continue to be reviewed and approved by authorized personnel.

17.2.5.1.2 (7) Appendix A N This refers to the standalone sentence at Existing QA Programs vs. QATR Comparison Matrix Page 61 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section 1)N/I Description Section/ (paragraph) Differences (Note 1) Basis for Acceptability (paragraph) the end of Section 17.2.5.1.2 17.2.5.1.2.1 Part II, Section 6 Note 2 N 17.2.5.1.3 Part II, Sections 5 Note 2 N and 6.1; and Appendix E 17.2.5.2 (1) Part I, Section 1.2 N 17.2.5.2.(2) Part II, Sections 7 N and 18 17.2.6 Part II, Section 6 Note 2 N 17.2.6 (A) Part II, Section 5.2 Note 2 N 17.2.6 (B) Part II, Section 6 Note 2 N 17.2.6 (C) Part II, Section 6 Note 2 N 17.2.6 (D) Part II, Section 6 Note 2 N 17.2.6 (E) Part II, Section 6 Note 2 N 17.2.6 (F) Part II, Section 6 Note 2 N 17.2.6 (G) Part II, Section 6 Note 2 N 17.2.6 (H) Part II, Section 6 Note 2 N 17.2:6 (I) Part II, Section 6 Note 2 N Existing QA Programs vs. QATR Comparison Matrix Page 62 of 85 Section 3 Vogtle Electric Generating Plant Current OA Program QATR Section Description Section/ Differences R/N/o Basis for Acceptability (paragraph) 17.2.6 (J) Part II, Section 6 Note 2 N 17.2.6 (K) Part II, Section 6 Note 2 N 17.2.6 (2) Part II, Section 6 Note 2 N Requirements of Regulatory Guide 1.33 are replaced by the QATR and NQA-1 -1994 17.2.6 (2A) Part II, Sections 5.2 R Note 4

&6, and Part I, Section 1.4 17.2.6 (2B) Part II, Section 6 ( 1 st Note 2 N The proposed QATR includes a Sentence) commitment to NQA-1-1994, including Supplement 6S-1. Paragraph 1 of Supplement 6S-1, in conjunction with QATR Part II, Section 6, provide requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.6 (2C) Part II, Section 6.1 N (1 st Sentence) 17.2.6 (2D) Part II, Section 6 Note 2 N 17.2.6 (2E) Part II, Section 6 Note 2 N 17.2.6 (3) Part II, Sections 1 N The proposed QATR includes a and 6 commitment to NQA-1 -1994, including Basic Requirement 6. Basic Requirement 6, in conjunction with QATR Part II, Existing QA Programs vs. QATR Comparison Matrix Page 63 of 85 Section 3 Vogtle Electric Generating Plant Current GA Program QATR Section Description Section/ Differences R/Nol Basis for Acceptability (paragraph)

Sections 1 and 6, include requirements that are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.6 (4) Part II, Section 18 N 17.2.7 Part II, Sections 4, 7, N The proposed QATR includes a and 13.2 (Commits to commitment to NQA-1 -1994, including NQA-1-1994, Subpart Basic Requirements 4 and 7, and Subpart 2.2) 2.2. These requirements, in conjunction with QATR Part II, Sections 7, and 13.2 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.7.1 (1) Part II, Section 7.1 N (Bullet 2) 17.2.7.1 (A) Part II, Section 7.2 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraph 8.2 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

Existing QA Programs vs. QATR Comparison Matrix Page 64 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/N/o Basis for Acceptability (paragraph) 17.2.7.1 (B) NQA-1-1994 N The proposed QATR includes a Supplement 7S-1, commitment to NQA-1-1994, including Paragraph 8.2 Supplement 7S-1. The requirements of Paragraph 8.2 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.1 (C) NQA-1-1994 N The proposed QATR includes a Supplement 7S-1, commitment to NQA-1 -1994, including Paragraph 8.2 Supplement 7S-1. The requirements of Paragraph 8.2 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.1 (2) Part II, Section 4.2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 4S-1. The requirements of Paragraph 2.2 of Supplement 4S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are Existing QA Programs vs. QATR Comparison Matrix Page 65 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) identified in Enclosure 4.

17.2.7.1 (2A) NQA-1-1994 N The proposed QATR includes a Supplement 4S-1, commitment to NQA-1-1994, including Paragraph 2.2 Supplement 4S-1. The requirements of Paragraph 2.2 of Supplement 4S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 4S-1 are identified in Enclosure 4.

17.2.7.1 (2B) NQA-1-1994 N The proposed QATR includes a Supplement 7S-1, commitment to NQA-1-1 994, including Paragraph 9 Supplement 7S-1. The requirements of Paragraph 9 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

Existing QA Programs vs. QATR Comparison Matrix Page 66 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program Description Section/ QATR Section (paragraph) Differences (Note R/N/I1) Basis for Acceptability (paragraph) 17.2.7.1 (20) NQA-1-1994 N The proposed QATR includes a Supplement 7S-1, commitment to NQA-1-1994, including Paragraph 9 Supplement 7S-1. The requirements of Paragraph 9 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.2 (1) Part II, Section 5, 6, Note 2 N The proposed QATR includes a and 7.2 commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Paragraphs 3.1 and 5 of Supplement 7S-1 in conjunction with QATR Part II, Sections 5, 6, and 7.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.2 (A) Part II, Section 5 and Note 2 N The proposed QATR includes a 7.2 commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraphs 3.1, 5, and 8.2.2 of Supplement 7S-1, in conjunction with QATR Part II, Sections 5 and 7.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 67 of 85 Section 3 Vogtle Electric Generating Plant Current 0A Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph)

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.2 (B) Part II, Section 5 and R Note 4 7.2 17.2.7.3 (A) Part II, Sections 2.4 N The proposed QATR includes a and 7.2 commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraph 8 of Supplement 7S-1, in conjunction with QATR Part II, Sections 2.4 and 7.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (B) Part II, Section 7.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Paragraph 8 of Supplement 7S-1, in conjunction with QATR Part II, Section 7.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (C) Part II, Section 7.2 N The proposed QATR includes a commitment to NQA-1 -1994, including Existing QA Programs vs. QATR Comparison Matrix Page 68 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences R/eNo Basis for Acceptability (paragraph)

Supplement 7S-1. The requirements of Paragraph 8 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (D) Part II, Section 7.2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement 7S-1. The requirements of Paragraph 8.3 of Supplement 7S-1 are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (2) Part II, Section 8.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 8. The requirements of Basic Requirement 8 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.7.3 (3) Part II, Section 15 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 15S-1. The requirements of Supplement 15S-1, in conjunction with those contained in QATR Part II, Section Existing QA Programs vs. QATR Comparison Matrix Page 69 of 85 Section 3 Vogtle Electric Generating Plant Current OA Program QATR Section Description Section/ (paragraph) Differences R/N/o Basis for Acceptability (paragraph) 15, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.7.3 (4) Part II, Sections 7.1 N The proposed QATR includes a and 7.2 commitment to NQA-1 -1994, including Supplement 7S-1. The requirements of Paragraph 10 of Supplement 7S-1, in conjunction with those contained in QATR Part II, Sections 7.1 and 7.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.7.3 (5) Part II, Section 18 N 17.2.8 (1) Part II, Section 8 N 17.2.8 (2) Part II, Sections 8 Note 2 N The proposed QATR includes a and 15 commitment to NQA-1-1994, including Basic Requirement 8 and Supplement 8S-1.

The requirements of Basic Requirement 8 and Paragraph 2.3 of Supplement 8S-1, in conjunction with those contained in QATR Part II, Sections 8 and 15, are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 70 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/eNo Basis for Acceptability (paragraph) 17.2.8 (3A) Part II, Sections 5 Note 2 N The proposed QATR includes a and 8 commitment to NQA-1 -1994, including Basic Requirement 8. The requirements of Basic Requirement 8, in conjunction with those contained in QATR Part II, Sections 5 and 8, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.8 (3B) Part II, Sections 5, Note 2 N The proposed QATR includes a 7.2, and 8 commitment to NQA-1-1 994, including Supplement 7S-1. The requirements of Paragraph 8.2.3 of Supplement 7S-1, in conjunction with those contained in QATR Part II, Sections 5, 7.2, and 8, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 7S-1 are identified in Enclosure 4.

17.2.8 (4) Part II, Section 1,5, Note 2 N and 7; Part III (Regulatory Guide 1.28 exception) 17.2.8 (5) Part II, Section 18 N 17.2.9(1) Part II, Sections 10.1, N The proposed QATR includes a 12.1, and 13.2 commitment to NQA-1-1994, including Existing QA Programs vs. QATR Comparison Matrix Page 71 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/N/I1)

(Note Basis for Acceptability (paragraph)

Supplement 2S-1 and Subparts 2.1 and 2.4.

The requirements, in conjunction with those contained in QATR Part II, Sections 10.1 and 13.2, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-1 and Subparts 2.1 and 2.4 are identified in Enclosure 4.

17.2.9 (2) Part II, Section 9 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 9S-1. The requirements of Paragraph 3.3 of Supplement 9S-1, in conjunction with those contained in QATR Part II, Section 9, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.9 (3) Part II, Sections 1, 5, N The proposed QATR includes a 7, and 9 commitment to NQA-1-1994, including Basic Requirement 9 and Supplement 9S-1.

These requirements, in conjunction with those contained in QATR Part II, Sections 1, 5, 7, and 9, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.9(4) Part II, Section 18 N Existing QA Programs vs. QATR Comparison Matrix Page 72 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/eNo Basis for Acceptability (paragraph) 17.2.10 (1) Part II, Sections 2.4, N The proposed QATR includes a 10.1, and 12.1 commitment to NQA-1 -1994, including Supplement 2S-1 and Subparts 2.4 and 2.8.

These requirements, in conjunction with those contained in QATR Part II, Sections 10.1 and 2.4, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 2S-1 and Subpart 2.4 are identified in Enclosure 4.

17.2.10 (2) Part II, Section 10 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraph 5.2 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Section 10, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (3) Part II, Section 10.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraphs 6.2 and 6.2.1 of Supplement 1oS-1 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10(4) Part II, Section 10 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Existing QA Programs vs. QATR Comparison Matrix Page 73 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/Nol Basis for Acceptability (paragraph)

Basic Requirement 10 and Supplement 1oS-1. The requirements of Basic Requirement 10 and Paragraphs 3 and 6.1 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Section 10, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (5) Part II, Sections 5 R Note 4 and 10.1 17.2.10 (6) Part II, Sections 5, N The proposed QATR includes a 10.1, and 12 commitment to NQA-1-1994, including Supplement 1OS-1. The requirements of Paragraph 8.2 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Sections 5, 10.1, and 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (7) Part II, Sections 10.1 Note 2 N The proposed QATR includes a and 16 commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraph 4 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Section 10.1 and 16, are equivalent to those contained in the specified paragraph of the current QA program Existing QA Programs vs. QATR Comparison Matrix Page 74 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences RDNor Basis for Acceptability (paragraph) description.

17.2.10 (8) Part II, Sections 5, 6, Note 2 N The proposed QATR includes a and 10.1 commitment to NQA-1 -1994, including Supplement 1OS-1. The requirements of Paragraph 4 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Sections 5, 6, and 10.1, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.10 (9) Part II, Section 1, 15 N

& 16 17.2.10 (10) Part II, Section 1 R Note 4 17.2.10 (11) Part II, Section N 1.2.2.1.2.1 17.2.10 (12) Part II, Sections 2.4 Note 2 N The proposed QATR includes a and 10.1, Part III commitment to NQA-1-1994, including (Regulatory Guide Supplements 2S-1 and 1OS-1. The 1.28) requirements of Paragraphs 2.1 and 2.7 of Supplement 2S-1 and Paragraph 3.2 of Supplement 1OS-1, in conjunction with those contained in QATR Part II, Sections 2.4 and 10.1, and QATR Part III (Regulatory Guide 1.28), are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 75 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/Nol Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph)

Exceptions to Supplements 2S-1 are identified in Enclosure 4.

17.2.10 (13) Part II, Section 18 N 17.2.11 (1) Part II, Sections 2.4, Note 2 N The proposed QATR includes a 5, 6, & 10.1, 11; and commitment to NQA-1 -1994, including 12.1 Supplements 2S-1 and Subparts 2.4 and FSAR Chapter 8 2.8. These requirements, in conjunction (Regulatory Guides with those contained in FSAR Chapter 8 1.108 & 1.118) associated with Regulatory Guides 1.108 and 1.118, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplements 2S-1 are identified in Enclosure 4.

17.2.11 (1A) Part II, Section 4 & 5 Note 2 N 17.2.11 (1B) Part II, Section 5 & Note 2 N 11 17.2.11 (1C) Part II, Section 5 & Note 2 N 11 17.2.11 (2) Part II, Sections 6.2 N The proposed QATR includes a and 11.1 commitment to NQA-1 -1994, including Supplements 6S-1 and 11S-1. The requirements of Paragraphs 3.1 of Supplement 6S-1, and Paragraph 5 of Supplement 11S-1, in conjunction with Existing QA Programs vs. QATR Comparison Matrix Page 76 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) those contained in QATR Part II, Sections 6.2 and 11.1, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (3) Part II, Sections 7 Note 2 N The proposed QATR includes a and 11.1 commitment to NQA-1 -1994, including SupplementI1S-1. The requirements of Paragraphs 4 and 5 of Supplement 11S-1, in conjunction with those contained in QATR Part II, Sections 7 and 11.1, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.11 (4) Part II, Section 18 N 17.2.12(1) Part II, Section 12 N 17.2.12 (2A) Part II, Section 12 (2) Note 2 N 17.2.12 (2B) Part II, Section 12 (3) N (Bullet 2) 17.2.12 (2C) Part II, Section 12 (3) N (Bullet 1) 17.2.12 (2D) Part II, Section 12 (3) N The proposed QATR includes a (bullet 1) commitment to NQA-1-1994, including Supplement1 2S-1. The requirements of Paragraph 2.1 of Supplement 12S-1, in Existing QA Programs vs. QATR Comparison Matrix Page 77 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences R/N/o Basis for Acceptability (paragraph) conjunction with those contained in QATR Part II, Section 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (2E) Part II, Sections 5 & N The proposed QATR includes a 12 (3) (Bullet 5) commitment to NQA-1 -1994, including Supplementl2S-1. The requirements of Paragraph 3.1 of Supplement 12S-1, in conjunction with those contained in QATR Part II, Sections 5 and 12, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (2F) Part II, Section 12 (3) Note 2 N The proposed QATR includes a (bullets 3 & 4) commitment to NQA-1-1994, including Supplement1 2S-1. The requirements of Paragraph 3.1 of Supplement 12S-1, in conjunction with those contained in QATR Part II, Section 12, are equivalent to those contained in the specified paragraph of the current QA program description.

Existing QA Programs vs. QATR Comparison Matrix Page 78 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/NoI Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.12 (2G) Part II, Section 12.1; N The proposed QATR includes a NQA-1-1994 commitment to NQA-1 -1994, including Supplementl2S-1. The requirements of Paragraph 5 of Supplement 12S-1, in conjunction with those contained in QATR Part II, Section 12.1, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.12 (2H) Part II, Section 12.1 N The proposed QATR includes a commitment to NQA-1 -1994, including Subpart 2.16. The requirements of Subpart 2.16 include IEEE 498-1985. The requirements of Paragraph 5.2 of IEEE 498-1985 are equivalent to those contained in the contained in the specified paragraph of the current QA program description.

17.2.12 (3) Part II, Section 12 (3) Note 2 N (Bullets 3 & 4) 17.2.12 (4) Part II, Section 5; Note 2 N The level of detail for the organization is Appendix A less in the QATR. This was intentional.

17.2.12 (5) Part II, Section 18 N 17.2.13(1) Part II, Sections 13 N and 13.2 17.2.13 (1A) Part II, Sections 7.1 N and 13.2 (Subpart Existing QA Programs vs. QATR Comparison Matrix Page 79 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph)Differences Basis for Acceptability (paragraph) 2.2, Paragraph 6.4.1) 17.2.13 (11B) Part II, Sections 2.3 Note 2 The proposed QATR includes a and 13.2 commitment to NQA-1-1994, including Supplement 13S-1. The requirements of Paragraphs 3.2 and 3.4 of Supplement 13S-1, in conjunction with those contained in QATR Part II, Sections 2.3 and 13.2, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.13 (1C) Part II, Section 13.2 The proposed QATR includes a commitment to NQA-1 -1994, including Supplement 13S-1. The requirements of Paragraph 3.3 of Supplement 13S-1, in conjunction with those contained in QATR Part II, Section 13.2, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.13 (2) Part II, Section 18 17.2.14 (1) Part II, Section 14 17.2.14 (2) Intro to section: info only 17.2.14 (2A) Part II, Section 14 Note 2 17.2.14 (2B) Part II, Section 14 Note 2 Existing QA Programs vs. QATR Comparison Matrix Page 80 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ Differences RDsN/ Basis for Acceptability (paragraph) 17.2.14 (2C) Part II,Section 14 Note 2 N 17.2.14 (2D) Part II,Sections 14.1 N The proposed QATR includes a and 15 commitment to NQA-1 -1994, including Basic Requirement 14. The requirements of Basic Requirement 14, in conjunction with those contained in QATR Part II, Sections 14.1 and 15, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.14 (3) Part I, Sections 1.2, N 2.3, and 15 17.2.14 (4) Part II,Section 18 N 17.2.15 (1) NQA-1-1994, Subpart N The proposed QATR includes a 2.2; Part II,Sections commitment to NQA-1 -1994, including 4, 7, 13.2, 15, & 16; Basic Requirement 15 and Subpart 2.2.

NQA-1-1994, Basic These requirements, in conjunction with Requirement 15 those contained in QATR Part II, Sections 4, 7, 13.2, 15, and 16, are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Subpart 2.2 are identified in Enclosure 4.

17.2.15 (1A) Part II, Section 15 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Supplementi15S-1. The requirements of Existing QA Programs vs. QATR Comparison Matrix PaLe 81 of 85 Section 3 Vogtle Electric Generating Plant Current GA Program QATR Section R/N/o Description Section/ Differences Basis for Acceptability (paragraph) (paragraph)

Supplement 15S-1, in conjunction with those contained in QATR Part II, Section 15, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15 (1B) Part II, Sections 15 Note 2 N and 16 17.2.15 (1C) Part II, Sections 11, R Note 4 15, and 16 17.2.15 (1 D) Part II, Section 16 Note 2 N and Appendix A 17.2.15 (1 E) Part II, Section 7 and N The proposed QATR includes a 15 commitment to NQA-1 -1994, including Supplement15S-1. The requirements of Paragraphs 4.4 and 4.5 of Supplement 15S-1, in conjunction with those contained in QATR Part II, Sections 7 and 15 are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15 (1 F) Part II, Section 15.1 Note 2 N The proposed QATR includes a commitment to NQA-1-1994, including Supplement15S-1. The requirements of Paragraph 3 of Supplement 15S-1 are equivalent to those contained in the specified paragraph of the current QA Existing QA Programs vs. QATR Comparison Matrix Page 82 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section Description Section/ (paragraph) Differences R/N/o Basis for Acceptability (paragraph) program description.

17.2.15 (1G) Part II, Section 15 Note 2 N The proposed QATR includes a and 16 commitment to NQA-1 -1994, including Supplementl5S-1. The requirements of Paragraph 4.4 of Supplement 15S-1, in conjunction with those contained in QATR Part II, Sections 15 and 16, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.15 (1H) Part II, Sections 15 Note 2 N and 16 17.2.15 (11) Part II, Section 15 N 17.2.15 (2) Part II, Section 18 R Note 4 17.2.16 (1) Part II, Section 16 N 17.2.16 (2) Part II, Section 16 Note 2 N The proposed QATR includes a commitment to NQA-1 -1994, including Basic Requirement 16. The requirements of Basic Requirement 16, in conjunction with those contained in QATR Part II, Section 16, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.16 (3) Part II, Section 16 Note 2 N This is a best practice - not a QA program Existing QA Programs vs. QATR Comparison Matrix Page 83 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/Nol Description Section/ Differences Basis for Acceptability (paragraph) (paragraph) requirement 17.2.16(4) Part II, Section 1 Note 2 N 17.2.16 (5) Part II, Section 1 R Note 4 17.2.16 (6) Part II, Sections 1 R Note 4 and 16 17.2.16(7) Part II, Sections 16, N 18; Appendix A 17.2.17(1) Part II, Sections 17 & Note 2 N The proposed QATR includes a 17.1 commitment to NQA-1-1994, including Basic Requirement 17. The requirements of Basic Requirement 17, in conjunction with those contained in QATR Part II, Sections 17 and 17.1, are equivalent to those contained in the specified paragraph of the current QA program description.

17.2.17 (2) Part II, Sections 1 & 6 Note 2 N 17.2.17 (3) Part II, Section 17.2 N 17.2.17 (4) Part II, Sections 1 & 6 Note 2 N 17.2.17 (5) Part II, Section 17.2; N The proposed QATR includes a Part Ill, Regulatory commitment to NQA-1 -1994, including Basic Requirement 17 and Supplement Existing QA Programs vs. QATR Comparison Matrix Page 84 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section R/N/1 Description Section/ (paragraph) Differences Basis for Acceptability (paragraph)

Guide 1.33 17S-1. The requirements of Basic Requirement 17 and Supplement 17S-1, in conjunction with those contained in QATR Part III (Regulatory Guide 1.33), are equivalent to those contained in the specified paragraph of the current QA program description.

Exceptions to Supplement 17S-1 are identified in Enclosure 4.

17.2.17 (6) Part II, Section 18 N 17.2.17 (7) Info only N 17.2.17.1 Moved to FSAR RN Rdurti,,n in GA pr^gram, but not a*chang.

Chapter 13 inR enrGeo ba~iS commitment. . Part 1 Section 17, of the proposed QATR states "Additional operations phase records and their retention periods are identified in the respective FSAR for each plant." The list of operations phase records and their retention period proposed to be moved from Section 17.2 to Chapter 13 of the Vocqtle FSAR are incorporated into the Voctle QA program by reference. Accordingly, chanqes to the list of operations records or their retention period will be subiect to the provisions of 10 CFR 50.54(a).

Existing QA Programs vs. QATR Comparison Matrix Page 85 of 85 Section 3 Vogtle Electric Generating Plant Current QA Program QATR Section RDNor Description Section/ (paragraph) Differences NBasis for Acceptability (paragraph) 17.2.18 Part II, Sections 13.2, Replaced FSAR Section 17.2.18 by N The proposed QATR includes a 18, and 18.1 standard language in QATR Part II, commitment to NQA-1-1994, including Sections 18 and 18.1, and NQA Basic Requirement 18 and Supplements 1994, Basic Requirement 18 2S-3 and 18S-1. These requirements, in FSAR Section 17.2.18(H) is conjunction with those contained in QATR replaced by NQA- 1-1994, Part II, Sections 13.2, 18, and 18.1, are Supplement 2S-3 and Supplement equivalent to those contained in the 18S-1, Paragraph 3.2. specified paragraph of the current QA program description.

Exceptions to Supplement 2S-3 are identified in Enclosure 4.

17.2.19 Part II, Section 18.1; N Replaced by Appendix C NOTES:

1. R = Reduction in Commitment N = Not a reduction in Commitment I = Increase in Commitment

2. Wording in the QATR establishes equivalent requirements or commitments, even though there may be a reduction in the level of detail.

3. The QATR describes the standard organization for SNC. The wording is different from that of the existing FSAR, but the structure is the same.

4. The commitment previously included is not required to meet 10 CFR 50, Appendix B, or other quality assurance standards.

Enclosure 4 Southern Nuclear Operating Company Quality Assurance Topical Report ASME NQA- 1-1994 Conformance Matrix NQA- 1-1994 Conformance Matrix Page 1 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (YIN) S_ ________

Part I - Basic Requirements and Supplementary Requirements for Nuclear Facilities (from former NQA-1)

Section I - Introduction 1 Purpose N Part I, The SNC QATR applies to operations phase activities, § 50.54(a)(3)(i)

Section 1 including design and construction activities similar in scope to original construction activities (e.g., ISFSI, steam generator mausoleum, etc.), consistent with the Exelon QATR and scope of NUREG-0800 Standard Review Plan, Section corresponding NRC SER dated 17.2. December 24, 2002 The NRC has approved use of NQA-1-1994, as NMC QATR and corresponding supplemented by ANSI Ni18.7-1976, as an acceptable NRC SER dated March 24, 2005 basis for a quality assurance program required to meet Dominion QATR and 10 CFR 50, Appendix B. The proposed QATR is corresponding NRC SER dated generally consistent with quality assurance topical September 9, 2005 reports previously submitted by Exelon, NMC, and Dominion and approved by the NRC.

2 Applicability N Part I SNC commits to compliance with NQA-1-1994 and as § 50.54(a)(3)(iv)

Section 1.1 such, the applicability requirements in Part I,Section I, Paragraph 2 are incorporated by reference and are not repeated in the QATR.

In addition, Part I,Section I, Paragraph 2, of NQA 1994 requires, "The application of this Part (Part I) or portions thereof, shall be specified in written contracts, policies, procedures, or instructions." This requirement is addressed in SNC QATR Part II, Section 4.2.

3 Responsibility N Part I, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Section 1.2 Section I, Paragraph 3 NQA 1994 Conformance Matrix Page 2 of 50 NQA-1-1994, Quality Assurance Reduction in T ATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 4 Terms and Definitions N Part 1, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Section 1.4 Section I, Paragraph 4, with the following clarifications:

"lairficatin" of the trmf As stated in Part I, Section 1.4 of the SNC QATR, SNC "Yerificatien" does not reflect a utilizes the terms and definitions provided in Part I, rdptvmp* in iran rag .H I

irnfnt P *a V ~ý1"'

4llL Section 1.4, of NQA-1-1994 to interpret the -SJKIfA -4 v* o requirements of NQA-1 -1994, Part I, as well as other provi!dec clarification of standards to which SNC is committed to in the QATR. IniormaPItrionAI conta'tneef~f tnrain.lf Additional terms and definitions not contained in NQA-1-1994 are provided in Appendix D of the SNC QATR.

The ;additional termn and definit!on cntained in Appendil D of the SNl QATR are idntinal to tho-se contained in Appendix Gofý th NMC QATR, with the addition Of the folloWing@ clar-ification -ofthe NQA 1 1994 defined term ",-erficaton:

Gaon-urra-nt14enficatian Verification by a second iniiulOf a component'9s con-ditin -ASthO action i being performed. Examples include, but are not limited to, equipment being removed from erGVice (proVided the eq*i*p*ment b*ein removed from se.vice will not cause any adverse sstem condition), lifting a lead, ramovinoaR une. and onenina a link.

hnnn~nt~Iifn-+.'n ~ar#..,a. k.+ A.,,

actionAs havea been completed by an idiual ther than the Person who perfOrmFed tho operation Or actviy being Verified. Such Verific-at1ion Will no-t require cenfirm.ation of the identi"a.l action

- ,:hen other indications provide assr.Uance or.indication that the prescribod actiVty *is*in fact complete. ExamAple inclUde, but are not limited to, vergifiation Of Abreaker opening by obsW4*ing rFeMtae brakelr indication lightsm of a setpoint (mad..e. with a-voltmetero

.ifi.at.on ammeter I !Fo E)XaMn'n' bv' ObeV thO A,.n"AtnO Of

_ __ _ _ _ _ _ _ _ I__ _ _ _ _ _ I _ _ I__Gi U OFIG ~ Ig1g I F 11 @ UFGP R IFO NQA- 1-1994 Conformance Matrix Page 3 of 50 NQA-1 -1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) ind~atodva8u; VeF~ficat*Gon that A WAWv harc bonA positioned by obcor:ing the starting or stopping of flo o~n moto~r iricatonc. or bO rbry Fh alV*G poitiAn Section Il - Basic and Supplementary Requirements Basic Requirement I - N Part II, The SNC QATR is consistent with NQA-1-1 994, Part I, § 50.54(a)(3)(i)

Organization Section 1.3 Section II, Basic Requirement 1, and includes a commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 1.

Supplement 1S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 1.3 Section II, Supplement 1S-1, and includes a Requirements for and commitment to comply with NQA-1-1994, Part I, Organization Section 2.2 Section II, Supplement 1S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 1S-1.

Additionally, delegation of work addressed by Section 2.2 of Supplement 1S-1 is described in SNC QATR Part II, Section 2.2.

Basic Requirement 2 - Quality N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Assurance Program Section 2.4 Section II, Basic Requirement 2, and includes a commitment to comply with NQA-1-1 994, Part I,Section II, Basic Requirement 2. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 2.

NQA- l- 1994 Conformance Matrix Page 4 of 50 NQA-1-1994, Quality Assurance Reduction in GATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Supplement 2S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 2.4 Section II, Supplement 2S-1, and includes a Requirements for the commitment to comply with NQA-1-1 994, Part I, § 50.54(a)(3)(iv)

Qualification of Inspection Section II, Supplement 2S-1.

and Test Personnel Accordingly, the SNC QATR does not reiterate the § 50.54(a)(3)(ii) requirements of NQA-1-1994, Part I,Section II, Supplement 2S-1. Dominion QATR, Appendix C, Section 6 and Corresponding In addition, Supplement 2S-1, Supplementary NRC SER dated September 9, Requirements for the Qualification of Inspection and 2005, Section 4.3.1 Test Personnel, will include use of the guidance provided in Appendix 2A-1 the same as if it were part of the Supplement. The following two alternative may be applied to the implementation of the requirements of this Supplement and Appendix:

(1) In lieu of being certified as Level 1,11,or III in accordance with NQA-1 -1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of qualify verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections),

evaluating inspection training programs, nor certifying inspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors. For the purpose of these functions, a qualified enqineer is one NQA- 1-1994 Conformance Matrix Page 5 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) who has a baccalaureate in engineering in a discipline related to the inspection activity (such as, electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities.

Supplement 2S N Part II, In lieu of Supplement 2S-2, for qualification of § 50.54(a)(3)(ii)

Supplementary Section 2.4 nondestructive examination personnel, SNC will follow Requirements for the the applicable standard cited in the version(s) of n QATA, Appendix C, Qualification of Section III and Section Xl of the ASME Boiler and S-ec-tion 6 and Co..e.pondin-Nondestructive Pressure Vessel Code approved by the NRC for use at NRC SER dated September 9, Examination Personnel SNC sites. 2006, SectioGn ,.3.1NMC QATR, Section A.5, approved by NRC SER dated March 24, 2005, Section 3.3.1 with the SNC addition of the qualification requirements of ASME Section III, as applicable.

Supplement 2S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 2.4 Section Il, Supplement 2S-3, and includes a Requirements for the commitment to comply with NQA-1 -1994, Part I, § 50.54 (a)(3)(iv)

Qualification of Quality Section II, Supplement 2S-3.

Assurance Program Audit Personnel Accordingly, the SNC QATR does not reiterate the § 50.54(a)(3)(ii) requirements of NQA-1-1994, Part I,Section II, NMC QATR, Section A.5 and Supplement 2S-3. Corresponding NRC SER dated March 24, 2005 In addition, 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 demonstrate his/her ability to properly implement the audit process, as implemented by SNC, to effectively lead an audit team, and to effectively organize and I report results, including participation in at least one NQA- 1-1994 Conformance Matrix Page 6 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) nuclear audit within the year preceding the date of qualification."

Supplement 2S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 2.4 Section II, Supplement 2S-4, and includes a Requirements for commitment to comply with NQA-1-1994, Part I, § 50.54(a)(3)(iv)

Personnel Indoctrination Section II, Supplement 2S-4.

and Training Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 2S-4.

Basic Requirement 3 - Design N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Control Section 3.3 Section II, Basic Requirement 3 and includes a commitment to comply with NQA-1 -1994, Part I, § 50.54(a)(3)(iv)

Section II, Basic Requirement 3.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 3.

Supplement 3S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 3.3 Section II, Supplement 3S-1, and includes a Requirements for Design commitment to comply with NQA-1-1994, Part I, § 50.54(a)(3)(iv)

Control Section II, Supplement 3S-1.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 3S-1.

Basis Requirement 4 - N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Procurement Document Control Section 4.2 Section II, Basic Requirement 4, and includes a commitment to comply with NQA-1-1 994, Part I, § 50.54(a)(3)(iv)

Section II, Basic Requirement 4.

Accordingly, the SNC QATR does not reiterate the NQA- 1-1994 Conformance Matrix Page 7 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) requirements of NQA-1-1994, Part I,Section II, Basic Requirement 4.

Supplement 4S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 4.2 Section II, Supplement 4S-1, and includes a

§ 50.54(a)(3)(iv)

Requirements for commitment to comply with NQA-1-1994, Part I, Procurement Document Section II, Supplement 4S-1 as modified by the Control alternatives and clarifications cited below.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Supplement 4S-1.

In addition, the proposed QATR incorporates the following alternatives/clarifications to Supplement 4S-1:

(a) Section 2.3 of Supplement 4S-1 includes a requirement that procurement documents require (a) § 50.54(a)(3)(ii) suppliers to have a documented quality assurance program that implements NQA-1, Part I. SNC may NMC QATR Section B.4 apply to the procurement document other nationally and corresponding NRC recognized and NRC endorsed quality standards, SER dated March 24, 2005 such as N45.2, in lieu of NQA-1, as appropriate to the circumstances of the procurement.

(b) Clarification is provided in the SNC QATR (b) Clarification only regarding onsite services performed by a supplier.

Specifically, SNC procurement documents may allow the supplier to work under the SNC quality assurance program, including implementing procedures, in lieu of the supplier having its own quality assurance program.

This item provides clarification regarding how the quality assurance program requirements may be aoolied to surmliers of on-site services and does NQA- 1-1994 Conformance Matrix Page 8 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) not represent a deviation from the requirements of NQA-1 -1994.

(G) Section 3 of Supplement 44S- requires procure*m', td*cumnt to bo re*i,.8wed rir to.0 bid or aWAOrd- of contMr-act. The quality assrac revieAY Of procuFGremnt documents. insatisfied through reiWW of the applicable procurement Specification, in.uding !h* technv. al and quality Pr.cur*O envt requ irement prrior to bid orFr aw4Arad of ontFr**c.

Thic item pr.ovides clar~it-ation regarding how the quality assuac reiwOf procurem~ent documents is accomplished and does not reprFecent adevi.Aaatin_ fromA the requirements. of A119.

Basic Requirement 5 - N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Instructions, Procedures, and Section 5.2 Section II, Basic Requirement 5, and includes a Drawings commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 5. § 50.54(a)(3)(ii)

Additionally, the SNC QATR includes a commitment to use Appendix A of Reg. Guide 1.33, Rev. 2, as §50.54(a)(3)(ii) - Instructions, guidance for establishing the types of procedures that procedures, and drawings are are necessary to control and support plant operations. controlled by the SNC QATR in Appendix E to the SNC QATR provides additional a manner consistent with that details regarding procedures developed and described in Section 5.2 of the implemented by SNC. Dominion QATR and corresponding NRC SER dated September 9, 2005.

Basic Requirement 6 - Document N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Control Section 6.2 Section II, Basic Requirement 6, and includes a commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 6. § 50.54 (a)(3)(iv)

NQA 1994 Conformance Matrix Page 9 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Supplement 6S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 6.2 Section II, Supplement 6S-1, and includes a Requirements for commitment to comply with NQA-1 -1994, Part I, Document Control Section II, Supplement 6S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Supplement 6S-1.

Basic Requirement 7 - Control of N Part II, The SNC QATR is consistent with the requirements of § 50.54(a)(3)(i)

Purchased Items and Services Section 7.2 NQA-1-1994, Basic Requirement 7, and includes a commitment to NQA- 1-1994, Basic Requirement 7.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Basic Requirement 7.

Supplement 7S N Part II, The SNC QATR includes a commitment to § 50.54(a)(3)(i)

Supplementary Section 7.2 conformance with the guidance of NQA-1-1994, Requirements for Control of Supplement 7S-1, with the following clarification and Purchased Items and exceptions:

Services (a) SNC considers that other 10 CFR 50 licensees, (a) Clarification only Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to SNC plants are not required to be evaluated or audited.

(b) When purchasing commercial grade calibration (b) § 50.54(a)(3)(ii) services from a calibration laboratory, The proposed alternative is procurement source evaluation and selection consistent with changes to the measures need not be performed provided each Palo Verde QAP requested by of the following conditions are met: Arizona Public Service

- The purchase documents impose any Company letter dated additional technical and administrative September 5, 2004, approved requirements, as necessary, to comply with the by NRC SER dated September NQA-1-1994 Conformance Matrix Page 10 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

SNC QA program and technical provisions. At 28, 2005.

a minimum, the purchase document shall require that the calibration certificate/report include identification of the laboratory equipment/standard used.

- The purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.

- A documented review of the supplier's accreditation shall be performed and shall include a verification of each of the following:

The calibration laboratory holds ap domestic accreditation by the National Voluntary Laboratory Accreditation Program (NVLAP) or by the American Association for Laboratory Accreditation (A2LA) as recognized by NVLAP through athe International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).

" The accreditation is based on ANS/ISO/IEC 17025.

" The published scope of accreditation for the calibration laboratory covers the necessary measurement parameters, ranges, and uncertainties.

(c) Section 8.1, SNC considers documents that may (c) Clarification only be stored in approved electronic media under SNC control and not physically located on the plant site but which are accessible from the NQA- 1-1994 Conformance Matrix Page 11 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site.

(d) For section 10, Commercial Grade Items, controls (d) § 50.54(a)(3)(ii) for commercial grade items are established in SNC documents using the guidance of EPRI NP- Dominion QATR, Section 5652 as discussed in Generic Letter 89-02. 7.5 and Corresponding NRC SER dated September 9, 2005 Basic Requirement 8 - N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Identification and Control of Section 8.1 Section II, Basic Requirement 8, and includes a Items commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 8. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 8.

Supplement 8S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 8.1 Section II, Supplement 8S-1, and includes a Requirements for commitment to comply with NQA-1 -1994, Part I, Identification and Control of Section II, Supplement 8S-1. §50.54(a)(3(iv)

Items Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 8S-1.

Basic Requirement 9 - Control of N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Processes Section 9.1 Section II, Basic Requirement 9, and includes a commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 9. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 9.

NQA- 1-1994 Conformance Matrix Page 12 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Supplement 9S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 9.1 Section II, Supplement 9S-1 and includes a Requirements for Control of commitment to comply with NQA-1-1994, Part I, Processes Section II, Supplement 9S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 9S-1.

Basic Requirement 10 - N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Inspection Section 10.1 Section II, Basic Requirement 10, and includes a commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 10. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 10.

Supplement 1OS N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 10.1 Section II, Supplement 1OS-1 and includes a Requirements for commitment to comply with NQA-1-1 994, Part I, § 50.54(a)(3)(iv)

Inspection Section II, Supplement 1OS-1.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 1OS-1.

Basic Requirement 11 - Test N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Control Section 11.1 Section II, Basic Requirement 11, and includes a commitment to comply with NQA-1-1994, Part I, § 50.54(a)(3)(iv)

Section II, Basic Requirement 11.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 11.

NQA 1994 Conformance Matrix Page 13 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Supplement 11 S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 11.1 Section II, Supplement 11S-1, and includes a Requirements for Test commitment to comply with NQA-1 -1994, Part I, Control Section II, Supplement 11S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 11S-1.

Supplement 11S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 11.2 Section II, Supplement 11S-2, and includes a Requirements for Computer commitment to comply with NQA-1-1994, Part I, Program Testing Section II, Supplement 11S-2. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Supplement 11S-2.

Basic Requirement 12 - Control N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i) of Measuring and Test Section 12.1 Section II, Basic Requirement 12, and includes a Equipment commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 12. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 12.

Supplement 12S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 12.1 Section II, Supplement 12S-1, and includes a Requirements for Control of commitment to comply with NQA-1-1994, Part I, Measuring and Test Section II, Supplement 12S-1. § 50.54(a)(3)(iv)

Equipment Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 12S-1.

NQA-1-1994 Conformance Matrix Page 14 of 50 NQA-1 -1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Basic Requirement 13 - N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Handling, Storage, and Shipping Section 13.2 Section II, Basic Requirement 13, and includes a commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 13. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 13.

Supplement 13S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 13.2 Section II, Supplement 13S-1, and includes a Requirements for Handling, commitment to comply with NQA-1-1994, Part I, Storage, and Shipping Section II, Supplement 13S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Supplement 13S-1.

Basic Requirement 14 - N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Inspection, Test, and Operating Section 14.1 Section II, Basic Requirement 14, and includes a Status commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 14. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 14.

Basic Requirement 15 - Control N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i) of Nonconforming Items Section 15.1 Section II, Basic Requirement 15, and includes a commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 15. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 15.

NQA- 1-1994 Conformance Matrix Page 15 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s)Comments Basis for Acceptance Application (YIN)

Supplement 15S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 15.1 Section II, Supplement 15S-1, and includes a Requirements for the commitment to comply with NQA-1-1994, Part I, Control of Nonconforming Section II, Supplement 15S-1. § 50.54(a)(3)(iv)

Items Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 15S-1.

Basic Requirement 16 - N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Corrective Action Section 16.1 Section II, Basic Requirement 16, and includes a commitment to comply with NQA-1 -1994, Part I,Section II, Basic Requirement 16. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Basic Requirement 16.

Basic Requirement 17 - Quality N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Assurance Records Section 17.2 Section II, Basic Requirement 17, and includes a commitment to comply with NQA-1-1994, Part I,Section II, Basic Requirement 17. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1 -1994, Part I,Section II, Basic Requirement 17.

Supplement 17S N Part II, The SNC QATR is consistent with NQA-1 -1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 17.2 Section II, Supplement 17S-1, and includes a Requirements for Quality commitment to NQA-1 -1994, Supplement 17S-1 with Assurance Records the following exception:

1. Supplement 17S-1, Section 4.2(b) requires records 1. § 50.54(a)(3)(ii) to be firmly attached in binders or placed in folders NMC QATR., Section B.15 and or envelopes for storage in steel file cabinets or on corresponding NRC SER dated shelving in containers. For hard-copy records March 24, 2005 maintained by SNC, the records are suitably stored in steel file cabinets or on shelving in containers, NQA- 1-1994 Conformance Matrix Page 16 of 50 NQA-1 -1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (YIN) except that methods other than binders, folders, or envelopes may be used to organize the records for storage.

Basic Requirement 18 - Audits N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Section 18.2 Section II, Basic Requirement 18, and includes a commitment to comply with NQA-1-1994, Part I, § 50.54(a)(3)(iv)

Section II, Basic Requirement 18.

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Basic Requirement 18.

Supplement 18S N Part II, The SNC QATR is consistent with NQA-1-1994, Part I, § 50.54(a)(3)(i)

Supplementary Section 18.2 Section II, Supplement 18S-1, and includes a Requirements for Audits commitment to NQA-1 -1994, Supplement 18S-1. § 50.54(a)(3)(iv)

Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part I,Section II, Supplement 18S-1.

NQA 1994 Conformance Matrix Page 17 of 50 NOA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N)

Part II- Quality Assurance Requirements for Nuclear Facility Applications (from former NQA-2)

Introduction SUBPART 2.1 - Quality Assurance N Part II, The SNC QATR is consistent with NQA-1-1994, Part § 50.54(a)(3)(i)

Requirements for Cleaning of Fluid Section II, Subpart 2.1, and includes a commitment to comply Systems and Associated 13.2 with NQA-1-1994, Part II, Subpart 2.1 with the Components for Nuclear Power exceptions to Sections 3.1 and 3.2 provided below.

Plants 1 General N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 1.1 Definitions N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 2 General Requirements N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 2.1 Planning N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 2.2 Procedures and N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Instructions Section associated with Subpart 2.1 13.2 NQA- 1-1994 Conformance Matrix Page 18 of 50 NQA-1-1994, Quality Assurance Reduction in QATR Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 2.3 Rectification of N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Unacceptable Cleanness Section associated with Subpart 2.1 13.2 2.4 Control of Cleaning N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Solutions Section associated with Subpart 2.1 13.2 3 Cleanness Criteria N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 3.1 Cleanness Classification N Part II, Subpart 2.1, Sections 3.1 and 3.2, establish criteria § 50.54(a)(3)(ii)

Section for classifying items into cleanness classes and 13.2 requirements for each class. Instead of using the NMC QATR, Section B.7 and cleanness level system of Subpart 2.1, SNC plants Corresponding NRC SER dated may establish cleanness requirements on a case-by- March 24, 2005 (See Section case basis, consistent with the other provisions of 3.3.2)

Subpart 2.1. SNC establishes appropriate cleanliness controls for work on safety related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign materials prior to system closure.

3.2 Cleanness Class Criteria N Part II, See comment on Subpart 2.1, Section 3.1 above. See Basis for Acceptance for Section Subpart 2.1, Section 3.1 above 13.2 3.3 Hydraulic, Instrument N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Control, and Lubrication Section associated with Subpart 2.1 Lines and Systems 13.2 NQA- 1-1994 Conformance Matrix Page 19 of 50 NOA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 3.4 Cleaning and Flushing N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Fluid Quality Section associated with Subpart 2.1 Requirements 13.2 4 Manufacturing Phase Cleanness N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 5 Cleanness Prior to Installation N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 6 Cleanness During Installation N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 7 Maintenance of Installation N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Cleanness Section associated with Subpart 2.1 13.2 8 Preoperational Cleaning N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 8.1 Preparations N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 8.2 Flushing and Cleaning N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Methods Section associated with Subpart 2.1 13.2 9 Layup and Post-layup Cleaning N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 NQA-1-1994 Conformance Matrix Page 20 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 10 Post-Operational Repairs and N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Modifications Section associated with Subpart 2.1 13.2 11 Records N Part II, See Comment associated with Subpart 2.1 above See Basis for Acceptance Section associated with Subpart 2.1 13.2 SUBPART 2.2 - Quality Assurance N Part II, The SNC QATR is consistent with NQA-1 -1994, Part § 50.54(a)(3)(i)

Requirements for Packaging, Section II, Subpart 2.2, and includes a commitment to comply Shipping, Receiving, Storage, and 13.2 with NQA-1 -1994, Part II, Subpart 2.2 with the Handling of Items for Nuclear Power exceptions to Sections 3.2, 3.5, 6.6, and 7.1 Plants described below.

1 General N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 1.1 Definitions N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 2 General Requirements N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 2.1 Planning and Procedures N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 2.2 Classification of Items N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 NQA- 1-1994 Conformance Matrix Page 21 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 3 Packaging N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 3.1 General N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 3.2 Levels of Packaging N Part II, For items in storage, as determined by facility § 50.54(a)(3)(ii)

Section management, the packaging requirements described 13.2 under Section 3, Packaging, may include alternate methods of affording the required protection such as Dominion QATR Section 13.3 maintaining a storage atmosphere free from harmful and corresponding NRC SER contaminants in concentrations that could produce dated September 9, 2005.

damage to the stored items, or utilizing storage practices that obviate the need for capping all openings.

3.3 Cleaning N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 3.4 Methods of Preservation N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 3.5 Caps, Plugs. Tapes. and N Part II, See Comment on Subpart 2.2, Section 3.2 above. See "Basis for Acceptance" for Adhesives Section Subpart 2.2, Section 3.2 above.

13.2 3.6 Barrier and Wrap Materials N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance and Desiccants Section associated with Subpart 2.2 13.2 NQA- 1-1994 Conformance Matrix Page 22 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 3.7 Containers. Crating. and N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Skids Section associated with Subpart 2.2 13.2 3.8 Cushioning. Blocking. N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Bracing. and Anchoring Section associated with Subpart 2.2 13.2 3.9 Marking N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 4 Shipping N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 4.1 General N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 4.2 Transportation N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Requirements Section associated with Subpart 2.2 13.2 4.3 Precautions During N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Loading and Transit Section associated with Subpart 2.2 13.2 4.4 Identification and Markings N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 4.5 Shipments From Countries N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Outside the United States Section associated with Subpart 2.2 13.2 NQA- 1-1994 Conformance Matrix Page 23 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 4.6 Nuclear Material N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Shipments Section associated with Subpart 2.2 13.2 5 Receiving N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 5.1 General N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 5.2 Receiving Inspection N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Requirements Section associated with Subpart 2.2 13.2 5.3 Disposition of Received N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Items Section associated with Subpart 2.2 13.2 5.4 Status Indicating System N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 5.5 Marking N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 5.6 Documentation N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 6 Storage N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 NQA- 1-1994 Conformance Matrix Page 24 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QAtR Comments Basis for Acceptance Application (Y/N) Section(s) 6.1 General N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 6.2 Storage Areas N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 6.3 Storage Methods N Part I, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 6.4 Control of Items in Storage N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 6.5 Removal of Items From N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Storage Section associated with Subpart 2.2 13.2 6.6 Storage Records N Part II, Subpart 2.2, Section 6.6, "Storage Records:" This § 50.54(a)(3)(ii)

Section section requires written records be prepared 13.2 containing information on personnel access. As an Dominion QATR, Section 13.3, alternative to this requirement, SNC documents and corresponding NRC SER establish controls for storage areas that describe dated September 9, 2005.

those authorized to access areas and the requirements for recording access of personnel.

However, these records of access are not considered quality records and will be retained in accordance with the administrative controls of the applicable plant.

7 Handling N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 NQA 1994 Conformance Matrix Page 25 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments SAti Comments Basis for Acceptance Application (Y/N) Section(s) 7.1 General N Part II, Subpart 2.2, Section 7.1, refers to Subpart 2.15 for § 50.54(a)(3)(ii)

Section requirements related to handling of items. The 13.2 scope of Subpart 2.15 includes hoisting, rigging and transporting of items for nuclear power plants. This NMC QATR, Section B.7, and scope exceeds the scope of the NRC's original the corresponding NRC SER endorsement of ANSI N45.2.2 in Regulatory Guide dated, March 24, 2005 1.38, and establishes requirements for which there is no NRC regulatory position. In lieu of compliance with Subpart 2.15, SNC establishes and implements controls 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," SNC performs dynamic load testing over the full range of the lift using test loads at least 110% of the lift weight.

Dynamic test include raising, lowering and traversing the load. Where required, SNC complies with applicable hoisting, rigging and transportation regulations and codes.

8 Records N Part II, See Comment associated with Subpart 2.2 above See Basis for Acceptance Section associated with Subpart 2.2 13.2 SUBPART 2.3 - Quality Assurance N Part II, The SNC QATR is consistent with NQA-1 -1994, Part § 50.54(a)(3)(i)

Requirements for Housekeeping for Section II,Subpart 2.3, and includes a commitment to comply Nuclear Power Plants 13.2 with NQA-1-1994, Part II, Subpart 2.3 with the exceptions to Sections 2.2 and 3.1 described below.

1 General N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 NQA- 1-1994 Conformance Matrix Page 26 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Seti Comments Basis for Acceptance (Y/N) Section(s)

Application 2 General Requirements N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 2.1 Planning and Procedures N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 2.2 Classification of N Part II, Subpart 2.3, Section 2.2 requires the use of five-level § 50.54(a)(3)(ii)

Cleanness Section zone designations. In lieu of the five-level zone 13.2 designations required by Subpart 2.3, Section 2.2, NMC QATR Section B.7 and SNC bases its control over housekeeping activities Corresponding NRC SER dated on a consideration of what is necessary and March 24, 2005 appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

3 Requirements N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 3.1 Control of Site Area N Part II, See "Comment" associated with Subpart 2.3, Section See "Basis for Acceptance" Section 2.2, above. associated with Subpart 2.3, 13.2 Section 2.2, above.

3.2 Control of Facilities N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 NQA-1-1994 Conformance Matrix Page 27 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 3.3 Material and Equipment N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 3.4 Construction Tools, N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Supplies, and Equipment Section associated with Subpart 2.3 13.2 3.5 Surveillance and N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Inspections Section associated with Subpart 2.3 13.2 4 Records N Part II, See Comment associated with Subpart 2.3 above See Basis for Acceptance Section associated with Subpart 2.3 13.2 SUBPART 2.4 - Installation, N Part II, The SNC QATR is consistent with NQA-1-1994, Part § 50.54(a)(3)(i)

Inspection, and Testing Section II, Subpart 2.4 and includes a commitment to comply Requirements for Power, 10.1; with NQA-1-1994, Part II, Subpart 2.4, with the Instrumentation, and Control Section following clarifications: 1. Clarification only Equipment at Nuclear Facilities 12.1 1. Subpart 2.4 commits requires the use of IEEE (ANSI/IEEE 336-1985) 336-1985 which refers to IEEE 498-1985. Both 2. § 50.54(a)(3)(ii)

IEEE 336-1985 and IEEE 498-1985 use the definition of "safety systems equipment" from NMC QATR, Section B.9 IEEE 603-1980. SNC commits to the definition of and Corresponding NRC "safety systems equipment" contained in IEEE SER dated March 24, 2005 603-1980 but does not comply with the balance of that standard.

This item provides clarification only and does not represent a change or deviation from NQA 1994.

NQA- l- 1994 Conformance Matrix Page 28 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s)

2. Section 7.2.1 of ANSI/IEEE 336-1985 requires all items requiring calibration to be labeled or tagged.

In lieu of this requirement, SNC may not label or tag certain items requiring calibration but will provide other means of identification so that appropriate controls can be implemented.

This alternative is consistent with NMC QATR Section B.9 and the corresponding NRC SER dated March 24, 2005.

SUBPART 2.5 - Quality Assurance N Part II, The SNC QATR is consistent with NQA-1-1994, Part § 50.54(a)(3)(i) and Requirements for Installation, Section II,Subpart 2.5, and includes a commitment to comply § 50.54(a)(3)(v)

Inspection, and Testing of 10.1 with NQA-1-1994, Part II, Subpart 2.5.

Structural Concrete, Structural The SNC QATR Part II, Section 10.1, description Steel, Soils, and Foundations for closely matches that contained in Section B.12 of the Nuclear Power Plants NMC QATR. However, Section B.12 of the NMC QATR contains additional information not contained in the SNC QATR. This information restates the requirements of NQA-1 -1994, Subpart 2.5 and incorporation into the QATR would be redundant.

1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 1.1 Definitions N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 2 General Requirements N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 NQA- l- 1994 Conformance Matrix Page 29 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 3 Requirements N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 3.1 Planning and Procedures N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 3.2 Measuring and Test N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Equipment Section associated with Subpart 2.5 10.1 3.3 Laboratory Testing N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 4 Preconstruction Verification N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 4.1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 4.2 Materials Suitability N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 4.3 Construction Processes N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 5 Inspection of Soils and N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Earthwork Section associated with Subpart 2.5 10.1 NQA- 1-1994 Conformance Matrix Page 30 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 5.1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 5.2 Materials N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 5.3 Placing and Compacting N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Equipment Section associated with Subpart 2.5 10.1 5.4 Preplacement N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Preparations Section associated with Subpart 2.5 10.1 5.5 Soils Compaction N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 5.6 In-Process Tests on N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Compacted Fill Section associated with Subpart 2.5 10.1 6 Inspection of Foundation Pile N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance and Caisson Construction Section associated with Subpart 2.5 10.1 6.1 Piles N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 6.2 Caissons N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 NQA 1994 Conformance Matrix Page 31 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 6.3 Required Qualification N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Tests Section associated with Subpart 2.5 10.1 7 Inspection of Concrete N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Construction Section associated with Subpart 2.5 10.1 7.1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 7.2 Protection of Materials N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 7.3 Measuring, Mixing, and N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Transporting Equipment Section associated with Subpart 2.5 10.1 7.4 Preplacement N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Preparations Section associated with Subpart 2.5 10.1 7.5 Concrete Placement N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 7.6 Finishing and Repairs N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 7.7 Curing N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 NQA- 1-1994 Conformance Matrix Page 32 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 7.8 Stress Transfer of N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Pretensioned Members Section associated with Subpart 2.5 10.1 7.9 Post-Tensioning N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 7.10 Shipping and Handling of N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Precast Concrete Section associated with Subpart 2.5 Members 10.1 7.11 In-Process Tests on N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Concrete and Reinforcing Section associated with Subpart 2.5 and Prestressing Steel 10.1 7.12 Mechanical (Sleeve With N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Ferrous Filler Metal) Section associated with Subpart 2.5 Splice Testing 10.1 7.13 Welded Reinforcing Bar N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Splices Section associated with Subpart 2.5 10.1 8 Inspection of Steel Construction N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 8.1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 8.2 Supporting Structures N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 NQA- 1-1994 Conformance Matrix Page 33 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 8.3 Assembly and Erection N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 8.4 High Strength Bolting N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 8.5 Welding N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 9 Data Analysis and Evaluation N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 9.1 General N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 9.2 Concrete and Mechanical N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance (Sleeve With Ferrous Filler Section associated with Subpart 2.5 Metal) Splice Test Data 10.1 Evaluation and Analysis 9.3 Steel Construction Test N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Data Evaluation and Section associated with Subpart 2.5 Analysis 10.1 9.4 Soils Test Data Evaluation N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance and Analysis Section associated with Subpart 2.5 10.1 10 Records N Part II, See Comment associated with Subpart 2.5 above See Basis for Acceptance Section associated with Subpart 2.5 10.1 NQA- 1-1994 Conformance Matrix Page 34 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments tComments Basis for Acceptance Application (Y/N) Sectior(s)

SUBPART 2.7 - Quality Assurance N Part II, The SNC QATR is consistent with NQA-1 -1994, Part § 50.54(a)(3)(i)

Requirements for Computer Section II,Subpart 2.7, and includes a commitment to comply Software for Nuclear Facility 11.2 with NQA-1-1994, Part II, Subpart 2.7.

Applications Accordingly, the SNC QATR does not reiterate the § 50.54(a)(3(iv) requirements of NQA-1 -1994, Part II, Subpart 2.7.

1 General N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 1.1 Definitions N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 2 General Requirements N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 2.1 Applicability N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 3 Software Life Cycle N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 3.1 Requirements Phase N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 3.2 Design Phase N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 NQA- 1-1994 Conformance Matrix Page 35 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 3.3 Implementation Phase N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 3.4 Testing Phase N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 3.5 Installation and Checkout N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Phase Section associated with Subpart 2.7 11.2 3.6 Operations and N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Maintenance Phase Section associated with Subpart 2.7 11.2 3.7 Retirement Phase N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 4 Software Verification and N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Validation Section associated with Subpart 2.7 11.2 4.1 Software Verification N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 4.2 Software Validation N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 5 Software Configuration Control N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 NQA- 1-1994 Conformance Matrix Page 36 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 5.1 Configuration Identification N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 5.2 Configuration Change N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Control Section associated with Subpart 2.7 11.2 5.3 Configuration Status N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Accounting Section associated with Subpart 2.7 11.2 6 Documentation N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 6.1 Plan(s) for Software N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Quality Assurance Section associated with Subpart 2.7 11.2 6.2 Software Requirements N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Documentation Section associated with Subpart 2.7 11.2 6.3 Software Design and N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Implementation Section associated with Subpart 2.7 Documentation 11.2 6.4 Software Verification and N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Validation Documentation Section associated with Subpart 2.7 11.2 6.5 User Documentation N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 NQA- 1-1994 Conformance Matrix Page 37 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 7 Verification Reviews N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 7.1 Software Requirements N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Review Section associated with Subpart 2.7 11.2 7.2 Software Design Review N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 7.3 Development N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Documentation Review Section associated with Subpart 2.7 11.2 8 Problem Reporting and N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Corrective Action Section associated with Subpart 2.7 11.2 9 Access Control N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 10 Software Procurement N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 10.1 Contracted Software N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 10.2 Software Developed Not N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Using Part II Section associated with Subpart 2.7 11.2 NQA-1-1994 Conformance Matrix Page 38 of 50 NQA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 10.3 Procured Software N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Services Section associated with Subpart 2.7 11.2 11 Records N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 12 References N Part II, See Comment associated with Subpart 2.7 above See Basis for Acceptance Section associated with Subpart 2.7 11.2 SUBPART 2.8 - Quality Assurance N The SNC QATR is consistent with NQA-1 -1994, Part § 50.54(a)(3)(i)

Requirements for Installation, II, Subpart 2.8, and includes a commitment to comply Inspection, and Testing of Part II, with NQA-1-1994, Part II, Subpart 2.8, for activities Mechanical Equipment and Section comparable to new plant construction.

Systems for Nuclear Power Plants 1Accordingly, the SNC QATR does not reiterate the requirements of NQA-1-1994, Part II, Subpart 2.8.

1 General N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 1.1 Definitions N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 2 General Requirements N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 2.1 Planning and Procedures N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 NQA 1994 Conformance Matrix Page 39 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 2.2 Prerequisites N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 3 Preinstallation Verification N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 3.1 General N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 3.2 Identification N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 3.3 Processes and N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Procedures Section associated with Subpart 2.8 10.1 3.4 Physical Condition N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 3.5 Site Conditions N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 4 Control During Installation N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Process Section associated with Subpart 2.8 10.1 4.1 General N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 NQA- 1-1994 Conformance Matrix Page 40 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 4.2 Process and Procedures N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Control Section associated with Subpart 2.8 10.1 4.3 Inspection N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 4.4 Installation Checks N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 4.5 Care of Items N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 5 Installed Systems Inspection N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance and Tests Section associated with Subpart 2.8 10.1 5.1 General N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 5.2 Preoperational Testing N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 5.3 Cold Functional Tests N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 5.4 Hot Functional Tests N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 NQA 1994 Conformance Matrix Page 41 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments SAtR Comments Basis for Acceptance Application (Y/N) Section(s) 6 Data Analysis and Evaluation N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 7 Records N Part II, See Comment associated with Subpart 2.8 above See Basis for Acceptance Section associated with Subpart 2.8 10.1 SUBPART 2.15 - Quality Assurance NA Part II, In lieu of the requirements of NQA-1 -1994, Subpart § 50.54(a)(3)(ii)

Requirements for Hoisting, Rigging, Section 2.15, SNC establishes and implements controls over and Transporting of Items for 13.2 hoisting, rigging and transport activities to the extent NMC QATR Section Nuclear Power Plants 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," SNC performs dynamic load testing over the full range of the lift using test loads at least 110% of the lift weight.

Dynamic tests include raising, lowering and traversing the load. Where required, SNC complies with applicable hoisting, rigging and transportation regulations and codes.

1 General NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 1.1 Definitions NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 2 General Requirements NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 NQA- 1-1994 Conformance Matrix Page 42 of 50 NOA-1 -1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments SAtR Comments Basis for Acceptance Application (Y/N) Section(s) 2.1 Planning and Procedures NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 2.2 Classification of Items NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Handled Section associated with Subpart 2.15 13.2 3 Types of Handling Equipment NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 3.1 Standard Manufactured NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Component Section associated with Subpart 2.15 13.2 3.2 Commercial Standard NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Design Equipment Section associated with Subpart 2.15 13.2 3.3 Special Designed NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Equipment Section associated with Subpart 2.15 13.2 3.4 Permanent Plant Handling NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Equipment Section associated with Subpart 2.15 13.2 4 Design Requirements NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 4.1 Standard Manufactured NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Components Section associated with Subpart 2.15 13.2 NQA 1994 Conformance Matrix Page 43 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 4.2 Commercial Standard NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Design Section associated with Subpart 2.15 13.2 4.3 Special Designed NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Equipment Section associated with Subpart 2.15 13.2 5 Acceptance Criteria for NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Manufactured Handling Section associated with Subpart 2.15 Equipment 13.2 5.1 Standard Manufactured NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Components Section associated with Subpart 2.15 13.2 5.2 Commercial Standard NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Design Section associated with Subpart 2.15 13.2 5.3 Special Design Equipment NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 6 Testing, Inspection, and NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Maintenance Section associated with Subpart 2.15 13.2 6.1 Testing NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 6.2 Inspection NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 NQA 1994 Conformance Matrix Page 44 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QAtR Comments Basis for Acceptance Application (Y/N) Section(s) 6.3 Maintenance NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 7 Control of the Use of Handling NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Equipment Section associated with Subpart 2.15 13.2 7.1 Handling Category A NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Items Section associated with Subpart 2.15 13.2 7.2 Handling Category B NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Items Section associated with Subpart 2.15 13.2 7.3 Handling Category C NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Items Section associated with Subpart 2.15 13.2 8 Qualifications of Personnel NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 8.1 Person-In-Charge (PIC) NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 8.2 Engineer NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 8.3 Inspector NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 NQA- 1-1994 Conformance Matrix Page 45 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments SAtR Comments Basis for Acceptance Application (Y/N) Section(s) 9 Records NA Part II, See Comment associated with Subpart 2.15 above See Basis for Acceptance Section associated with Subpart 2.15 13.2 SUBPART 2.16 - Requirements for N Part II, The SNC QATR is consistent with NQA-1 -1994, Part § 50.54(a)(3)(i) the Calibration of Measuring and Section II, Subpart 2.16, and includes a commitment to Test Equipment Used in Nuclear 12.1 comply with NQA-1 -1994, Part II, Subpart 2.16 with Facilities (ANSI/IEEE 498-1985) the following exception:

(a) Subpart 2.16, Section 5.5 of ANSI/IEEE 498-85 (a) § 50.54(a)(3)(ii)

(NQA-1, Subpart 2.16) requires all M&TE to be labeled. SNC plants may not label certain NMC QATR, Section B.9 M&TE, such as installed instrumentation, but will and corresponding NRC provide other means of identification so that SER dated March 24, 2005.

appropriate controls can be implemented.

SUBPART 2.18 - Quality Assurance N Part I, SNC is committed to NQA-1-1994, Parts I and II, § 50.54(a)(3)(i)

Requirements for Maintenance of Section I except as specified in the QATR. Accordingly, SNC Nuclear Facilities is committed to NQA-1 -1994, Part II, Subpart 2.18.

1 General N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2 General Requirements N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2.1 Responsibilities N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2.2 Procedures N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 NQA- 1-1994 Conformance Matrix Page 46 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments QATR Comments Basis for Acceptance Application (Y/N) Section(s) 2.3 Cleanness Control N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2.4 Environmental and N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Seismic Qualifications Section I associated with Subpart 2.18 2.5 Work Authorization N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2.6 Equipment History N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 2.7 Verification of N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Maintenance Work Section I associated with Subpart 2.18 2.8 Updating of Maintenance N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Procedures from Vendor Section I associated with Subpart 2.18 Technical Manuals and Industry Bulletins 3 Preventive Maintenance N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 3.1 General N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 3.2 Plans and Procedures N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 4 Corrective Maintenance N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 4.1 General N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 NQA- 1-1994 Conformance Matrix Page 47 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 4.2 Identification. Reporting. N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance and Documenting of Section I associated with Subpart 2.18 Equipment or Systems Requiring Corrective Maintenance 4.3 Assessments and N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Evaluations Section I associated with Subpart 2.18 4.4 Implementing Corrective N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Maintenance Section I associated with Subpart 2.18 5 Records N Part I, See Comment associated with Subpart 2.18 above See Basis for Acceptance Section I associated with Subpart 2.18 SUBPART 2.20 - Quality Assurance N Part I, SNC is committed to NQA-1-1994, Parts I and II, § 50.54(a)(3)(i)

Requirements for Subsurface Section I except as specified in the QATR. Accordingly, SNC Investigations for Nuclear Power is committed to NQA-1-1994, Part II, Subpart 2.20.

Plants 1 General N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 1.1 Definitions N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 2 General Requirements N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 2.1 Planning N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 2.2 Procedures and N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Instructions Section I associated with Subpart 2.20 NQA-1-1994 Conformance Matrix Page 48 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 2.3 Results N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 2.4 Personnel Qualifications N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 3 Verification Requirements N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 3.1 General Requirements N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 3.2 Preinvestigation N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 3.3 Field Activities Verification N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 3.4 Laboratory Activities N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Verification Section I associated with Subpart 2.20 3.5 Engineering Activities N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Verification Section I associated with Subpart 2.20 4 Field investigation N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Requirements Section I associated with Subpart 2.20 4.1 General Requirements N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 4.2 Field Operations N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Requirements Section I associated with Subpart 2.20 4.3 Field Equipment N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Requirements Section I associated with Subpart 2.20 NQA-1-1994 Conformance Matrix Page 49 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments SAtR Comments Basis for Acceptance Application (Y/N) Section(s) 4.4 Surveying Requirements N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 4.5 Boring and Excavating N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Requirements Section I associated with Subpart 2.20 4.6 Sampling and Test N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Requirements Section I associated with Subpart 2.20 5 Laboratory Testing N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated withSubpart 2.20 5.1 General N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 5.2 Scope N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 5.3 Test Methods N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 5.4 Report of Laboratory Test N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 6 Evaluation and Analysis N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 6.1 General N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20 6.2 Analysis of Subsurface N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Conditions Section I associated with Subpart 2.20 6.3 Report of Evaluation and N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Analysis Section I associated with Subpart 2.20 NQA- I - 1994 Conformance Matrix Page 50 of 50 NQA-1-1994, Quality Assurance Reduction in Requirements for Nuclear Facility Commitments Section(s) Comments Basis for Acceptance Application (Y/N) 7 Records N Part I, See Comment associated with Subpart 2.20 above See Basis for Acceptance Section I associated with Subpart 2.20